CBP Form 5106: The Importer ID Form and Why Its Data Matters

CBP Form 5106 creates and updates the identity record behind an importer of record number. It holds the importer's legal name, business addresses and contact details. It used to be a one-time setup form. It now matters for refunds too: since September 18, 2026, CBP can void an importer number whose 5106 shows a broker's address, a P.O. box, or contact details that belong to someone else, and a voided number stalls every refund tied to it.

What the form contains

• Legal name and business type.
• Identification number, usually the company's IRS employer identification number.
• Addresses: The physical business location and a mailing address.
• Contacts for the importer.

The data problems that cause trouble

• A broker's address listed as the importer's address.
• A P.O. box as the physical location.
• Contact details that belong to the broker or another company.
• An outdated record after a move, merger or name change.

Why it matters now

IEEPA refunds through CAPE are tied to the importer number. If CBP voids the number for bad 5106 data, refunds stop until it is fixed. CBP is also holding a large number of approved refunds for importers that never enrolled a refund bank account in ACE. See CAPE Phase 3.

How to check and update it

Ask your customs broker to pull your current 5106 record and confirm every field. Updates are filed through your broker or in ACE.

Frequently asked questions

Do I file a 5106 for every shipment? No. It is filed once and updated when details change.

Can my broker's address appear anywhere? Your broker files on your behalf, but the 5106 should describe your company, not the broker.

How Caspian checks this

Before filing CAPE declarations, Caspian checks the importer record and refund enrollment so nothing holds up the refund. See IEEPA tariff refunds.

Works Cited:

• 19 CFR 24.5, Filing identification number
• CBP: IEEPA Duty Refunds