TABLE OF CONTENTS

Ch. 1

CBP Power of Attorney (POA) — Execution Requirements

Ch. 2

Importer of Record (IOR) Status

Ch. 3

IOR Voided — Reinstatement Process

Ch. 4

CBP Form 5106 — Key Fields

Ch. 5

ACE Portal Account Setup

Ch. 6

Error Code F865 — HTS Not Allowed for Importer

Ch. 7

CPSC eFiling — Electronic Certificate Submission

Ch. 8

Compliant U.S. Importer Guide — June 3 Executive Order

Ch. 9

Quick Reference — Action Guide

POA Summary

① State SOI-registered officer signs  

② Signature must match the ID 

③ Attach a valid U.S.-legal government photo ID  

④ Attach original EIN Letter (CP575 or 147C if lost)

Title

Authority

Notes

President

Yes

Primary authorized officer — preferred signatory

Vice President / Secretary

Yes

Must be listed in the state SOI filing

CEO / CFO / Treasurer

Yes

Must have corresponding state SOI registration

General employee / Manager

No

Not state-registered — POA is invalid

Most Common Rejection

The POA signature does not match the signature on the attached ID. CBP compares them directly — any mismatch results in rejection of the entire submission.

Requirement

Details

Handwritten cursive signature required

Printed names are not accepted as a substitute

Must match the attached ID

Compare against your ID before signing

Printed name must match legal name on ID

Include Middle Initial if it appears on the ID

Electronic signatures generally not accepted

CBP requires original handwritten signatures

Important

A Chinese passport without a valid U.S. work visa or lawful immigration status is NOT acceptable.

ID Type

Accepted?

Notes

U.S. Driver's License

Yes

Most commonly used; must not be expired

U.S. Passport

Yes

Highest authority; must not be expired

Green Card (I-551)

Yes

Must not be expired

Foreign passport with valid U.S. work visa (H-1B/L-1/O-1/TN)

Yes

Visa page must be included; must not be expired

EAD / I-766

Yes

Must not be expired

Chinese passport only (no U.S. visa or status)

No

Cannot establish lawful U.S. presence

B-1/B-2 tourist or F-1 student visa passport

No

Does not confer business or corporate authority

No.

Document

Requirements

1

Valid U.S.-legal government-issued photo ID

Must be an accepted type; unexpired; clear color scan; signature matches POA

2

Original EIN Letter

CP575 or SS-4 confirmation; if lost, request 147C from IRS at 1-800-829-4933

Checklist Item

✓

Signatory is a state SOI-registered officer (President / VP / Secretary or equivalent)

POA bears a handwritten cursive signature — not a printed name

POA signature matches the signature on the attached ID

Printed name below signature matches legal name on ID (including Middle Initial)

Attached ID is a valid U.S.-legal document (Driver's License / U.S. Passport / Green Card / passport with valid work visa / EAD)

Attached ID is not expired

Attached EIN Letter is IRS-issued (CP575, SS-4 confirmation, or 147C)

Status

Meaning

How to Resolve

Active

Valid — entries may be filed normally

No action required

Inactive

Suspended but not voided

Submit updated CBP Form 5106 to the appropriate CEE

Voided

Cancelled — no entries permitted

Email [email protected] with required documentation

Important

A Voided IOR causes every entry to be automatically rejected by ACE (error code F865). The IOR must be reinstated before any shipment can clear customs.

Reason for Void

Email

Notes

Invalid / inaccurate data on CBP Form 5106

[email protected]

CBP issues formal Void Notice; 6 documents required

Bond / financial issue

[email protected]

Resolve bond issue first

Critical

If CBP issued a formal Void Notice, email [email protected] — not [email protected]. These two channels handle different types of void situations.

Field

Content

To (Email)

[email protected]

Subject Line

Voided IOR number [EIN] VT  (e.g., Voided IOR number 12-345678900 VT)

Attachments

See the 6-item document checklist in Section 3.3 below

Document

Notes

147C (EIN Verification Letter)

Best option; call IRS at 1-800-829-4933 — faxed same day

SS-4 Confirmation / 941 / 1120 / 1065

IRS-issued notices sent to the company (not filed by the company to IRS)

Download Form

CBP Form 5106 Official Download:

https://www.cbp.gov/document/forms/cbp-form-5106-createupdate-importer-identity-form

Option

When to Use

Notification of Identification Number

First-time submission or reactivating Inactive IOR

Change of Name / Change of Address

IOR on file — name or address change only

Leave blank

All other updates to existing IOR

Field 3J — Mandatory

All authorized SOI-listed officers should be entered. The 5106 signatory must be listed in 3J. Each 3J officer must provide a valid government photo ID.

