Customs will start voiding importer numbers outright where the details on file are wrong, and the notice telling you it happened goes to the email address on the form it doubts

Read the second paragraph of this one twice.

Customs and Border Protection put a general notice on public inspection on Tuesday morning saying it is reviewing the identity information every importer of record has on file, and that from 30 days after publication it will void the importer number of anyone whose Form 5106 details turn out to be inaccurate or incomplete. Publication is scheduled for Wednesday. A voided number is invalid for any purpose, which the notice spells out to include entering merchandise into the United States.

What is on the form

Six things are mandatory: the importer name, an employer identification number or Social Security number or CBP-assigned number, a mailing address, a physical address where it differs, a phone number and an email address. The notice says each one must be accurate, complete, and belong directly to the importer. Optional fields cover company structure, beneficial ownership and officers.

Where a customs broker submits the form, the broker must hold a power of attorney executed directly with the importer. The notice cites the regulation and puts broker-supplied information under the same standard as the importer's own.

The authority

This traces to Executive Order 14411, Strengthening Customs Enforcement, signed on June 3 and published a week later. Section 2(e) directs Homeland Security to confirm that active importers of record are compliant with applicable regulations and disclosures. The notice adds that CBP is separately working on revised importer eligibility regulations, guidance and policies, and that those will be announced later.

Nothing here is a rulemaking. There is no comment period, no proposed rule and no request for views. It is a general notice announcing enforcement of requirements that already exist.

How you find out

CBP will email you. The notice goes to the address the importer most recently submitted, with a copy to the broker that last filed an entry for that importer where there is one, and it explains the basis for the void and how to ask for the number to be reestablished.

That is worth sitting with for a second, because the field that carries the notice is one of the six the review is checking. An importer whose email address on file is out of date is exactly the importer whose number is at risk, and the message saying so is going to the address that is out of date.

Reestablishment requests and questions go to the trade office by email, under the subject line the notice specifies.