CBP Will Void Inaccurate Importer Numbers Starting September 18 as Congress Sends a Russia Tariff Bill to the President
In case you missed it: this issue is the companion to our Section 338 Canada tariff dispatch, issued September 16 — read it here.
Several regulatory developments demand attention over the next eleven weeks. CBP begins voiding Importer of Record (IOR) numbers — the ID that identifies whoever is legally responsible for an import — for inaccurate Form 5106 data on September 18, 2026 — an address error alone can now halt clearance immediately — and has separately proposed sweeping new supply-chain disclosure requirements in a September 2 Advance Notice of Proposed Rulemaking (ANPRM, a formal heads-up that a rule may be coming, open for public comment before anything is final), with comments due December 1. Congress passed the Lindsey O. Graham Sanctioning Russia Act of 2026 on September 16 and sent it to President Trump, who is expected to sign it; it authorizes tariffs up to 100% on the largest importers of Russian oil and gas. USTR’s Section 301 case — Section 301 is the law letting the President impose tariffs in response to unfair foreign trade practices — against 16 economies for manufacturing overcapacity — Mexico included — remains undecided since May hearings, and the Department of Justice-Department of Homeland Security Trade Fraud Task Force disclosed in July that it has recovered or charged more than $1 billion in customs fraud cases in under a year. Freight costs are diverging: diesel has posted a second straight sharp weekly increase on Middle East-driven disruption even as transpacific container rates ease slightly off their peak-season highs.
| Date | Item |
|---|---|
| Sept. 18, 2026 | CBP begins voiding Importer of Record numbers for inaccurate or outdated Form 5106 data |
| ~Nov. 30, 2026 | Approximate 180-day mark for EO 14411’s IOR-registry and bonding-minimum provisions (no proposal issued yet) |
| Dec. 1, 2026 | Comments due on CBP’s ANPRM, “Heightened Import Disclosures for Supply Chain Visibility” |
- Confirm your Form 5106 address, tax ID, phone, and email with your customs broker before September 18 — CBP will void inaccurate importer numbers automatically, with no warning beyond an email.
- If your supply chain touches a major buyer of Russian oil or gas, watch for tariff designation once S. 5025 is signed — the affected-country list isn’t fixed and is set by trade data at the time.
- Re-verify country-of-origin paperwork on any goods routed through a third country — DOJ’s Trade Fraud Task Force is actively building cases on exactly this.
- If you source from or export to Mexico, China, or another of the 16 Section 301 overcapacity-named economies, put it on your watch list — no tariff rate has been proposed yet, so there’s nothing to act on beyond monitoring.
§01Trade Updates
CBP Will Void Import Numbers for Inaccurate Address Data Starting September 18
Effective September 18, 2026, U.S. Customs and Border Protection will immediately void an Importer of Record (IOR) number if the CBP Form 5106 on file contains inaccurate, incomplete, or outdated information, under the Federal Register notice “Accuracy of Importer of Record Data Submitted to CBP,” published August 19, 2026. The rule requires that the physical address, email, phone number, and IRS employer identification number or Social Security number on file belong directly to the importer and reflect its actual business location.
CBP explicitly disqualifies a registered agent’s address, a customs broker’s address, a freight forwarder’s address, a P.O. box, or a business service center address as the IOR’s physical address. Customs brokers are required to verify the information before submission. If CBP voids a number, it will notify the importer by email and the importer must request reestablishment through IORProgram@cbp.dhs.gov — a process that can halt clearance in the interim. Importers should confirm their Form 5106 details with their broker before the effective date.
Sources: Federal Register, “Accuracy of Importer of Record Data Submitted to CBP,” Doc. 2026-16911 (Aug. 19, 2026)
CBP Proposes Sweeping New Supply-Chain Disclosure Requirements, Comments Due December 1
On September 2, 2026, CBP published an Advance Notice of Proposed Rulemaking (ANPRM), “Heightened Import Disclosures for Supply Chain Visibility,” implementing the broader mandate of Executive Order 14411 to close customs enforcement gaps. The docket poses 64 questions and proposes requiring importers to submit the export declarations, commercial invoices, packing lists, and certificates of origin that foreign exporters already file with their own customs authorities — either for all imports or on a targeted or randomized basis, an open question in the docket itself.
The proposal would also replace the current Manufacturer Identification Code with Global Business Identifiers and other entity-level data to identify manufacturers, shippers, exporters, and sellers on each shipment, and it encourages AI-driven traceability technology, with potentially expanded requirements for Customs-Trade Partnership Against Terrorism (CTPAT) participants — CTPAT is CBP’s voluntary trusted-trader program, which speeds clearance for vetted, low-risk importers. Comments are due December 1, 2026. This ANPRM is separate from, and in addition to, the September 18 Form 5106 enforcement action above; it is also distinct from EO 14411’s still-unproposed IOR-registry and bonding-minimum provisions, which remain due around the 180-day mark in late November.
