U.S. Import Compliance Guide
IOR / Bond / CBP Form 5106 / POA / ACE Portal / F865 / CPSC eFiling /
Executive Order Compliance
Prepared & Authored by ATA LOGISTICS
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
Chapter 1. CBP Power of Attorney (POA) — Execution Requirements
When a licensed U.S. Customs Broker files documents with CBP on behalf
of an importer, the broker must hold a valid POA signed by the importer.
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)
1.1 Who May Sign a POA
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
1.2 Signature Requirements — Must Match the ID
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
1.3 Acceptable ID — Must Be a Lawful U.S. Identity Document
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
1.4 Attach Two Documents Only
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
1.5 POA Execution Checklist
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)
Chapter 2. Importer of Record (IOR) Status
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.
Chapter 3. IOR Voided — Reinstatement Process
3.1 Two Types of Void — Two Channels
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.
3.2 Email Format for Reinstatement Request
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
3.3 Six Required Documents — All Mandatory
1. Detailed written explanation of why inaccurate data was provided on
the original CBP Form 5106
2.Fully completed and signed CBP Form 5106— all fields 1A–3J; signatory must be listed in Field 3J
3.Valid, unexpired government-issued photo ID for each officer in Field
3J
4. Valid POA (only if 5106 is signed by an Attorney-in-Fact)
5.IRS documentation proving EIN ownership, dated within last 12 months— IRS-issued to the importer (e.g., 147C); documents submitted to IRS
are not acceptable
6. A copy of the CBP Void Notice
3.4 Acceptable IRS EIN Documents (within 12 months)
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)
Chapter 4. CBP Form 5106 — Key Fields
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 1A: Full legal company name
• Field 1B: ID type — EIN / SSN / CBP-Assigned Number (select one)
• Field 2E: Email (required)— must be accessible by the importer; used for ACE Portal verification
code
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.
Chapter 5. ACE Portal Account Setup
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
Chapter 6. Error Code F865 — HTS Not Allowed for Importer
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
Chapter 7. CPSC eFiling — Electronic Certificate Submission
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.
7.1 Certificate Types & 7 Required Data Elements
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
Each certificate must include:
① Product Identifier (SKU/UPC/GTIN/Model No.)
② Applicable CPSC Standard
③ Testing Lab Name & Accreditation
④ Test Date
⑤ Manufacturer/Importer Contact
⑥ Place of Manufacture
⑦ Certificate Date
7.2 Two Submission Methods
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]
Chapter 8. Compliant U.S. Domestic Importer Guide — June 3, 2026 Executive
Order
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/
8.1 Why You Should NOT Use an Overseas Entity as U.S. IOR
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.
8.2 EO Key Requirements Summary
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
8.3 Proactive Compliance Checklist
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
8.4 IOR Compliance Roadmap
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.
Chapter 9. Quick Reference — Action Guide
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
For reference only. Always verify against the latest official CBP guidance.
CBP: www.cbp.gov | CPSC: www.cpsc.gov | ACE Portal:
ace.cbp.dhs.gov | IRS: www.irs.gov