Importer of Record Deactivated: What CBP Turned Off — and What Still Works

Key takeaways

• "Importer of record deactivated" is narrower than it sounds, and that's the problem. CBP's notice is specific: "Deactivated IOR numbers will be ineligible to transmit a cargo release or entry summary transaction." Two transaction types stop. The account itself doesn't disappear.
• Everything else about your account keeps working, so nothing warns you. Per CBP, the status "will not affect non-entry functions for the IOR such as acting as a consignee, filing drawback claims, reconciliations, securing bonds, transmitting Importer Security Filing information, or other ACE business functions." You find out at the transactions that move the goods — as error F875 on an entry summary, or 333 on a cargo release.
• The trigger is a gap, not a judgment about your business. CBP describes automatic deactivation of accounts "that have not filed an entry in 366 days, pursuant to 19 CFR 24.5."
• If your goods clear under someone else's importer-of-record number, your own number is the one going quiet. As CBP describes the trigger, what's counted is entries filed on the number — not how much you ship.
• There are two documented ways back, and they have different characters. A customs broker transmits a message through ABI with Action Code A; without that route, you email a revised CBP Form 5106 to your Center Entry Team, where CBP says the number "will be reactivated dependent on the Center's workload." Before either one, CBP tells you to "query and verify the current status of the IOR in the ACE Portal Account."

Importer of record deactivated: the "Inactive for Entry Purposes" status CBP deployed on July 16, 2026

Short answer, because you probably arrived here mid-shipment: your importer-of-record number wasn't cancelled, revoked, or penalized. It was moved into a status that blocks two specific transmissions — cargo release and entry summary — because an entry hasn't been filed on it for 366 days. There is a documented way back, and which route you take depends on whether a customs broker can transmit for you.

Here is the change in CBP's own words. On July 14, 2026 at 2:43 PM EDT, CBP sent CSMS # 69241265, and its accompanying Trade User Information Notice (CBP-253, July 2026) opens:

"On July 16, 2026, U.S. Customs and Border Protection (CBP) will introduce a new "Inactive for Entry Purposes" status for Importers of Record (IOR) in the Automated Commercial Environment (ACE)."

And the mechanism:

"This enhancement will enable CBP to automatically deactivate IOR accounts that have not filed an entry in 366 days, pursuant to 19 CFR 24.5."

The CSMS says the same thing with the subsection spelled out — "within 366 days, in accordance with 19 CFR 24.5(e)" — and states the operational consequence twice, once per document:

"Deactivated IOR numbers will be ineligible to transmit a cargo release or entry summary transaction."

"IORs with this status will be ineligible to transmit ACE Cargo Release and ACE Entry Summary transactions."

One line in the notice matters if you or your forwarder self-file through software rather than through a broker's desk: "This update impacts EDI processes." A status change of this kind shows up as a transaction rejection, not as a letter.

Here's the whole thing at a glance, in the language of the two documents:

If you got here from error F875 or 333

These are the two rejection messages, and they're worth reading closely because they describe the same status from opposite ends of a shipment.

On an entry summary:

"F875: IMPORTER INACTIVE FOR ENTRY PURPOSES – The importer of record number is ineligible to transmit an Entry Summary due to having exceeded the allowable time period since the last successfully submitted entry summary."

On cargo release:

"333: IMPORTER INACTIVE FOR ENTRY PURPOSES - An Add/Replace/Update transaction is submitted and the Importer of Record account is deactivated."

Notice the difference in what each one gives you. F875 states the cause — an elapsed period since the last successfully submitted entry summary. 333 states the condition — the account is deactivated. If 333 is what came back to you, the message you're holding contains no clock and no instruction; the explanation lives in the other code's text, above.

One more thing about searching this, because a search for a deactivated importer number tends to land there. CBP maintains a separate FAQ page about voided importer records — a different label, a different procedure, and a page CBP last modified in March 2025, before this status existed. It contains no mention of F875, of 333, or of "Inactive for Entry Purposes." The documents that answer those are the two quoted above.

