A Practical Guide to CBP Form 5106

If you import goods into the United States, you will almost certainly meet CBP Form 5106 at some point. It is not paperwork for show. It is the legal way U.S. Customs and Border Protection (CBP) identifies importers, consignees, and other parties that appear on entries.

Get this right and your shipments clear faster. Get it wrong, and customs holds, delays, and phone calls follow. This article explains what Form 5106 is, when and why you must file it, what information it collects, how to submit it, and common pitfalls to avoid.

What Is Form 5106 and Why Does It Matter?

CBP Form 5106, officially titled the Create/Update Importer Identity Form, is the form importers use to create or update their importer identification on CBP systems. It assigns or confirms your Importer of Record (IOR) Number, which CBP uses to track your shipments and customs filings.

The form is required by CBP before you can submit your first formal import entry or request services that involve paying duties or receiving refunds. It applies regardless of mode of transport, like air, ocean, truck, or rail.

Why is it important?

By signing the 5106 customs form, you are confirming that you are the importer of record and accept responsibility for duties and taxes, or compliance violations.

Furthermore, CBP and federal trade statistics show imports into the U.S. amount to trillions of dollars per year. As U.S. imports are massive in scale, accurate importer identity keeps statistics, duties, and compliance records straight. It also helps carriers and brokers avoid unnecessary holds when they hand an entry to CBP for processing.

Who Needs to File Form 5106?

The regulation spells it out: any person, business, government agency, or other organization that intends to make a formal entry must file. It might be importers of record, consignees, and ultimate consignees listed on an entry. For most Incoterms, the U.S. importer is the one filing 5106. But for terms like DDP,  the foreign seller handles customs and submits Form 5106. In most cases, your customs broker will file this data electronically on your behalf.

In practice, this importer identity form covers most commercial shipments and informal shipments above low-value thresholds. The rule is not optional. If you will be on a formal entry, the 5106 comes first.

Shipping carriers and brokers often require an importer to have a completed 5106 on file before they process certain shipments. For example, major carriers such as FedEx provide instructions saying international shipments above a set value commonly trigger a 5106 requirement for customs clearance paperwork. Requirements and carrier practices vary, so check with your carrier, customs broker, or freight forwarder.

When to File: Timing and Retention Rules

You must have a valid 5106 on file before CBP can clear your first shipment. It should be submitted before shipment arrival to avoid holds and storage charges. You cannot obtain a Continuous Customs Bond without a 5106 on file. If you are a new importer, the 5106 is Step 1; the Bond is Step 2.

Once on file, you do not refile for every shipment; you refile only to update or reactivate your record (for example, after a name, address, tax ID change, or switching importer type between individual and company).

Under 19 CFR 24.5, an importer identification number remains on record for one year after it was last used, and it will be removed if unused for a year. So if you return to importing after the number is removed, you need to file a new 5106.

What Information Does Form 5106 Collect?

The customs form 5106 asks for identification details that let CBP uniquely identify the importer and link transactions to the right taxpayer ID. Typical blocks include:

• Filing type that indicates whether this is a new importer, a change of name or address, or a reactivation of an inactive number

• Importer or business name and address

• IRS Employer Identification Number (EIN) of the company or Social Security Number (SSN) if an individual

• If no EIN or SSN exists, a request for a CBP-assigned number (used mainly by foreign businesses)

• Active contact details and electronic filer information

• Prior customs numbers or related entities, when applicable

• Certification signature and privacy notice explaining the SSN collection authority

CBP uses this information to verify importers, to detect related parties, and to maintain enforcement and trade statistics. The Privacy Act and applicable law allow CBP to collect SSNs and taxpayer identification numbers for these purposes.

How to Submit Form 5106

There are two main routes.

Electronic via ACE Secure Data Portal

CBP accepts importer identity data through the ACE (Automated Commercial Environment) portal. Large importers and brokers use ACE to submit Form 5106 information. ACE is also the primary route for self-filers and sophisticated brokers.

Paper Form

CBP still offers the fillable PDF of Form 5106, which you can print, sign and deliver to the appropriate CBP office or present to your broker. Many smaller importers or foreign businesses begin with the paper copy to request a CBP-assigned number. The official CBP PDF contains explicit instructions and a privacy notice you must read.

If you have an EIN, it usually becomes your importer identification number automatically. But foreign businesses without U.S. taxpayer IDs should request a CBP-assigned number on the form; CBP will return a copy with the assigned number. When in doubt, work with your customs broker. They submit the form often and can prevent simple errors that cause clearance delays.

ship your cargo

Common Errors That Cause Delays

Errors are surprisingly common. Watch for these:

• Entering an incorrect or inactive EIN or SSN.

• Mismatching the importer name on the 5106 with the name on the commercial invoices or bills of lading.

• Failing to indicate a prior importer number if one exists.

• Incomplete signatures or missing contact info.

• Many delays happen because the broker’s copy is outdated. Make sure your broker has the valid version on file. 

A single wrong digit in an EIN can mean your entry does not associate with your account. That triggers manual reviews and holds. Ask your broker for a copy of the electronic query (like an “ACE screen print”) of your 5106 data to verify it matches your official IRS records exactly. 

Other Common U.S. Import Customs Declaration Documents

The importer number created via 5106 is referenced on entry documents such as CBP Forms 3461 and 7501 and is linked to your bonds and any enforcement or audit activity.

For a standard import entry, the main documents include:

CBP Form 3461 – Entry/Immediate Delivery (for cargo release).

CBP Form 7501 – Entry Summary (detailed declaration of goods, value, duties, etc.).

Commercial Invoice – Provided by the exporter, listing goods, value, buyer/seller info.

Packing List – Item details, weights, measurements.

Bill of Lading / Air Waybill – Contract of carriage from the carrier.

Arrival Notice – From the carrier to notify that goods have arrived.

Other docs depending on goods: Certificates of Origin, Import Licenses, FDA/USDA docs, etc.

FAQs

Any person, business, government agency, or other organization that intends to file a formal entry or request CBP services that could result in a bill or refund must file a 5106. This includes importers of record and ultimate consignees.

File it with your first formal entry or at your first request for services that would lead to a bill or refund. Also, file an updated form when your importer’s name, address, or tax ID changes.

A CBP number (often called an Importer of Record number) is the unique ID U.S. Customs and Border Protection uses to identify who is legally responsible for an import shipment.

Request a CBP-assigned importer number on Form 5106. CBP issues assigned numbers to foreign businesses or individuals without U.S. taxpayer IDs. Be ready to provide supporting documentation.