September Newsletter | New CBP Enforcement Sharpens Focus on Form 5106 Accuracy

TOP NEWS: 

CBP sharpens focus on Form 5106 accuracy. Errors could impact your ability to import.

September 18, 2026 is an important date for importers. CBP is strengthening its focus on the accuracy and completeness of CBP Form 5106, the form used to establish and maintain an importer's identity and account with CBP. CBP relies on this information for critical activities including entry and release of merchandise, liquidation, and refunds.

An inaccurate 5106 isn't just a paperwork problem—it could impact your ability to import. Importers should review their 5106 information now and ensure company names, addresses, identification numbers, ownership and other required information are current and accurate.

Don't wait until there's a problem at the border. Review your 5106 today and make sure CBP has the right information about your company.

TRADE FRAUD & CLASSIFICATION RISK

DOJ and DHS ramp up trade fraud enforcement. Is your HTSUS classification ready for scrutiny?

CBP and the Department of Justice are looking more closely at trade fraud—and your HTSUS classifications are part of the picture.

Through the Trade Fraud Task Force, DOJ and DHS are combining enforcement resources to target customs fraud, including misclassification and tariff evasion. Their July 2026 Trade Fraud Resource Guide makes clear that inaccurate classifications can have serious consequences.

Now is the time to take a fresh look at your classifications.

A classification that was correct years ago may not be correct today. Products change. Manufacturing processes change. Tariff provisions change. And sometimes, classifications simply get overlooked.

Don't wait for CBP to find the problem. Find it first.

Read our latest blog, "When Things Aren't What They Appear to Be: The Art and Science of HTSUS Classification", and learn why a proactive classification review could help uncover errors, reduce duty exposure, and strengthen your compliance program.

U.S.-CANADA TARIFF ESCALATION

Canada to impose tariffs on $20 billion in U.S. goods September 8. Is your compliance program ready?

The global trade landscape remains anything but predictable. New tariffs, retaliatory measures and changing trade policies are creating added costs and compliance challenges for companies importing and exporting goods. Recent U.S.-Canada tariff actions are just the latest example, with Canada set to impose additional tariffs on approximately $20 billion of U.S. goods beginning September 8.

For importers and exporters, getting the details right matters. Tariff classification, country of origin, valuation and documentation can directly impact duty liability—and an error can become increasingly costly in today's enforcement environment.

The best defense is preparation. Review your classifications, understand how current and potential tariffs affect your products, and make sure your import and export documentation can withstand increased scrutiny.

The trade rules are changing. Is your compliance program keeping up?