Prerequisite

Valid 5106 IOR record must exist in CBP ACE, and POC email must be accurate. If IOR is Voided, complete reinstatement first.

Step

Action

Notes

1

Confirm IOR is reinstated to Active

Complete IORPROGRAM email process if Voided

2

Confirm 5106 POC email is accessible

Verify if a third party filed the 5106

3

Go to https://ace.cbp.dhs.gov — select Importers

4

Complete application; enter full IOR number with suffix (e.g., 12-345678900)

5

CBP sends verification code to POC email; complete verification

If code not received, account cannot be created

6

Account established; access entries, duties, liquidation

F865

One or more HTS codes in the entry are not eligible for the submitted IOR. Deployed to ACE production: June 2, 2026 (CSMS #68674937).

Claim in Circulation

Reality

Verdict

EIN must be pre-registered and bound to HS codes

No such process; CBP validates automatically at filing

Incorrect

F865 takes effect June 2, 2026

Confirmed by official CBP CSMS

Correct

Missing any item locks the container

Only affects entries with ineligible HTS codes

Overstated

Bond will be tied to stores like EU VAT

No CBP official basis

No basis

Product Category

Required Authorization

Medical devices

FDA Device Registration

Wireless / electronic products

FCC equipment authorization

Steel, aluminum, solar panels

AD/CVD compliance filing

Food, dietary supplements

FDA Food Facility Registration

General consumer goods

No requirement — not affected by F865

Deadline

Scope

July 8, 2026 (Mandatory)

All CPSC-regulated consumer product imports

January 8, 2027 (Mandatory)

Products imported through Foreign Trade Zones (FTZs)

What Changes

Previous: Importers retained certificates on file. New: Certificate data must be electronically filed through CBP ACE at the time of entry. Non-compliance: cargo holds up to 60 days, entry refusal, civil penalties up to ~USD 120,500/violation.

Certificate

Products

GCC (General Certificate of Conformity)

General consumer products subject to CPSC mandatory safety standards

CPC (Children's Product Certificate)

Children's products — must be based on CPSC-accepted third-party lab testing

Method

Process

Best For

Method 1: CPSC Product Registry

Register at cpsc.gov/eFiling → Upload product data → Get Reference number → Broker submits Reference PGA Message Set at filing

Repeat imports; stable SKU catalog

Method 2: Full Data per Entry

Prepare 7 data elements → Provide to broker before vessel departure → Broker submits Full PGA Message Set in ACE

Occasional imports; varied product mix

Practical Advice

Most importers do not have direct ABI access and must submit eFiling through their customs broker. Key: prepare test reports and all 7 data elements before shipment departs. Conduct a test submission before July 8, 2026.

CPSC Resources

cpsc.gov/eFiling  |  [email protected]

Executive Order

Strengthening Customs Enforcement  |  Signed June 3, 2026  |  DHS must finalize regulations within 180 days (~Dec 1, 2026)

EO:whitehouse.gov/presidential-actions/2026/06/strengthening-customs-enforcement/

Fact Sheet:whitehouse.gov/fact-sheets/2026/06/fact-sheet-president-donald-j-trump-strengthens-customs-enforcement/

Core Risk

Registering an overseas entity (Hong Kong, Cayman, or China-registered company) as the U.S. IOR creates fundamental legal, financial, and compliance failures — particularly under the June 3 Executive Order. This is not a matter of convenience. It is the line between compliant and non-compliant.

Risk Area

Why It Matters

How the EO Makes It Worse

No U.S. Assets to Back Duty Liability

The IOR is legally responsible for all duties and penalties. If the IOR is overseas, CBP cannot pursue its assets for unpaid duties — creating a shell IOR where goods enter but duty liability has no real backing

EO requires IORs to maintain minimum U.S. tangible domestic assets — overseas entities cannot satisfy this by definition

Bond Cannot Be Established

U.S. surety companies routinely decline overseas entities or demand prohibitive collateral due to opaque credit and asset profiles

EO will increase minimum bond coverage; overseas entities will find it even harder to qualify

No U.S. Physical Presence

IORs must have U.S. physical presence (registered address, business license) or a registered legal agent — overseas companies fail this requirement

