Ensure CF5106 Accuracy to Meet New CBP Regulations
The purpose for sending out the current CF5106 is to allow Taggart’s import clients to update their CF5106 records in order to satisfy new Homeland Security through CBP regulatory expectations as detailed in Executive Order 14411. We recommend all importers thoroughly review all CF5106 instructions prior to the Form’s completion to ensure that all supplied data fully aligns with CBP requirements and guidelines, even though the current form does not currently say “required” for much of the information. While the information was NOT required when the current form was last updated (6/2026). The EO 14411 requires that within 180 days of EO issuance (6/3/2026), the Secretary of Homeland Security must take steps to revise importer eligibility regulations and some of the information the Secretary is directed to collect is explicitly stated in the EO:
(iii) requiring that an IOR provide to CBP additional data and identification information, including anticipated import volumes, year organized, ownership and beneficial ownership disclosures, business affiliation disclosures, and domestic asset disclosures, and any other data that CBP deems necessary.
As a reminder, this is an update to an already existing Customs Record, so CBP should already have the “required” information on file. In fact, many importers just updated their CF5106 data in order to collect CAPE Refunds. Any CF5106 completed now should ensure that the data reported thereon aligns with what CBP already has on file, unless it is an importer’s explicit intent to change that information. The receipt of a completed CF5106 for this update process WILL BE interpreted by Taggart to be that explicit intent and instruction to over-write any existing information. Therefore, please ensure this is indeed your intent.
The most common mistakes or omissions on the CF5106 UPDATE are as follows:
- 1A: Importer Name. The importer’s name listed on the form does not match the company's existing Customs records.
- 1B: Unselected option or missing number. A Taggart import client has either an EIN or a CBP-Assigned number (CAN). List it.
- 1G: Unselected company type. The company is either organized as a Corporation, Partnership or an LLC. This is not a question about how the organization is taxed, but how it was organized.
- 1H: Missing estimated entry count. If you’re getting this email, you’re already an importer and you do not import personal shipments with Taggart because we do not handle them. There are 3 other options.
- 1I: Missing or incorrect types. Most recipients of this newsletter are Importer of Record and Consignee/Ultimate Consignees. If the company files drawback claims, check that box. If the company is set up to receive refunds directly from CBP (like for CAPE) you should check Refunds / Bills as well.
- 2A & 2B: Missing country ISO code or location type (select only one). The instructions say you can leave this blank if the company is in the US.
- 2B: PO Box in Street. CBP requires an actual physical location, a PO Box does meet that requirement. Furthermore, a UPS or similar service address does not meet it either. See instructions for further clarification.
- 2E: Email address. A monitored email address must be provided.
- 2F: Missing website. If the Company has a website domain, list it. Customs brokers are now expected to check that website in some detail.
- 3A: Brief description of your business. We need something, but make it under 32 characters including spaces.
- 3B: Missing or incomplete 6-digit NAICS code. A US company has a NAICS code. It was likely on the local or state business license or applications for the same. CBP wants it.
- 3C: Missing or incomplete 9-digit DUNS number. A US company that has been in business for a bit has a DUNS (Dun and Bradstreet) number . Finding it is not hard if the company does not already know it.
- 3E: Year Established. This is the year the company was legally founded. It should be noted in the company’s founding documentation.
- 3F: Undisclosed related businesses. Homeland Security has been directed to understand related businesses that import products into the USA so they are asking for the information voluntarily for now. We recommend taking this “ask” seriously.
- 3G: Missing city, state, or country ISO code. Make sure the address is complete.
- 3H: Missing information – List the state where the company was originally organized or founded. A company founded in Delaware but operating in Florida is a Delaware organized entity.
- 3I: Missing information. When your company was originally organized, it was given a reference number. CBP wants the business reference number from the state noted in 3H (from Delaware, not Florida continuing the example from 3H). It is probably listed on the company’s annual (or biannual) state registration or renewal.
- 3J: Missing SSN or passport numbers for company officers. Homeland Security is asking for individually identifying information from the company’s owners and officers and disclosures of “Beneficial Owners” on a voluntary basis for now (there is specific language and definitions of “Beneficial Owners” in the instructions), We recommend taking this “ask” seriously.
- 4: Missing signature (digital signatures accepted)
To reiterate, we strongly recommend that the entire Form is completed thoroughly to ensure full compliance with DHS / CBP requirements and to help minimize the risk of having your Importer of Record (IOR) number voided; an action that CBP has indicated it will take in some cases. Please do be advised that the submission of a CF5106 by your company to Taggart will be treated as a request to make such changes as noted in the CF5106 sent, regardless of what has been provided in the past. Therefore, we recommend a thorough review (via your company’s ACE account) the information CBP already has on file