Accurate customs data has become even more important for businesses importing into the US, with Customs and Border Protection increasing scrutiny of importer records and gaining greater scope to invalidate businesses that hold incorrect information on file.
The implications extend beyond US-based importers.
Overseas exporters selling into the United States may depend on customers, subsidiaries, distributors or other entities acting as Importer of Record (IOR). Problems with those records can consequently disrupt the wider supply chain and prevent merchandise entering the country.
From 18 September, CBP began reviewing existing IOR information and can invalidate an importer when details held on Form 5106 are inaccurate or incomplete.
Even relatively straightforward information, including physical and email addresses, telephone numbers and tax identification details can therefore have operational consequences.
Importer records come under greater scrutiny
Form 5106 provides CBP with the identity information it uses for businesses and individuals importing merchandise into the US.
Responsibility for keeping that information accurate remains with the importer, even where a customs broker submits information on its behalf.
Brokers acting for importers must also hold a valid power of attorney executed directly with the IOR.
CBP has indicated that it is comprehensively reviewing new and existing records and is reportedly using AI-based tools to help identify inaccurate or incomplete information.
Where an IOR is invalidated, CBP will notify the importer and provide guidance on restoring its standing.
Until that process is completed, however, the business may be unable to import merchandise into the United States.
Compliance continues after cargo clears
The review forms part of a wider shift towards more data-driven customs enforcement.
For importers, compliance should increasingly be viewed as an ongoing process rather than something completed when cargo is released at the border.
Release can remain conditional while an entry passes through a liquidation process lasting up to 314 days, while supporting records generally need to be retained for five years.
Technology, including AI, also gives CBP greater ability to examine patterns across an importer’s transaction history rather than treating individual shipments entirely in isolation.
That can become particularly relevant when businesses change suppliers, sourcing countries, tariff classifications or declared values in response to changing duties and trade policy.
Those changes may be entirely legitimate, but importers need the records to substantiate them.
Better information needs to start at origin
The practical response begins well before cargo reaches a US port or airport.
Importers need accurate information covering purchase orders, commercial invoices, quantities, origin, classification and valuation before goods leave their suppliers.
For European and UK businesses exporting to the US, the same principle applies. Ensuring that suppliers, customers, brokers and logistics providers are working with consistent information can reduce the risk of discrepancies emerging when declarations are made.
Using a customs broker does not remove the Importer of Record’s underlying compliance responsibilities.
Effective controls around vendor data and shipment documentation are therefore increasingly important.
Connect customs with the wider supply chain
As CBP expands its use of data, customs compliance becomes less effective when treated as an isolated border transaction.
Purchasing information, supplier documentation, freight data and customs declarations need to align throughout the shipment lifecycle.
That makes early visibility and communication across the international supply chain increasingly valuable, particularly for businesses moving goods between Asia, Europe, the UK and the United States.
Global Forwarding connects origin freight management with US customs brokerage and destination logistics, helping customers maintain greater visibility and control from shipment preparation through clearance and final delivery.
With Global Forwarding’s experienced US brokerage team supporting customs clearance and compliance, talk to us about strengthening the processes and information behind your US-bound supply chain.