Sources: Federal Register, “Heightened Import Disclosures for Supply Chain Visibility,” Doc. 2026-17926 (Sept. 2, 2026)
Congress Sends 100% Tariff Authority on Russian Oil Importers to the President
The House passed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (S. 5025) by a vote of 262-159 on September 16, 2026, following Senate passage 86-11 on August 7, 2026. The bill now heads to President Trump, who is expected to sign it. It directs the President to impose tariffs of up to 100% on the five largest importers of Russian crude oil or natural gas, and on countries identified as among the top facilitators of Russian sanctions evasion, with an exemption for countries whose Russian natural gas imports fall under 15% of Russia’s total exports and that are taking meaningful steps to reduce them further.
The legislation also extends the Iran Sanctions Act through 2031 and adds sanctions on Russian financial institutions. Because the tariff targets are determined by trade-flow data at the time of implementation rather than a fixed country list, importers with supply chains touching major energy-trading nations should watch for designation once the bill is signed and implementing guidance follows.
Sources: Congress.gov, S. 5025 — Lindsey O. Graham Sanctioning Russia Act of 2026 (119th Congress); CNBC, “House passes sweeping Russia sanctions bill honoring Lindsey Graham, sends to Trump” (Sept. 16, 2026)
Section 301 Overcapacity Case Against 16 Economies, Including Mexico, Remains Undecided
USTR’s Section 301 investigation into structural excess manufacturing capacity — covering China, the European Union, Japan, South Korea, Vietnam, Taiwan, India, Mexico, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, and Bangladesh — remains open with no determination and no proposed tariff rate as of this issue. The most recent procedural step was the public hearings held May 5-8, 2026, following a comment period that closed April 15, 2026. Canada is not among the 16 named economies in this proceeding.
There is no announced timeline for a determination. Companies with cross-border production tied to sectors under review, including maquiladora operations sourcing from or exporting to any of the 16 named economies, should treat this as an open item to monitor rather than one requiring immediate action.
Sources: Federal Register, “Initiation of Section 301 Investigations… Structural Excess Capacity” (Mar. 17, 2026); USTR, Section 301 — Structural Excess Capacity and Production in Manufacturing Sectors (program page)
DOJ-CBP Trade Fraud Task Force Surpasses $1 Billion in Recoveries
The Trade Fraud Task Force, a joint Department of Justice and Department of Homeland Security initiative launched in August 2025 with CBP, Homeland Security Investigations, IRS Criminal Investigation, and other federal partners, disclosed on July 14, 2026 that it has surpassed $1 billion in civil and criminal recoveries, penalties, forfeitures, and publicly charged losses in under one year of operation. Cases have centered on false country-of-origin declarations, Section 301 tariff evasion, and antidumping and countervailing duty evasion — duties meant to offset goods sold below cost or propped up by foreign government subsidies.
Named settlements include Perfectus Aluminum at $549.5 million for aluminum extrusion duty evasion and Ceratizit USA at $54 million for tungsten carbide duties, alongside criminal charges against Chicago jewelry importers for falsely declaring Indian- and UAE-origin jewelry as Singaporean-made (a form of transshipment, where goods are routed through a third country to disguise where they actually came from and dodge tariffs). The task force is using the False Claims Act, which carries treble damages — triple the amount owed — and lets private whistleblowers sue on the government’s behalf. Importers relying on transshipment or on country-of-origin claims that have not been recently re-verified should treat this milestone as a reason to audit those claims now, not after an inquiry arrives.
Sources: U.S. Department of Justice, Office of Public Affairs, “Trade Fraud Task Force Surpasses $1 Billion in Recoveries and Charged Losses in Less Than One Year” (July 14, 2026)
§02Takeaway for U.S. IORs
What happens if my CBP Form 5106 has outdated address information after September 18, 2026?
CBP will immediately void the Importer of Record number if the Form 5106 on file contains inaccurate, incomplete, or outdated information — including a physical address that actually belongs to a customs broker, freight forwarder, registered agent, P.O. box, or business service center rather than the importer itself. CBP notifies the importer by email, and reestablishing the number requires contacting IORProgram@cbp.dhs.gov, a process that can halt clearance in the meantime. Confirm with your broker now that the address, EIN or SSN, phone number, and email on file are accurate and belong directly to your importing entity.
Will the new Russia sanctions bill affect tariffs on my imports if I don’t import Russian energy?
For most U.S. importers, not directly. The tariff authority in S. 5025 targets the five largest importers of Russian crude oil or natural gas, and countries identified as top facilitators of Russian sanctions evasion, with an exemption for countries under the 15%-of-Russian-exports gas-dependency threshold that are actively reducing imports. Watch whether any of your supply-chain countries end up on that list once the bill is signed and implemented, since a tariff action there could raise landed costs on goods sourced or transshipped through an affected country.