EO makes U.S. physical presence an explicit IOR eligibility requirement

CBP Identity Verification Failure

Field 3J requires officers to provide U.S.-legal photo ID. Overseas officers without U.S. work authorization cannot provide qualifying ID — 5106 will be rejected or IOR voided

EO strengthens IOR identity verification; overseas officer ID problem becomes a hard disqualifying condition

POA Legal Validity Questionable

A POA signed by an overseas officer without U.S. legal status has questionable enforceability under U.S. jurisdiction

Under strengthened enforcement, a defective POA directly blocks import operations

Higher Examination Rate

CBP applies significantly stricter scrutiny to entries under overseas IORs — higher exam rates lead to port delays and storage costs

EO directs CBP to increase inspection frequency for high-risk importers

Root Cause of the EO

When violations occur (undervaluation, origin fraud), CBP's ability to pursue overseas entities for penalties is extremely limited — this enforcement gap is a primary reason the EO was issued

EO explicitly targets shell IORs and importers with no substantive U.S. assets or presence

The Right Structure

A compliant U.S. IOR must be: a U.S.-registered entity (Corporation or LLC), with a valid EIN, a U.S. registered address and business license, authorized officers with lawful U.S. immigration status and qualifying ID, and a continuous import bond held in the entity's name.

EO Provision

Requirement

Timeline

IOR Asset Requirement

Maintain minimum U.S. tangible domestic assets and/or bonding at all times

~Dec 1, 2026

Increased Bond Coverage

CBP will increase minimum bond coverage amounts

~Dec 1, 2026

U.S. Physical Presence

Physical presence in U.S. or registered legal agent

~Dec 1, 2026

IOR Identity Verification

Strengthened identity verification; combat fraud and concealment

~Dec 1, 2026

Origin & Duty Compliance

Enhanced enforcement of origin rules, forced labor, and duty payment

Ongoing

Action

Purpose

Confirm IOR is Active; reinstate if Voided or Inactive (Ch. 3)

Satisfy enhanced identity verification requirements

Review all 5106 data for accuracy; update if anything has changed

EO targets inaccurate 5106 data; errors can result in IOR revocation

Contact surety company; assess and increase bond coverage proactively

Insufficient bonding will directly disqualify IOR eligibility under new rules

Document U.S.-based assets (bank accounts, real property, equipment)

EO requires IORs to maintain minimum U.S. tangible domestic assets

Confirm valid U.S. registered address and active business license

EO requires U.S. physical presence or registered legal agent

Clear any outstanding duties or unresolved CBP bills immediately

EO prioritizes duty collection; arrears will jeopardize IOR status

Audit all product origin declarations; avoid misrepresenting origin

EO strengthens rules of origin and forced labor enforcement

Ensure all Field 3J officers hold valid U.S.-legal IDs (see Ch. 1)

Identity verification is a primary focus of the EO

Timeframe

Action

Now

Verify IOR status + Review 5106 accuracy + Assess bond coverage + Clear outstanding duties

Before July 8, 2026

Complete CPSC eFiling preparation (see Chapter 7)

Before Dec 1, 2026 (ahead of DHS deadline)

Increase bond coverage + Document U.S. tangible assets + Confirm U.S. entity registration is current

Ongoing

Update 5106 promptly after any change; maintain regular contact with broker and surety company

Note

The EO is in its implementation phase — CBP's specific regulations are not yet finalized. However, the direction is clear. Preparing now is the most effective way to minimize import disruption when the rules take effect.

Situation

Immediate Action

Ch.

Issuing POA to customs broker

SOI officer signs; signature matches ID; attach U.S.-legal ID + original EIN Letter (CP575 or 147C)

1

IOR voided — inaccurate 5106 data

Email [email protected] — Subject: Voided IOR number [EIN] VT — attach all 6 documents

3

IOR voided — bond / financial issue

Email [email protected]; resolve bond issue first

3

IOR is Inactive

Submit 5106 to CEE — Subject: IOR Reactivation Request

3

CBP Form 5106 never filed

Confirm with bond company; submit new 5106 — Subject: New 5106 Add

4

Need ACE Portal account

Confirm IOR Active + POC email accessible; apply at ace.cbp.dhs.gov

5

Importing regulated products (medical/electronics/steel)

Verify each HTS code aligns with required federal license / registration

6

Importing CPSC-regulated consumer products

Register in CPSC Product Registry; complete eFiling before July 8, 2026

7

Responding to June 3 EO

Verify IOR + review 5106 + increase bond + document U.S. assets + clear duties; build compliant structure before Dec 1, 2026

8