The Amazon FBA import guide for late 2026: your importer number, your bond, and September 18

The short answer: you, not Amazon, are the importer of record for your FBA inventory. With de minimis suspended, every shipment needs a real entry, which means an importer number, a customs bond, and a power of attorney signed directly with a licensed broker. And on September 18, 2026, CBP starts voiding importer numbers whose registration data is wrong, and the most common defect in the FBA world (a forwarder’s or agent’s address on file) is specifically named. Check your record this week.

September 18: the importer-number check

CBP’s notice “Accuracy of Importer of Record Data Submitted to CBP” (91 FR 53627) announces enhanced enforcement of existing registration requirements, starting September 18, 2026, for new and existing importers. If the data on your CBP Form 5106 is inaccurate or incomplete, CBP “will… immediately void the associated IOR number.” No cure period is stated. A voided number is invalid for entry, which for an FBA seller means inventory that can’t clear.

Walk your record against the notice’s own words:

• Physical address: must be “the actual physical location of the business or individual. It cannot be a registered agent, customs broker, freight forwarder, P.O. box, a business service center, or an address of another person or entity.” Two things sellers get wrong in both directions: a huge share of foreign sellers registered with exactly one of those forbidden addresses, and the fix is not buying a U.S. address. CBP’s instructions expressly allow the principal’s home address, and nothing in the notice requires the address to be in the U.S. Your real operating address, wherever it is, is the right answer.
• Email: “must be valid and belong to the IOR.” Not your forwarder’s. This one matters twice, because the voiding notice itself goes “to the email address the IOR most recently submitted.” (CBP copies the customs broker that last filed for you, where applicable, so there’s a second channel, but a seller relying on two intermediaries to forward bad news is not in a good place.)
• Phone: must be valid and belong to the IOR.
• EIN: the IRS employer identification number on file must be accurate.

If your number does get voided, the notice explains reestablishment: email IORProgram@cbp.dhs.gov with the subject line “Enforcing IOR Accuracy” and the identity documentation CBP requests. Better to fix the record before the wave.

You are the importer. Amazon says so too.

The rule and the platform agree completely here. Amazon staff, on its own seller forums: “Amazon will not act as the IOR for your FBA inventory, regardless of the shipment size or value,” and “If you engage the services of a customs broker or a freight forwarder… you must engage them directly. You must also directly make the arrangements for establishing the importer or exporter of record.” Customs law says the matching thing about the paperwork: a broker “must execute a customs power of attorney directly with the importer of record… and not via a freight forwarder or other third party” (19 CFR 111.36(c)(3)), and no arrangement between broker and forwarder may block direct communication between you and your broker. If your POA was something your China-side forwarder put in front of you, signed to someone you’ve never spoken with, that’s the arrangement CBP is currently tightening around.

The three things every seller needs on file

1. An importer of record number. For a U.S. entity, your EIN registered with CBP via Form 5106; without an EIN, an SSN; without either, CBP assigns a number. This registration is exactly the data being enforced on September 18.
2. A customs bond. Continuous versus single-entry is a frequency and duty-exposure decision: regular shippers almost always come out ahead on a continuous bond, occasional shippers may not. (CBP sizes bonds against your activity and risk, so bring your duty numbers to that conversation.)
3. A power of attorney signed directly with your broker. Same-day e-signature, from an officer of your company, to the licensed broker who files for you.

Foreign-entity sellers have one more layer: a nonresident corporation can’t enter goods without a resident agent for service of process and a bond with a resident corporate surety (19 CFR 141.18). Don’t confuse the two rules: you need a registered agent for service of process, and you can’t use that agent’s address as your 5106 physical address. Both are true at once.

Why your old setup broke this year

Until 2025, a sub-$800 parcel could arrive duty-free with no entry at all. That’s over: the de minimis exemption is suspended for every mode (since June 24, 2026 by regulation, permanent by statute on July 1, 2027). Shipments now need real entries at ordinary duty rates, plus this year’s tariff layers.

And one trap specifically for FBA sellers with China-origin goods: informal entry (the simpler, cheaper type) is generally available up to $2,500, but for goods carrying Chapter 99 subchapter III provisions, which is where Section 301 and similar tariffs live, the informal ceiling drops to $250 (19 CFR 143.21). Most Chinese-origin FBA shipments carry those provisions, so formal entry, with a bond, arrives far sooner than sellers expect. Consolidating shipments and setting up properly once beats improvising per parcel. Our low-value shipment guide covers the entry paths in detail.

Selling into Europe too? The EU eliminated its €150 customs-duty relief this year. Since July 1, 2026, consignments at or under €150 pay a transitional €3 per item (where IOSS-exempt or postal; ordinary duty otherwise), running to July 2028, and the EU is reviewing monthly whether to broaden it. The €22 VAT exemption died back in 2021. Plan EU pricing accordingly.

What’s coming for foreign sellers (no date yet, and don’t panic)

Executive Order 14411 directs several changes on a 180-day clock that runs out November 30, 2026: revised importer eligibility rules, a “good standing” requirement, an updated IOR registry, and enhanced recurrent vetting (which extends to brokers and forwarders as well). The harsher foreign-IOR restrictions people are quoting, a ban on informal entries, a bar on continuous bonds (with an exception where revenue is shown to be fully protected), and the CTPAT requirement, carry no date at all; the order says regulations will come “promptly.” Two accurate takeaways: none of it is current law today, and the CTPAT requirement is satisfiable by filing through a CTPAT-validated licensed broker, so a foreign seller doesn’t have to join CTPAT itself.

Four things sellers believe that are false

1. “Amazon can be my ultimate consignee, they’ll give the broker their EIN.” No. Real answer from the seller forums: “Amazon WILL not be the Importer of Record. Any shipments sent that way will get rejected.”
2. “My supplier quoted DDP, so customs is handled.” DDP means your supplier promised to handle it, usually through an arrangement you can’t see, where you may not control your own import record. It also doesn’t cover FDA or other agency filings for regulated goods. Ask who the importer of record on your entries actually is; the answer will be educational.
3. “I’ll buy a U.S. mailbox address.” A mailbox was never sufficient, and as of September 18 a business-service-center address is a voiding defect. Your real address, even a foreign home address, is what CBP wants.
4. “The courier will just be my IOR.” Courier importer-of-record arrangements exist in narrow forms, but as a general plan it means your inventory’s import record and liability live with someone else. It isn’t a substitute for your own registration.

What to do this week

1. Pull your 5106 record and check the four fields: address, email, phone, EIN.
2. Fix the email first, so you’d actually receive any CBP notice.
3. If a forwarder arranged your current POA, re-sign one directly with a licensed broker.
4. Confirm your bond exists and matches your current duty exposure (2026 tariffs pushed many bonds toward insufficiency).

We do all four as part of onboarding, at flat published rates, and verify your identity details rather than copying them, precisely because of the September 18 rule. Our page for e-commerce importers has the bigger picture.

Current as of August 30, 2026. The EO 14411 rulemakings are pending, so details for foreign sellers will change; nothing here is legal advice for a specific business.

Sources

• CBP, “Accuracy of Importer of Record Data Submitted to CBP,” 91 FR 53627 (Aug. 19, 2026)
• Executive Order 14411, 91 FR 35125 (June 10, 2026)
• 19 CFR 111.36; 19 CFR 24.5; 19 CFR 141.18; 19 CFR 143.21
• Council Regulation (EU) 2026/382
• Amazon Seller Central Forums, staff posts: “Importing 101 for FBA Sellers” and “Importer of record”