The distinction is worth holding onto, because the two states are undone differently. A voided record is reinstated by emailing a Form 5106 with identity proof to CBP's bond mailbox, and CBP tells you to "allow 5 business days." The inactive-for-entry status is changed by retransmitting your record, on the timing described further down. CBP's own voided FAQ draws the line for you: "If you are attempting to reactivate an inactive importer record, please note that any licensed Customs broker with ABI access may accomplish this by retransmitting the data to CBP."

Why it fails quietly: everything else about your account still works

This is the part that turns an administrative status into an operational problem, and it appears as an aside in CBP's own notice:

"NOTE: This status does not affect non-entry functions for the IOR such as acting as a consignee, filing drawback claims, reconciliations, securing bonds, transmitting Importer Security Filing information, or other ACE business functions."

Read that as a list of things that will not warn you. Your bond is fine. You can be named as consignee. Importer Security Filing (ISF) information transmits. Drawback and reconciliation work. Each of those is a point where a system could have said this account is inactive. CBP's sentence says only that they are unaffected — it doesn't describe any of them as raising a flag, and none of them is a place we'd expect one. That last step is our inference, not CBP's statement.

What stops is the pair of transactions that actually move the goods: cargo release and entry summary. So the failure surfaces at the point where freight is already booked, already loaded, or already sitting somewhere accruing costs — and it surfaces to whoever is transmitting, which for a small importer usually means a message from a broker or forwarder with a code in it.

If you have a full-time customs team, this is a Tuesday. If you import twice a year and hire a broker per shipment, it's the kind of thing that gets discovered by the person least able to fix it quickly.

Who this actually catches: the once-or-twice-a-year importer

CBP's FAQ on the executive order behind this describes the affected population in one sentence — "Importers of Record (IORs), both foreign and domestic, and any individuals or entities conducting customs business related to the importation of goods into the United States." Foreign and domestic alike; the sentence reaches individuals and entities, not just large filers.

But the 366-day condition selects for a specific profile, and it isn't the profile compliance guidance is usually written for:

• Seasonal and batch importers. If you place one production order a year, your entry-to-entry gap is approximately the length of your ordering cycle. An entry filed in early June 2025 puts day 366 in early June 2026. A single slipped production cycle moves you across a line you didn't know was there. Treat the arithmetic as approximate and give yourself margin rather than counting days to the edge.
• Businesses whose number was created for one shipment. If a broker set up a number years ago for a single import, it has been sitting at zero entries ever since.
• Brands whose goods clear under someone else's number. If your shipments have been moving under a delivered-duty-paid arrangement or a platform's clearance program, goods keep arriving while your own importer-of-record number files nothing. Volume feels healthy; what's counted is entries on the number named on the entry, and that may not be yours. Which party is named there decides more than this status — it also decides who a refund goes to, which we took apart in our brief on who gets the tariff refund.
• Non-resident importers. CBP's FAQ names foreign and domestic alike. A business abroad that imports intermittently has the same clock and, typically, fewer people watching it. This group also faces a separate question — whether a US-formed LLC owned from abroad counts as a US importer of record at all under the executive order behind this change — which we take apart in our brief on the foreign importer of record test.

The part that isn't over: an incremental rollout

It's easy to read July 16 as the event and move on. CBP's notice describes something else — a rollout with an open end:

"On July 16, ACE will begin to deactivate IOR accounts. Initially, IOR accounts with the longest periods of inactivity will be flagged as "Inactive for Entry Purposes." CBP will incrementally deactivate additional IOR accounts until all accounts without an entry in 366 days are updated to this status."

Two words carry the operational weight: "incrementally" and "until." The first pass took the longest-dormant accounts. The stated endpoint is all accounts meeting the condition — not a batch, not a list.

For scale, on a page CBP last modified July 27, 2026, the agency writes that "this status has been automatically applied to approximately 4.8 million Importer of Record (IOR) accounts that have not filed an entry within the past year." We're not going to tell you which batch your number is in, or where the rollout stands today; what's stable across both documents is the condition, not the batch.

That reframes the practical question. "Was I caught in July?" is the wrong one to plan around. The right one is: when did my number last have an entry filed on it, and how close is that to 366 days? A quiet year is what qualifies an account — this year, next year, or the year you switch to a platform program and stop filing under your own number.

