4.6 Importer of Record Numbers, CBP Form 5106, and Schedule D Port Codes

4.6 Importer of Record Numbers, CBP Form 5106, and Schedule D Port Codes

Why identifiers get their own section: a released Practical Exercise set supplied a partially completed CBP Form 5106 and asked three questions about it — who may input the data, whose EIN and suffix may be used, and who bears responsibility for accuracy. None of those are answerable from classification or valuation knowledge. They come from 19 CFR 24.5 and the face of the form.

The Identification Requirement (19 CFR 24.5)

CBP cannot process an entry against an unidentified party. Under 19 CFR 24.5, each importer of record and each ultimate consignee must be identified to CBP by one of three number types:

The Two-Digit Suffix

An EIN may be reported with a two-digit suffix so that a division, subsidiary operating unit, or separately managed business line can act as importer of record under the parent company's EIN while being tracked separately in CBP's systems. A corporation with a single EIN can therefore establish several importer of record numbers — the nine-digit EIN plus 00, 01, 02, and so on — each with its own name and address record.

This is a favored Practical Exercise fact pattern: a division that intends to be a consignee on future import transactions asks a broker to obtain an importer of record number using the parent's EIN as the first nine digits and adding a two-digit suffix. That is exactly what the suffix convention is for.

CBP Form 5106 — Create/Update Importer Identity Form

The form is authorized by 19 CFR 24.5 and is used to create a new importer of record or ultimate consignee record, to update an existing record, or to change the type of action. It collects the party's name, address, EIN/SSN/CBP-assigned number with suffix, business structure, and program-related contact information.

Who Is Responsible for the Content

The face of the form states the allocation of responsibility directly, and the exam tests it:

"As the importer, consignee, or other party listed in block 1, you are responsible for the validity of the information provided in this document. Any Customs Broker or third party who is submitting the information on your behalf is only obligated to convey this information to Customs and Border Protection (CBP)."

Two consequences follow:

1. The party in block 1 owns the accuracy of the data. A broker who faithfully transmits what the importer supplied has discharged its obligation as to validity.
2. The broker's own obligations still apply to its own conduct. A broker may not transmit information it knows to be false (19 CFR 111.32), must exercise diligence in preparing and filing documents and in inquiring into the correctness of the facts (19 CFR 111.29), and must advise the client promptly of any error or omission it discovers (19 CFR 111.39). The form's allocation of responsibility for validity is not a license to transmit data the broker knows is wrong.

Authority to Submit

A broker submitting or updating a 5106 on an importer's behalf needs authority to do so under the customs power of attorney. Where the POA confers authority to add or change the importer's data, an employee of the brokerage may input the data through ABI; the licensed broker who endorsed the POA on the firm's behalf is the source of that authority, and the firm's responsible supervision and control obligations under 19 CFR 111.28(a) govern how unlicensed employees perform the work.

5106 and the Entry

No entry or entry summary will be accepted until the importer of record and ultimate consignee records exist. A rejected entry summary citing an invalid importer number is cured by correcting or creating the 5106 record and retransmitting within the ACE resubmission window.

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Schedule D Port Codes and Annex C of the HTSUS

The port code reported on the entry summary is a four-digit Schedule D district and port code. The authoritative listing is published in Annex C of the Harmonized Tariff Schedule of the United States, which means it is available on the exam inside a designated reference.

• The format is DDPP — two digits identifying the customs district, two identifying the port within it — reported with no spaces or hyphens.
• The port reported is the port where the merchandise was entered under an entry, or released under an immediate delivery permit.
• A Practical Exercise question that gives an invoice with a stated final destination and asks for "the Customs port code for this intended port" is a pure Annex C lookup. Practice finding a port by name in Annex C before exam day; candidates lose several minutes learning the table's organization under pressure.

The Other Identifier Conventions on the Entry Summary

These appear in the header blocks and recur in document-reading questions:

Constructing the MID

The MID is derived, not assigned, and the derivation rules are set out in the appendix to the CBP Form 7501 instructions:

1. Country: the two-character ISO code of the country of origin.
2. Name: the first three characters of each of the first two words of the company name; if the name is a single word, the first six characters. Ignore punctuation and the words "a," "an," "and," "of," and "the."
3. Address: the largest numeric component of the street address, up to four digits. If the address contains no numbers, omit this element.
4. City: the first three characters of the city name.

Example: Kyoto Precision Robotics, 1245 Sakura Boulevard, Tokyo, Japan → JP + KYO + PRE + 1245 + TOK = JPKYOPRE1245TOK.

Because the MID is constructed from the invoicing party's name and address, a change of invoicing party changes the MID even when the physical factory does not — a frequent source of ACE rejections.