CBP Form 5106: How to Register as an Importer of Record

CBP Form 5106, officially titled "Create/Update Importer Identity Form," is the document that establishes your identity as an importer in U.S. Customs and Border Protection's systems. Every business or individual that imports commercial goods into the United States must have an active importer record with CBP, and Form 5106 is how that record is created.

The form itself is straightforward. It collects basic information about the importing entity: legal name, address, tax identification number, entity type, and bond information. But despite its simplicity, errors on CBP Form 5106 are remarkably common and can delay your first shipment by days or weeks. Approximately 15% of initial 5106 submissions contain errors that require correction before the importer record is created, according to customs broker industry data.

This guide walks through every field on the form, explains the submission process, and identifies the errors that cause the most delays.

What CBP Form 5106 Actually Does

When you file CBP Form 5106, you are creating a record in CBP's Automated Commercial Environment (ACE) system that links your business identity to an importer number. This importer number — which is typically your IRS Employer Identification Number (EIN) preceded by a two-digit code — becomes your permanent identifier for all customs transactions.

Every customs entry filed on your behalf references this importer number. It connects to your customs bond, your entry history, your compliance record, and your duty payment account. Without an active importer record in ACE, your customs broker cannot file an entry for your shipment, and your goods will sit at the port until the record is established.

The form also establishes important legal facts about your importing entity. The address you provide becomes your address of record with CBP — this is where CBP will send penalty notices, audit notifications, and official correspondence. The entity type determines how CBP categorizes your business for compliance purposes. The bond information links your importer record to your financial guarantee.

When You Need to File CBP Form 5106

You must file Form 5106 before your first formal customs entry is submitted. There is no grace period. If your cargo arrives at a U.S. port and you do not have an active importer record, the entry cannot be filed. Your goods will be held at the port, incurring storage charges (typically $75 to $300 per day for containerized cargo) until the record is established.

You need to file Form 5106 in the following situations:

• First-time importers. Any business or individual importing commercial goods into the United States for the first time must file Form 5106 before the first entry.
• DTC brands transitioning from de minimis. If your shipments previously entered under the Section 321 de minimis exemption (which did not require an importer record), you now need to file Form 5106 to establish your identity for formal entry filings. The suspension of de minimis for Chinese-origin goods has made this the most common reason for new 5106 filings in 2025 and 2026.
• Foreign companies importing into the U.S. Non-resident importers must also file Form 5106. Foreign entities use their CBP-assigned importer number (obtained by applying through a customs broker or directly from CBP) since they typically do not have a U.S. EIN.
• Updates to existing records. If your company name, address, entity type, or tax identification number changes, you must file an updated Form 5106. Using outdated information on customs entries can trigger compliance flags and potential penalties.

Who Needs to File

The importer of record is the party legally responsible for the imported goods and is the entity that files CBP Form 5106. This is not always the same as the buyer, the seller, or the company that physically receives the goods.

The following entities need an importer record:

• U.S. businesses importing goods for resale or use. This includes corporations, LLCs, partnerships, and sole proprietorships that buy goods from foreign suppliers.
• DTC and e-commerce brands that source products from overseas manufacturers.
• Individual importers who bring commercial quantities of goods into the United States.
• Foreign entities that sell directly to U.S. consumers and act as the importer of record (rather than using a U.S.-based IOR).
• Customs bonded warehouses and Foreign Trade Zones that receive imported goods.

If you use a third-party logistics provider (3PL) or fulfillment company, they are not your importer of record unless you have specifically assigned them that role. The default IOR is the owner or purchaser of the goods.

Field-by-Field Walkthrough of CBP Form 5106

The form contains approximately 20 fields. Here is what each one requires and where errors most commonly occur.

Section 1: Importer Identification

Importer of Record Number. This is your IRS Employer Identification Number (EIN) preceded by a two-digit prefix. For most businesses, the prefix is "XX" (where XX is determined by CBP based on entity type). If you do not have an EIN, individuals can use their Social Security Number with the prefix "SSN." Foreign entities without a U.S. tax ID will receive a CBP-assigned number.

This is the single most critical field on the form. An incorrect EIN is the number one cause of rejected 5106 filings. Before submitting, verify your EIN against your IRS CP 575 confirmation letter (the letter you received when the EIN was first assigned). Do not rely on memory or business cards — transposed digits are common.

Entity Type. Select the correct entity type: individual, sole proprietorship, partnership, corporation, LLC, or other. The entity type must match your IRS registration. If you registered your EIN as a corporation with the IRS, selecting "LLC" on the 5106 will create a mismatch that may trigger a rejection or require correction.

Section 2: Company Information

Legal Name. Enter your company's legal name exactly as it appears on your IRS tax registration. Do not use trade names, brand names, or DBAs in this field. If your company is legally registered as "ABC Holdings, Inc." but operates under the brand "ABC Direct," the legal name field must show "ABC Holdings, Inc."

Doing Business As (DBA). If you operate under a different name than your legal name, enter the DBA here. This field is optional but helpful for CBP to identify your shipments when the brand name differs from the legal entity name.

Physical Address. Enter the physical street address of your principal place of business. P.O. boxes are not accepted for the physical address field. This address becomes your address of record with CBP for all official correspondence, including penalty notices and audit notifications. Use the address where you can reliably receive and respond to time-sensitive government communications.

Mailing Address. If your mailing address differs from your physical address, enter it here. Otherwise, it can match the physical address.