How to check your own status before something moves

CBP put the first step in writing, and it comes before contacting anybody:

"Prior to requesting assistance from CBP, please query and verify the current status of the IOR in the ACE Portal Account."

What you're looking for is the account's status. CBP's reactivation bulletin names the two values a broker's message moves between — it describes changing the status "from '20-Inactive' to '10-Active'" — while the July change carries its own label, "Inactive for Entry Purposes." CBP's documents describe those values as what a transaction sets, not as what your portal screen prints, so don't hunt for one exact string. Treat any of them as the same answer: if the number isn't active for entry, the rest of this brief is the procedure. If it is, the useful follow-up is the date of the last entry filed under it.

If a broker files for you, that's a fast phone call — the reactivation route CBP describes for brokers runs through the same interface they transmit entries on, so the party that files for you can generally check and act on the account. If you don't currently know who holds your ACE Portal account or whether one is set up, that gap is worth closing now rather than during a shipment: CBP lists the ACE Account Service Desk at 866-530-4172 / ace.support@cbp.dhs.gov, and ESAR support at esar@cbp.dhs.gov.

Two routes back — and they don't take the same kind of time

The notice gives them in order of preference.

Route A — through a customs broker, over ABI.

"A customs broker should submit an Importer/Consignee Create/Update (TP) message through Automated Broker Interface (ABI) with Action Code A to change the status from Inactive to Active."

CBP's June bulletin adds that "all required CBP Form (CBF) 5106 data elements must be submitted with the TP message" — so the broker isn't flipping a switch, it's re-transmitting your importer record. It also states a preference plainly: "Importers seeking to reactivate their IOR numbers should do so in ACE in coordination with their customs broker to avoid potential delays in processing."

Route B — manual, through your Center.

"Importers who are unable to reactive their IOR numbers via ABI may submit a revised CBP Form 5106 with all the mandatory data elements filled out to their Center Entry Team for manual reactivation."

CBP is specific about how that email has to be constructed:

"The email to which the CBF 5106 is attached must include "IOR reactivation request" in the subject line and explain in the body that the CBF 5106 is being submitted to reactivate an IOR that already exists, but is currently in "20 – Inactive" status."

And about what governs the timing:

"Once received, the IOR number will be reactivated dependent on the Center's workload."

That last sentence is the one to plan around. It's a workload, not a service level. Route A is a message a licensed broker transmits into a system; Route B is a queue at a Center of Excellence and Expertise. Both are documented, and CBP's stated preference for the broker route is expressly about avoiding delay. Questions about the CBF 5106 itself go to IORProgram@cbp.dhs.gov — that's the scope CBP gives that mailbox — and CBP's Form 5106 page holds the form and its instructions.

The sequencing lesson is blunt: this is a pre-shipment task. Doing it while a container waits converts an administrative step into a demurrage question.

One year in the regulation, 366 days in the system

The authority CBP cites is 19 CFR 24.5, a section titled "Filing identification number." Its paragraph (e), headed "Retention of importer identification number," reads in full:

"An importer identification number shall remain on file until 1 year from the date on which it is last used on Customs Form 7501, or its electronic equivalent, or a request for services. If not used for 1 year and there is no outstanding transaction to which it must be associated, the importer identification number will be removed from Customs files. To engage in future transactions described in paragraph (a) of this section, the person, business firm, Government agency, or other organization, previously covered by an importer identificatign [sic] number, must file another Customs Form 5106."

Set that next to what was deployed, and three differences are visible on the page. This is an observation about two texts, not a legal conclusion — we take no position on how the regulation should be read.

1. The number. The regulation says "1 year." The automation runs on 366 days — a year plus a day, or exactly a leap year.
2. The trigger event. The regulation's clock starts when the number was "last used on Customs Form 7501, or its electronic equivalent, or a request for services." CBP's description of the automation keys on whether an entry has been filed. Those aren't phrased identically, which is one more reason to date your last entry rather than reason your way to a deadline from the regulation's wording.
3. The consequence — and where the two texts meet again. The regulation describes the number being "removed from Customs files," and then says what that costs you: to transact again, the party "must file another Customs Form 5106." What ACE applies is a status, and CBP's reactivation bulletin treats it as reviving "an IOR that already exists" rather than issuing a new one. But look at where both roads end. The regulation points at a Form 5106 after removal; both reactivation routes below carry that form's data elements. Whatever the label on the state you're in, the thing that brings a number back is your importer identity record — which is the subject of the closing section.

