How To Complete CBP Form 5106: Step-by-Step For Merchants And Warehouses

CBP Form 5106 The U.S. Customs and Border Protection form used to create or update importer identity information and request an importer number where applicable. Completing the form correctly prevents filing rejections and helps ensure import entries, bills, and examinations are linked to the correct legal entity within the Automated Commercial Environment (ACE).

This step-by-step guide covers the information CBP expects, how to prepare supporting details, and practical handling tips for merchants, customs brokers, and warehouse teams who manage documentation during onboarding or changes in importer identity.

Prepare Required Information

Before filling the form, gather: the importer’s legal name as registered with the IRS, the EIN or SSN, full physical and mailing addresses, contact names and phone numbers, business structure (corporation, LLC, sole proprietor), and any existing CBP-assigned numbers. If the importer is part of a corporate group or uses a DBA, collect both the legal and trade names.

Step-By-Step Field Guidance

Follow the printed field order on the official form. Common practical steps:

• Legal Name: Enter the importer’s exact legal name — do not use aliases or abbreviations that differ from IRS records.
• Tax Identification: Provide an EIN or SSN. For corporations and partnerships, use EIN. For sole proprietors without EIN, SSN may be used.
• Addresses: Give the physical address where business records are kept and a mailing address if different. PO boxes are acceptable only for mail; a physical address is often required for verification.
• Point Of Contact: List a contact with direct knowledge of import activity (name, title, phone, email) so CBP can resolve questions quickly.
• Requested Action: Mark whether this is a new importer number request, an update, or both.

Who Signs And Submits The Form

Form 5106 must be signed by the importer or an authorized company official. Brokers often submit on behalf of clients with a signed 5106 or power of attorney; when a broker files, ensure the broker includes a statement of authority and retains the signed form in the broker’s records. Electronic submissions through ACE may require supporting documentation to be available on demand.

Supporting Documentation To Keep On File

While CBP may not require every submission to include attachments, maintain documentation such as IRS EIN confirmation letters, articles of incorporation, state business registration, or any legal name-change paperwork. Retain these documents for audit and to respond promptly if CBP requests verification.

Common Errors And How To Avoid Them

Errors that cause delays include mismatched EIN and legal name, using a trade name instead of the legal name, incorrect address formatting, and unsigned forms. To minimize mistakes, compare the 5106 fields line-by-line against the importer’s IRS records before submission and confirm whether the importer already holds an importer number in ACE.

Submission Channels And Timing

Submitters can file a paper Form 5106 per CBP instructions or have a customs broker submit the information electronically via ACE. If a new importer number is needed for an imminent shipment, complete the 5106 before the entry is filed; filing it after an entry may cause delays or require entry amendments.

Practical Warehouse Example

A fulfillment center onboarding a new merchant customer requests a signed Form 5106 during onboarding. The center’s compliance team uses the details to verify that the merchant’s name and EIN match what the nominated customs broker will use on entry filings. When the merchant moves its headquarters, the fulfillment center asks the merchant to submit an updated 5106 to avoid mismatches on future ASNs and entries.

• Timing: File or update before the next entry to avoid rework.
• Authority: Ensure signature authority is documented if a broker submits for the importer.
• Recordkeeping: Keep a dated copy of every 5106 submission and supporting documents for at least five years consistent with CBP record-retention expectations.

When To Update Rather Than Refile

Use an updated Form 5106 when core identifiers change — legal name, EIN, or address. Minor changes in contact names or phone numbers should also be updated but typically don’t necessitate re-requesting a new importer number unless the core legal identity changes.

In short, the CBP Form 5106 must be completed with accurate legal names, tax IDs, and addresses and submitted by the importer or an authorized agent to create or update the importer identity in CBP systems. Completing it carefully reduces entry rejections and keeps import operations running smoothly.