Phone Number and Email. Provide a direct contact number and email for the person responsible for customs matters at your company. CBP may use these to contact you regarding entry issues, document requests, or compliance questions.

Section 3: Bond Information

Bond Type and Number. If you already have a customs bond in place, provide the bond number and type (single entry or continuous). If you do not yet have a bond, this field can be left blank and updated once the bond is obtained. However, you cannot file a formal entry without both an active importer record and a valid bond.

Surety Code. The three-digit code identifying the surety company that issued your bond. Your customs broker or surety provider will supply this number.

Section 4: Additional Information

Point of Contact. The name and title of the individual authorized to act on behalf of the importing entity for customs purposes. This person should have authority to sign customs documents and respond to CBP inquiries.

Foreign Trade Zone. If your goods will be entered into a Foreign Trade Zone, provide the FTZ number. This field is only applicable if you operate within or receive goods at an FTZ.

How to Submit CBP Form 5106

There are three ways to submit the form, but one is overwhelmingly more common and efficient than the others.

Through Your Customs Broker (Recommended)

The most common and efficient method is to have your licensed customs broker file Form 5106 on your behalf through the ACE system. Your broker will collect the required information from you, complete the form, submit it electronically, and confirm that your importer record has been created.

Most brokers handle Form 5106 as part of their standard client onboarding process. Greenwich Mercantile completes this filing as part of our importer of record setup service. When you provide your EIN, legal name, and address, we file the 5106, arrange your customs bond, and have your importer record active within 24 to 48 hours.

Through ACE (Direct Portal Access)

If you have an ACE portal account, you can submit Form 5106 directly through the system. This requires registering for ACE access, which involves identity verification and can take several days. Most importers do not need direct ACE access — your customs broker files through ACE on your behalf.

Paper Filing to CBP Port Office

You can submit a paper Form 5106 to any CBP port office. This method is slower (5 to 10 business days for processing) and is generally only used when electronic filing is unavailable or for unusual situations requiring in-person documentation.

Processing Time

Electronic filings through ACE are typically processed within 24 to 48 hours. During this processing period, your importer record is being created in CBP's system and linked to your EIN. Once the record is active, your customs broker can immediately begin filing entries on your behalf.

Paper filings take 5 to 10 business days. If your cargo is in transit and expected to arrive within this timeframe, file electronically through a broker to avoid port delays.

Rejected filings — typically due to EIN mismatches or entity type errors — restart the clock. Each correction and resubmission adds another 24 to 48 hours. This is why getting the initial filing right matters: a single typo in your EIN can delay your first shipment by a week.

Common Errors That Delay Processing

Based on broker industry experience, these are the errors that most frequently cause Form 5106 rejections or processing delays.

EIN does not match IRS records. This is the most common rejection reason. Your EIN must exactly match what the IRS has on file. If you recently changed your business name or structure with the IRS, the update may not have propagated to the CBP verification system. Verify your EIN against your IRS CP 575 letter or call the IRS Business and Specialty Tax Line at 800-829-4933 to confirm.

Entity type mismatch. If the IRS has your entity registered as a corporation but you select "LLC" on the 5106, CBP's automated validation may flag the discrepancy. Check your IRS records to confirm your entity classification.

Missing or incorrect bond reference. If you include bond information on the 5106 but the bond is not yet active in CBP's system, the filing may be held pending bond activation. Coordinate with your broker to ensure the bond is filed before or simultaneously with the 5106.

Address format issues. CBP's system has specific formatting requirements for addresses. Abbreviations, special characters, and formatting that deviates from USPS standards can cause validation errors. Use the standardized USPS format for your address.

Using a previously used EIN. If your EIN was previously associated with a different importer record (for example, if you purchased a business), CBP may flag the filing for manual review. In these cases, you may need to provide additional documentation showing the change of ownership.

Relationship to ACE Portal Access

Filing CBP Form 5106 creates your importer record in ACE, but it does not automatically give you access to the ACE portal. ACE portal access is a separate registration process that allows you to view your entry data, access reports, and manage your account directly with CBP.

Most importers do not need direct ACE portal access because their customs broker provides all entry data, status updates, and compliance reports. However, if you want to review your own entry history, check liquidation status, or run compliance reports independently, you can register for ACE access after your importer record is established.

To register for ACE access, go to the ACE Secure Data Portal on CBP.gov, complete the Account Owner Registration, provide your importer number (the same EIN used on your 5106), and complete the identity verification process. ACE portal registration typically takes 3 to 5 business days.

Updating Your Importer Record

Your importer record is not a one-time filing that you can forget about. Whenever key information changes, you must file an updated Form 5106. Failure to update your record means your customs entries contain incorrect information, which CBP treats as a compliance violation.

File an updated 5106 when your company name changes (due to rebranding, merger, or acquisition), your physical address changes, your entity type changes (e.g., converting from LLC to corporation), your bond changes (new surety, new bond number), or your point of contact changes.

Address changes are particularly important because CBP sends official correspondence — including penalty notices, audit notifications, and requests for information — to your address of record. If CBP sends a penalty notice to an outdated address and you fail to respond within the required timeframe, the penalty may become final by default.

This guide reflects CBP Form 5106 requirements and filing procedures as of April 2026. Form requirements and processing procedures are subject to change. Importers should verify current requirements through CBP.gov and consult with a licensed customs broker for filing assistance.