CBP Form 5106 and the New Low-Value Shipment Rules

Why CBP Is Tightening Importer Data

U.S. Customs and Border Protection (CBP) is closing gaps that let shipments enter the country with weak or borrowed importer information. Two actions drive the change: stricter enforcement of CBP Form 5106 data and a proposed overhaul of how low value shipments are entered.

For life science companies that import reagents, research samples, instrument parts and clinical supplies, both actions matter. Many of these shipments are small, frequent and handled through intermediaries, which is exactly where CBP is focusing.

What CBP Form 5106 Is

CBP Form 5106 creates or updates an importer's identity record. It assigns the importer of record number used on every entry, usually an IRS Employer Identification Number (EIN), a Social Security Number or a CBP-assigned number. Our glossary explains the role of the importer of record in more detail.

The form captures six data points: importer name, importer of record number, mailing address, physical location address, phone number and email address. Some records list a broker's or forwarder's contact details instead of the importer's own, and that is now a problem.

What Changed for Form 5106

Under a general notice published in August, CBP may now immediately void an importer of record number if its Form 5106 data is inaccurate or incomplete (Federal Register, Accuracy of Importer of Record Data Submitted to CBP). A voided number cannot be used for any purpose, including entering goods into the United States.

The key requirements are:

• Physical address: It must be the importer's actual place of business. Registered agent offices, broker or forwarder addresses, P.O. boxes and business service centers are not accepted.

• Email and phone: Both must belong to the importer, not to a broker or other third party.

• Power of attorney: A broker filing Form 5106 must hold a power of attorney signed directly with the importer, not through a forwarder (Clark Hill, CBP to Void Importer Numbers for Inaccurate Form 5106 Data).

CBP is reviewing records already on file, not only new filings. It will send notice to the last email address provided, so an outdated email can mean you learn about a voided number only when a shipment is held. Our guide on why you need to sign a power of attorney explains how a direct POA with your broker works.

The Proposed Low-Value Shipments Rule

On October 8, CBP proposed new requirements for informal entry, the process used for shipments valued at $2,500 or less (Federal Register, Low-Value Shipments proposed rule). The proposal follows the end of the de minimis rule. Duty-free entry under section 321 has been suspended since August 29, 2025, and the exemption terminates by law on July 1, 2027.

The proposed changes include:

• Earlier filing: Informal entries would be filed electronically at or before importation, replacing the current window of up to 15 days after arrival.

• Broker as importer of record: A consignee that does not own or purchase the goods, such as a carrier or freight forwarder, would have to appoint a licensed customs broker to act as importer of record.

• Bond requirement: Every informal entry filer would need a single transaction or continuous customs bond.

• More data: Filers would identify the final deliver-to party when it differs from the ultimate consignee.

• Section 232 goods: The $250 limit that keeps certain tariff-affected goods out of informal entry would be removed, allowing them up to $2,500.

What This Means for Life Science Importers

Low value shipments are common in research and clinical work. A vial of antibodies, a replacement sensor or a box of assay kits can easily fall under $2,500. Under the proposed rule, each of these would need complete data, a bond and a valid importer of record before it lands.

The Form 5106 changes add a second risk. Foreign suppliers that ship on a delivered duty paid basis sometimes act as importer of record using a forwarder's U.S. address. If CBP voids that number, your shipment can stall at the border even though your own records are clean.

Materials that already require extra review, such as items covered in our guide to importing human-derived materials into the United States, face even less room for error.

Steps to Take Now

1. Audit your Form 5106 record. Confirm that your name, importer of record number, addresses, phone and email are current and belong to your company.

2. Check your supplier setups. Ask foreign vendors who act as importer of record how their CBP 5106 data is filed.

3. Confirm your power of attorney. Make sure your broker holds a direct POA that names your company.

4. Review your bond. A continuous bond may be more practical if you file frequent informal entries.

5. Clean up shipment data. Accurate values, descriptions and commercial invoices will matter more when entries are filed before arrival.

6. Submit comments if the rule affects you. CBP accepts public comments on the proposal until December 7.

How Mercury Helps

Mercury's customs brokerage team supports life science importers with Form 5106 reviews, direct POA setup, bond guidance and entry filing for shipments of every size. Because we also manage transport and temperature control, your shipment and its customs paperwork move together from pickup to delivery.

Our customs and import training helps your team understand new requirements before they cause delays. Contact Mercury to review your importer setup and keep your shipments moving.