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U.S. Customs and Border Protection (CBP) has intensified its scrutiny of importer information, with a formal policy effective 18 September 2026. The move focuses on verifying importer details such as identity, address, contact information, and customs declaration authorization, signaling stricter compliance standards. Reports of widespread container detentions, with some involving cargo from Beneficial Cargo Owners (BCOs), have further highlighted the growing importance of robust compliance practices.
Recent reports suggest thousands of containers have faced delays or detentions at U.S. ports. Although CBP has not officially confirmed the scale, discrepancies in importer of record (IOR) details appear to be a key factor, even when other declaration details are correct. This underscores the critical need to ensure IOR information is accurate and consistent, as compliance risks extend beyond cargo declarations alone.
BCOs, who book directly with carriers, may also face exposure due to complex shipping arrangements. When vessel space is acquired through intermediaries, the actual cargo owner, booking party, and IOR may differ, creating vulnerabilities. Sellers using third-party IORs must verify the IOR's identity, business address, EIN, and contact information, as well as ensure a valid Power of Attorney exists between the customs broker and the IOR. A lack of clarity in these areas increases the risk of detentions.
CBP's enhanced verification now requires accurate and complete information on Form 5106, including the IOR's legal name, EIN, business address, and contact details. Customs brokers filing on behalf of an IOR must have a direct Power of Attorney. Indirect authorizations through intermediaries are no longer sufficient. These changes place greater compliance burdens on clearance models reliant on third-party IORs or outdated information.
To prepare for peak season and mitigate compliance risks, sellers should: verify the IOR entity and ensure all information is accurate; review and update Form 5106 details; confirm direct POA authorization between the IOR and customs broker; and reconcile all shipping and clearance documentation. For in-transit cargo, proactive IOR verification and documentation audits are essential to avoid delays.
As CBP tightens its compliance focus, the accuracy of IOR information has become critical. Sellers must act now to address potential vulnerabilities, particularly with the holiday season approaching, to avoid costly delays and disruptions.