Does CBP’s proposed supply chain disclosure rule mean I need to submit my supplier’s export paperwork?
Not yet. CBP’s September 2, 2026 Advance Notice of Proposed Rulemaking, “Heightened Import Disclosures for Supply Chain Visibility,” is a request for public input, not a final rule. It floats requiring the export declarations, commercial invoices, and certificates of origin that foreign exporters already file with their own customs authorities, and replacing the Manufacturer Identification Code with Global Business Identifiers for manufacturers, shippers, exporters, and sellers. Comments are due December 1, 2026. If your supply chain is complex or multi-tier, start assessing now whether you could produce this documentation, and consider commenting before the rule is finalized.
How should the $1 billion Trade Fraud Task Force milestone change my compliance posture?
The task force’s recoveries are built on false country-of-origin declarations, Section 301 tariff evasion, and antidumping/countervailing duty evasion, prosecuted in part under the False Claims Act, which allows treble damages and whistleblower suits. If your imports rely on transshipment through third countries, or on country-of-origin claims that haven’t been re-verified recently, treat this milestone as a reason to audit those claims proactively rather than wait for a government inquiry.
§03Takeaway for Maquiladoras & Foreign IORs
Is Mexico part of the Section 301 structural overcapacity investigation, and what would tariffs mean for maquiladora operations?
Yes. Mexico is one of 16 economies named in USTR’s Section 301 investigation into structural excess manufacturing capacity, alongside China, the EU, Japan, Korea, Vietnam, Taiwan, India, and others. As of the most recent public hearings in May 2026, USTR has issued no determination and proposed no tariff rate, and there is no announced timeline for one. If your sourcing or export flows touch the sectors under review, this is worth monitoring, but there is nothing to act on yet.
Does the CBP Form 5106 address-accuracy rule apply to Mexican manufacturers who import into the U.S. as Importer of Record?
Yes. Any entity acting as Importer of Record on a U.S. entry, including a Mexican manufacturer using a nonresident-importer program, must have a Form 5106 on file with a physical address that is its actual business location — not the address of its U.S. customs broker, freight forwarder, or a registered agent. Starting September 18, 2026, CBP will void the IOR number immediately if that address, EIN, phone, or email is inaccurate or outdated, which stops entries from clearing until it’s corrected. Confirm your Form 5106 details with your broker before that date.
Could the new Russia sanctions tariffs (S. 5025) indirectly affect Mexican exporters?
Not based on current Russian energy trade data. The bill’s 100% tariff authority targets the five largest importers of Russian crude oil or gas and top facilitators of sanctions evasion, and Mexico does not currently appear among the largest buyers of Russian energy. The named-country list is set by trade data at the time of implementation, so it isn’t fixed — exporters with cross-border supply chains touching a named country should still watch for downstream cost effects even without direct exposure.
Should foreign manufacturers start preparing export documentation for CBP’s proposed Global Business Identifier system?
It’s worth starting now, even though nothing is mandatory yet. CBP’s September 2, 2026 ANPRM proposes collecting the export declarations, invoices, and certificates of origin that foreign exporters already file with their own customs authorities, alongside Global Business Identifiers replacing the current Manufacturer Identification Code. Comments are due December 1, 2026, and foreign manufacturers and maquiladora operators are well positioned to comment on how a randomized versus universal application would affect their operations before CBP finalizes its approach.
§04Freight & Rate Watch
| Region | Price | Week-over-Week | Year-over-Year |
|---|---|---|---|
| U.S. National | $6.285 | +$0.318 | +$2.546 |
| PADD 1 (East Coast) | $6.158 | +$0.414 | +$2.410 |
| PADD 3 (Gulf Coast) | $6.027 | +$0.273 | +$2.638 |
| PADD 5 (West Coast) | $7.250 | +$0.263 | +$2.727 |
National diesel has now risen sharply for a second consecutive week, per EIA data dated September 14, 2026 (next release September 22), after already reaching a record for the week of September 7. The increase tracks the escalating U.S.-Iran tanker conflict in the Strait of Hormuz, which Bloomberg reported on September 14 has pushed war-risk insurance and effective vessel supply tight enough that oil tankers are earning roughly $1 million a day, pulling bunker and diesel pricing higher across the board.
| Lane | Rate | Week-over-Week |
|---|---|---|
| Asia – N. America West Coast | ~$7,600 | -1% |
| Asia – N. America East Coast | ~$9,500 | -3% |
| Asia – North Europe | ~$4,500 | -3% |
| Asia – Mediterranean | ~$4,700 | -1% |
Transpacific and Asia-Europe container rates are estimates from Freightos’ most recent published weekly update and are easing modestly off peak-season highs that matched 2024 levels, even as typhoon-driven congestion at Far East ports continues to support pricing. Freightos characterizes the current window as likely the final stretch of this year’s peak season, with carriers using blanked sailings — scheduled departures they cancel outright — to manage capacity rather than pushing further rate increases.
