CBP Form 5106, officially called the “Create/Update Importer Identity Form”, is a necessary form that must be filled out in order to import goods into the United States. It’s how U.S. Customs and Border Protection (CBP) collects the basic details about you or your business, and it’s the first step in setting you up as an Importer of Record (IOR).
Once submitted, the form helps CBP create your importer profile and assign you a unique importer number. This number is usually tied to your IRS Employer Identification Number (EIN), Social Security Number (SSN), or, in some cases, a CBP-issued ID. This number is required for clearing shipments through customs and is used to track the importer’s activity, compliance, and financial responsibilities related to duties, taxes, and other obligations.
Frequently Asked Questions
There are a number of questions that are frequently asked about the role of CBP Form 5106 in the import process.
What is the Purpose of CBP Form 5106?
The primary purpose of CBP Form 5106 is to ensure that CBP has accurate, up-to-date information about the parties responsible for importing goods into the U.S. This information supports customs enforcement, trade compliance, and operational efficiency. It helps CBP:
- Identify and verify the legal entity responsible for imports
- Link imports to the correct financial and tax data
- Communicate with importers regarding shipments, compliance, or audits
- Monitor import activity and enforce trade regulations
Filing this form is a prerequisite for anyone who intends to import goods under their name, including manufacturers, businesses, individuals, and foreign entities appointing a U.S. agent or broker.
How to Fill Out CBP Form 5106?
Filling out CBP Form 5106 isn’t overly complicated, but it does require accurate information. The form is divided into sections that collect details about the importer, such as identification, contact info, and financial responsibility. Here’s a breakdown of the main parts:
Importer Identification
Provide your IRS number (EIN or SSN), or request a CBP-assigned ID if you don’t have one. This becomes your importer number for all shipments.
Business or Personal Information
Enter the legal name, address, and contact details for the individual or company importing the goods. Make sure the address matches official tax records or registration documents.
Type of Filing
Choose whether this is a new application, an update to an existing record, or a reactivation of a previous account. If you’ve imported before under a different name or number, you’ll need to reference it here.
Point of Contact
List the name and contact details of the person who can answer questions about the form, this could be the importer, a customs broker, or a designated agent.
CBP Bond Information (if applicable)
If you already have a continuous Customs Bond under your name, include the bond number and surety company information. If you’re a first-time or occasional importer, your service provider may help arrange a single-entry bond under your name as part of the next stages in preparing your import operations, so you typically won’t need to include bond details on this form.
Certifications and Signature
At the end of the form, the importer or their representative must sign and date the document, certifying that all information provided is accurate and up to date.
Where and How to Submit CBP Form 5106
If you’re working with a licensed customs broker, they can submit CBP Form 5106 for you using the ACE Portal, which is the official platform for electronic filings with CBP. Brokers with ABI (Automated Broker Interface) access can also create an IOR through this system.
For importers who don’t use the ACE Portal or need manual processing, the completed and signed form should be emailed to the appropriate Center of Excellence and Expertise (also known as “Centers”) based on your industry. Be sure to write either “New 5106 Add” or “5106 Update” in the subject line of your email. This helps CBP direct it to the right team.
If you’re not sure which Center to use, choose the one that covers the tariff number with the highest value in your shipment. You can find a list of Centers and their contact info in CBP’s official guidelines on the Centers of Excellence and Expertise.
When Do I Need to File CBP Form 5106?
You must file CBP Form 5106 before your first shipment can be cleared by U.S. Customs. Ideally, this form should be submitted well in advance, during the early pre-arrival stage, to avoid delays, entry holds, or added storage costs.
CBP uses the information on this form to create or update your IOR profile, which is essential for processing entries and assigning duties. If you’re working with a customs broker or freight forwarder, they can usually handle this step for you. Keep in mind that, without a valid Form 5106 on file, your goods can’t legally be cleared into the U.S.
Do I Need to Submit CBP Form 5106 for Every Shipment?
No. Once your importer number is created through CBP Form 5106, you don’t need to submit a new form for every shipment. The number stays valid as long as your business details remain the same and you keep importing at least once a year. Under 19 CFR 24.5, CBP removes an importer number from its system after 12 months of inactivity, so a seasonal importer or a business that pauses shipping for a year may need to file a fresh Form 5106 even without any change to their name, address, or tax ID.
If you’re shipping frequently or working with multiple suppliers, having an active importer ID on file simplifies the process and reduces delays. It also helps ensure CBP can easily link your shipments and entry data to your importer profile.
What Happens If Your Importer Number Goes Inactive
An importer number from Form 5106 does not expire on a fixed schedule, but it is not permanent either. Under 19 CFR 24.5, CBP removes an importer identification number from its system after one full year of no import activity tied to that number.