For background on why this arrived now: CBP's June bulletin ties it to policy directly — "In response to the "Strengthening Customs Enforcement" Executive Order, U.S. Customs and Border Protection (CBP) is exercising its legal authority to deactivate Importer of Record (IOR) numbers in the Automated Commercial Environment (ACE) that have not been used to file entry for one or more years and that have no outstanding post-entry transactions." That order, Executive Order 14411 of June 3, 2026 (91 FR 35125), directs at Sec. 2(e) that "Within 180 days of the date of this order, the Secretary shall update the IOR registry consistent with the policy of this order," including "removing inactive IORs; confirming active IORs are compliant with all applicable regulations and disclosures; and creating risk-based tiers for IORs based on compliance history, enforcement actions, and audit results, among other things." By our own count, 180 days from June 3, 2026 lands in late November 2026. The order reaches further than account status, and we don't predict what lands next; CBP's Strengthening Customs Enforcement page is where the agency posts these changes as they deploy, and it's the page to check rather than this one.

If you have a refund or another post-entry matter in flight

The June bulletin's description of what CBP deactivates carries a second condition alongside the inactivity one: numbers "that have not been used to file entry for one or more years and that have no outstanding post-entry transactions."

Rather than infer which post-entry matters count as outstanding, do the thing CBP asks for first — query the account status in the ACE Portal — and confirm with the Center handling your entries if the answer bears on a live filing. What the documents let us say is narrower and more useful: the functions CBP lists as unaffected include drawback claims and reconciliations, so this status isn't a blanket freeze on post-entry work. It stops entries.

That matters if you're mid-way through a tariff refund, because that process runs on the ACE Portal account and on the question of whose importer-of-record number was on the entry in the first place — a different set of gates, which we sequenced in a separate brief. Account status and refund eligibility are neighboring questions living in the same portal, and it's worth not confusing them.

What to do now

1. Query the status before you do anything else. CBP's instruction is explicit and it precedes contacting the agency: "query and verify the current status of the IOR in the ACE Portal Account." You're checking one thing: whether the number is still active for entry purposes.

2. Find the date of your last filed entry. That's the fact the whole status turns on. Your broker or filer has it. Put day 366 from that date in a calendar with a reminder well ahead of it — this is a standing condition, not a one-time event, and the next time it applies to you is decided by that date.

3. If you're inactive, start with a broker. The ABI route — a TP message with Action Code A, carrying all required CBP Form 5106 data elements — is the one CBP points to "to avoid potential delays in processing."

4. If ABI isn't available to you, use the Center route exactly as specified. A revised CBP Form 5106 with all mandatory data elements, emailed to your Center Entry Team, with "IOR reactivation request" in the subject line and a body that explains the number already exists and is in "20 – Inactive" status. Then plan around CBP's own timing language: "dependent on the Center's workload."

5. Do it before the goods move. Nothing in the unaffected list — bonds, ISF, consignee status — will surface this for you. The first system that says no is the one releasing your cargo.

6. If you self-file, or your software transmits directly, check with your provider. CBP flagged that "This update impacts EDI processes."

The record layer this quietly runs on

Look at what both reactivation routes have in common: CBP Form 5106, with all mandatory data elements. Route A transmits those elements over ABI. Route B attaches the form to an email. Reactivation isn't a button — it's a re-assertion of your importer identification record, the record 19 CFR 24.5 is about in the first place.

Which puts a spotlight on something founders tend to treat as settled: whether the business details in that record still describe where the business actually is and how it can be reached. A business address is not a customs qualification, and having one does not make anyone an importer of record — that's decided on the entry, not by a mailing label. What a stable, verifiable address does is more modest and more boring: it keeps the records a government system checks in agreement with each other, and it keeps you reachable when a Center, a broker, or an account service desk has something to send you.

