CBP Form 5106, the Create/Update Importer Identity Form, is what you file with U.S. Customs and Border Protection to establish yourself as an importer before your first formal entry of goods. CBP uses the information to build your record in the Automated Commercial Environment (ACE), and a correctly completed form typically activates a new importer record within about two business days.
Who Has to File, and When
Under 19 CFR 24.5, every person, business, government agency, or other organization must file Form 5106 with their first formal entry or their first request for CBP services that will generate a bill or refund. Formal entry is generally required for commercial shipments valued above $2,500. Some regulated goods — textiles, food, quota items — can trigger a formal entry below that threshold. Shipments that qualify for informal entry, with no other CBP services requested, don’t require a 5106.
If the ultimate consignee is a different party from the importer of record, that consignee needs its own 5106 record. A distributor bringing goods in for another U.S. company means two records in ACE, not one.
Importer numbers don’t stay live indefinitely. CBP voids any importer identification number that has gone unused for one year with no outstanding transactions attached. A voided number has to be reactivated with a fresh 5106 before you can clear goods again. Any material change to the business — legal name, address, corporate structure — also calls for an updated filing.
What to Gather Before You Start
Have these ready before you open the form:
- A tax identification number. Your IRS Employer Identification Number takes priority. If you don’t have an EIN, use the Social Security Number of the principal or owner. If you have neither, common for foreign businesses and individuals, check the “NONE” box and request a CBP-assigned number.
- Your legal business name, exactly as it appears on IRS records or articles of incorporation.
- A physical street address. A P.O. box will not work as the primary address; CBP needs a location where it can reach you for audits or compliance.
- A working phone number and email. Phone numbers must be entered without dashes, as an unbroken string or separated by spaces.
- Names and titles of corporate officers, if you’re filing the extended version of the record.
If you already hold an EIN when you submit, that number automatically becomes your importer identification number and CBP will not issue a separate assigned number. A CBP-assigned number exists strictly for customs purposes and does not substitute for an EIN or SSN when you have one.
Filling Out the Form
The fillable PDF is on the CBP website. It’s organized into numbered blocks, each collecting one specific piece of information.
Type of Action
Your first choice is the type of action. Select “Notification of identification number” for a brand-new record, “Change of Name” to update an existing record’s legal name, or “Change of Address” for a new location. Picking the wrong action is one of the most common errors CBP sees. Selecting “create” when your number already exists generates an error and kicks the submission back.
Identification Numbers and Legal Name
Block 1B holds your EIN or SSN. Block 1E is where you request a CBP-assigned number if you have neither. Block 1F is for an existing CBP-assigned number carried over from a prior filing. Block 1I asks how the identification number will be used: check “Importer of Record” if you’re the party responsible for the goods, or “Consignee/Ultimate Consignee” if you’re the receiving party on someone else’s entry. Enter your legal name exactly as registered with the IRS.
Company Information and Address
Enter the full legal business name and primary street address. CBP will use this address for all correspondence and compliance activity. If you operate under a trade name that differs from your legal name, the form has a field for an alternate importer name. Keep it under 32 characters. Longer entries overflow into a restricted portion of the record and trigger an automatic rejection.
Basic or Extended Record
You can file a basic or an extended record. The basic version covers identification number, legal name, address, and contact information. The extended version adds business structure and ownership, names and identification numbers of corporate officers, expected commodity types, and anticipated shipment frequency. High-volume importers often file the extended version up front, since CBP may request that information later anyway.
Certification
Section 4 is the certification block. The person signing certifies that all information on the form is accurate. Both a printed name and a job title are required. Submitting without a title is another frequent cause of rejection. Whoever signs takes on legal responsibility for the validity of everything on the form.
How to Submit It
Three routes get a completed 5106 to CBP:
- Through a licensed customs broker. This is the most common path for first-time importers. The broker submits the form electronically on your behalf through their ACE connection. The 5106 itself does not require a formal power of attorney, but you’ll likely need one on file with the broker for the entry process, so most brokers handle both together.
- Paper submission to a port of entry. You can send a printed, signed copy to the Port Director at the port where your goods will arrive. CBP typically activates a paper submission within two business days.
- ACE Secure Data Portal. CBP publishes instructions for portal submission, but the ACE portal account application for importers is only available to parties that already have a 5106 record on file. In practice, first-time filings go through a broker or on paper, and the ACE portal handles later updates.
Updates to an existing record, whether a name change or an address change, take roughly five business days to process once CBP receives a correctly completed form.
Formatting Errors That Cause Rejection
CBP has flagged several recurring mistakes that bounce submissions automatically:
- Phone number formatting. Dashes cause a “Pattern Unknown” error. Enter the number as a continuous string (1234567899) or with spaces (123 456 7899).
- Certifier name formatting. The certifying individual’s name must be entered as Last, First, Middle Initial with commas. “John W. Doe” becomes “Doe, John, W.”
- Missing title. Both a name and a title are mandatory in the certification block. A blank title triggers a “Data Element Missing” error.
- Wrong action type. Requesting creation of a new record when your importer number already exists produces an “Importer Number Already on File” error.
- Alternate name overflow. An alternate importer name longer than 32 characters bleeds into a restricted data field and rejects immediately.
All of these are preventable with a formatting check before submission.
After CBP Activates Your Record
An active record puts you in the system but doesn’t yet let you clear goods. Formal entries also require a customs bond on file. A continuous bond covers all your import transactions through any port for 12 months, with a minimum amount generally set at $50,000. A single-entry bond covers one shipment and suits infrequent importers. Your broker or a surety company can arrange either.
With both an active 5106 record and a bond in place, you can begin filing entries. Your importer number, whether it’s an EIN, SSN, or CBP-assigned number, appears on every entry document going forward. Keep the record current. If CBP sends correspondence to a stale address or can’t reach you by phone, shipments can be held at the port until the discrepancy is fixed.
Penalties for False or Inaccurate Information
If required information is missing, CBP will deny your importer number outright. Without an active number you cannot pay duties, taxes, or fees, which effectively blocks your shipments at the border.
Intentionally supplying false information is a federal crime. The form itself warns that false statements, deception, or fraud can bring fines or up to five years’ imprisonment under 18 U.S.C. § 1001. Separately, 19 U.S.C. § 1592 authorizes CBP to impose civil penalties for negligence, gross negligence, or fraud in connection with imports. Clerical errors and honest mistakes of fact are generally excluded unless they form a pattern of negligent conduct. Catching an error yourself and correcting it before CBP opens an investigation, known as a prior disclosure, can significantly reduce any penalty that would otherwise apply.