| Headwinds | Tailwinds |
|---|---|
| National diesel has risen sharply for a second consecutive week — $6.285/gal national, up $0.318 week-over-week per EIA data dated September 14, 2026 — tracking the escalating U.S.-Iran tanker conflict in the Strait of Hormuz, where Bloomberg reports oil tankers earning roughly $1 million a day amid a war-driven ship shortage and surging war-risk insurance costs. | Transpacific and Asia-Europe container rates are easing modestly off their peak-season highs — Asia-USEC down 3% to roughly $9,500/FEU, Asia-USWC down 1% to roughly $7,600/FEU — with Freightos characterizing the current window as likely the final stretch of this year’s peak season. |
| Panama Canal Authority cut daily transit capacity to 32 slots (23 Panamax, 9 Neopanamax) effective September 15, 2026, down from 36 slots earlier this month, after rainfall across the watershed ran 34% below historical average from May through August; a planned draft-limit increase has also been pushed to October 1. | The National Tender Rejection Index — the share of truckload freight offers carriers turn down, a proxy for how tight trucking capacity is — eased to 13.22% for the week of September 14, 2026, down 9% week-over-week per FreightWaves data, with volumes and rejections both softening even as carriers in tightening metros like Cincinnati retain some negotiating power. |
Macro Trade & Policy Watch
A standing feature tracking longer-horizon developments that shape trade flows and routing decisions, distinct from the week’s tariff and rate news above.
Section 338 Canada tariff dispute. Section 338 is a rarely used trade-retaliation authority; the 50% U.S. tariff on Canadian goods it triggered, and Canada’s matching retaliation on roughly C$27.6 billion in U.S. products, remain fully in effect, with Prime Minister Mark Carney signaling openness to resuming talks in a September 14, 2026 interview; no resumption date has been confirmed. That thread is tracked in its own dedicated brief.
Standing compliance watch. The Uyghur Forced Labor Prevention Act (UFLPA) Entity List (187 entities, which bars imports linked to forced labor in China’s Xinjiang region) and the 100% Section 232 tariff — Section 232 lets the President impose tariffs on national-security grounds — on named pharmaceutical companies under Annex III remain in force, with no changes to either this issue.
What to Watch Next Week
President Trump’s signature on S. 5025 and the first tariff designations that follow; whether CBP voids any high-profile importer numbers in the opening days of Form 5106 enforcement; any movement in the Section 301 overcapacity case after months without one; and whether the Strait of Hormuz tanker conflict eases or keeps pushing diesel and bunker fuel higher into next week’s freight numbers.
§05
Navco Trade Advisory & U.S. Customs Brokerage
Navco is a CTPAT-certified U.S. Customs broker (national permit), bonded warehouse and FTZ operator with 3PL and Fulfillment operations in Texas and partner network across the country. With Canada’s Section 338 tariffs still in effect and CBP’s Form 5106 enforcement date now here, the levers below are where we help clients hold the line.
(Commercial section — Navco advisory.)
Form 5106 Accuracy Check Before September 18With CBP voiding inaccurate Importer of Record numbers starting September 18, Navco’s brokerage team can audit your Form 5106 on file — address, EIN, and contact data — before the effective date, not after clearance stops. |
UFLPA & Forced-Labor ScreeningSupply-chain screening against the UFLPA Entity List and emerging CBP disclosure expectations, built into your entry process rather than bolted on after a detention. |
CAPE & Bonded Warehouse ComplianceBonded-warehouse administration — keeping imported goods in a secure, duty-deferred facility until they’re sold or shipped — and CAPE portfolio review designed to keep duty deferral compliant as CBP enforcement priorities tighten. |
Protest Filing & Refund PreservationPreserving your right to recover duties through Post Summary Corrections (PSCs, fixes filed after entry) and protests (formal challenges to a CBP duty decision) while tariff actions like S. 5025 and Section 301 remain in motion. |
In-House Bonded & Foreign-Trade Zone (FTZ) Program Design — Built for Enforcement-Era ComplianceAs CBP tightens importer-identity verification and DOJ’s Trade Fraud Task Force expands its enforcement reach, Navco designs and administers in-house bonded warehouse and FTZ programs engineered to hold up under scrutiny — not just to defer duty, but to document every step of it. Thirty-plus years of CTPAT-certified execution at a national-permit Customs brokerage based in Brownsville, Texas. |
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Contact Navco Trade Advisory: (956) 542-4138 • navcologistics.com • Brownsville, Texas