That isn't an abstraction, and the proof is on the other page we sent you away from earlier. Among the reasons CBP gives for voiding an importer record — a different regime from the status this brief is about, but the same underlying record — are these two: "CBP has received returned (undeliverable) mail when attempting to contact the importer via the US Postal Service" and "Failure to respond to CBP requests sent to the name and address listed on the importer record." The address CBP holds for you is not decorative. It is something CBP acts on. A business that has moved twice, or that never had one consistent address across its filings, tends to discover the drift at exactly the wrong moment — mid-shipment, with a code in an email.

On the US side, our partner save office runs that service; Auteur doesn't operate the US service directly. If your records currently point at a home address, an old address, or three different addresses, set up a US business address through our partner before the next system needs to reach you.

This is general information about a customs development for founders, current as of August 1, 2026 — not legal, tax, or customs advice. CBP's guidance can change after this date; confirm your own account status and the current procedure with US Customs and Border Protection or a licensed customs broker before you act on it.

FAQ

How do you know if you are the importer of record? The importer of record is the party whose IOR number appears on the entry filed for a shipment — not necessarily the business that paid for the goods or bore the duty. The party that filed the clearance holds that record and can tell you whose number was used. There's now a second signal available to you: if a number is yours and you have an ACE Portal account, you can query its status there, and CBP asks that you do so before requesting assistance — "query and verify the current status of the IOR in the ACE Portal Account." If your goods have been clearing for a year while your own number shows no filed entries, that gap is itself informative about who has been acting as importer of record. We sequence the full version of that question, and what it decides about refunds, in our brief on who gets the tariff refund.

How long can an importer of record number go unused before it's deactivated? CBP's automation is described as 366 days without a filed entry: "This enhancement will enable CBP to automatically deactivate IOR accounts that have not filed an entry in 366 days, pursuant to 19 CFR 24.5." The regulation it cites, 19 CFR 24.5(e), is phrased as "1 year from the date on which it is last used on Customs Form 7501, or its electronic equivalent, or a request for services." Because those two descriptions aren't worded identically, the safe practice is to track your actual last-entry date and leave margin rather than computing a deadline to the day.

How long does it take to reactivate a deactivated IOR number? It depends on the route. Through a customs broker, reactivation is a TP message transmitted over ABI with Action Code A, carrying all required CBP Form 5106 data elements — which is why CBP directs importers to coordinate with their broker "to avoid potential delays in processing." Through the manual route, you email a revised CBP Form 5106 to your Center Entry Team, and CBP states that "Once received, the IOR number will be reactivated dependent on the Center's workload." That's a queue rather than a published turnaround, which is the argument for handling this before a shipment is in motion.

Does an inactive importer of record number stop my ISF, bond, or consignee status? No — and that's precisely why this catches people late. In CBP's words, the status "will not affect non-entry functions for the IOR such as acting as a consignee, filing drawback claims, reconciliations, securing bonds, transmitting Importer Security Filing information, or other ACE business functions." What it blocks is narrow: ACE Cargo Release and ACE Entry Summary transactions, which surface as error 333 and error F875 respectively.

Bottom line

This isn't a finding about your business. A counter reached 366 and a status flipped. That's the whole event — and the reason it lands hard on small importers is that CBP switched off the one function that releases goods while leaving the surfaces that could have warned you working normally. Bonds, ISF, consignee status: all green. The red light is at the port.

So the useful posture isn't compliance anxiety, it's a date. Find out when an entry was last filed under your number, check whether it is still active for entry purposes, and if it isn't, get a broker to transmit the TP message with Action Code A — or send the Form 5106 email your Center will want, worded the way CBP specifies. None of these steps is hard. All of them are slower than the shipment that discovers them.

And keep the durable fact rather than the news: the rollout is described as incremental and continuing "until all accounts without an entry in 366 days are updated to this status." Not being flagged so far isn't an exemption. It's a position on the same clock as everyone else's — which means the question to put in your calendar isn't did this happen to me, but when does my quiet year end.