If that happens to you, and then you go back to importing, you cannot just resume using the old number. You will need to file a new Form 5106 from scratch, even though nothing about your business changed. This mostly catches seasonal importers and companies that paused shipping for a year during a slow stretch or a supplier switch. If you import less than once a year, or you are not sure when your last entry was filed, ask your customs broker to check your importer number’s status before you book your next shipment. Finding out it is inactive after your cargo has already left the origin port costs you far more time than checking ahead would.
What Happens if I Don’t File CBP Form 5106 in Time?
If CBP Form 5106 isn’t filed before your shipment arrives in the U.S., your goods may be held at the border or flagged for further review. This can result in delays, added storage fees, or penalties, especially if your entry can’t be processed due to missing importer information.
Customs brokers or freight partners usually identify this issue ahead of time, but if you’re managing the process yourself, it’s important to prepare and submit the form early. Incomplete or late submissions can also affect bonded entries, duties, and other customs-related filings tied to your shipment.
The Most Common Form 5106 Filing Errors
Most delays trace back to a handful of avoidable mistakes.
The EIN or SSN on the form does not match IRS records exactly, sometimes off by a single digit, and CBP’s system rejects the mismatch outright. The legal importer name on the form does not match the name on the commercial invoice and bill of lading, which creates a discrepancy CBP has to resolve manually. An importer reactivating an old account forgets to reference the prior importer number, so CBP treats it as a brand new filing instead of a reactivation. Or the certification block at the end goes unsigned, or gets signed by someone without the authority to sign on the company’s behalf.
Every one of these is a paperwork problem, not a policy problem, which is exactly why a customs broker who files these forms daily tends to catch them before submission rather than after CBP flags them.
How to Avoid Delays When Filing CBP Form 5106?
To avoid delays, make sure you’re using the most recent version of the form and fill out all required fields completely and accurately. Double-check your IRS number and legal business address, as they must match IRS records. If submitting manually, send the form to the correct Center of Excellence and Expertise and clearly mark the email subject line as “New 5106 Add” or “5106 Update.” It’s also helpful to work with a licensed service provider who can catch errors early and file the form through CBP’s electronic system (ACE Portal) on your behalf.
How Long Does It Take for CBP to Process Form 5106?
If you’re submitting a new Form 5106 by paper, CBP usually takes two business days to activate your importer account.
If you’re updating an existing importer profile, such as a change of name or address, it typically takes five business days for CBP to process the update.
Do Incoterms Affect This Form?
While Incoterms and CBP Form 5106 serve different purposes, there’s a connection when it comes to responsibility for customs clearance. For most Incoterms, the U.S.-based buyer files Form 5106. However, in DDP (Delivered Duty Paid) transactions, the foreign seller becomes the Importer of Record and is responsible for customs duties and compliance, including submitting Form 5106. That means even overseas businesses may need to file this form or work with a U.S. agent or broker to do so. Understanding your Incoterms is key, since they determine who must be registered with CBP before a shipment arrives.
Is There a Canadian Equivalent to Form 5106?
Canada doesn’t have a direct equivalent to CBP Form 5106, but it does require importers to register before bringing goods into the country. Canadian importers must obtain a Business Number (BN) from the Canada Revenue Agency (CRA) and activate an import/export program account.
This registration is necessary for customs clearance and is linked to the company’s tax records, much like the IOR system in the U.S. While the processes differ slightly, the purpose is similar: both systems allow customs authorities to track importer activity, ensure compliance, and assign financial responsibility for duties and taxes.
Is This Form Used for Both Air and Ocean Freight?
Yes, CBP Form 5106 is required no matter how your goods are shipped into the United States. Whether your cargo arrives by air, ocean, rail, or truck, this form must be on file to identify the IOR. It’s not tied to the shipping method, but rather to the entity responsible for the import. In other words, if you’re legally responsible for customs clearance, you’ll need to have a valid importer ID created through Form 5106. This applies equally to one-time air shipments and regular ocean freight deliveries handled by freight forwarders or brokers.
What’s the Connection Between Form 5106 and Customs Clearance?
Form 5106 is one of the first steps in getting your goods cleared by CBP. Without it, CBP doesn’t have the basic information needed to create your IOR profile, which is essential for filing entries, calculating duties, and tracking import activity.
The form links directly to other customs-related documents such as bonds, CBP Form 3461 (Entry/Immediate Delivery form), CBP Form 7501 (Entry Summary), and CBP Form 4647 (Notice to Mark/Notice to Re-Deliver).
It ensures the importer is properly registered and accountable. If Form 5106 isn’t submitted in time, your goods may be delayed or held until the necessary importer data is received and processed.