week of January 29, 2026

Members of the Hobby Industry Community,
As we await the Supreme Court’s upcoming ruling, the broader trade and tariff news cycle has remained relatively quiet. That said, CBP enforcement activity continues to move forward at the operational level.
This Clear Signals article addresses a compliance issue we are now encountering directly: stricter enforcement of how CBP Form 5106 is completed and signed.

What was once treated as routine paperwork can now affect cargo release, eligibility for duty refunds, and electronic payments. We encourage all importers to take a few minutes to review this information and confirm that their Form 5106 records are current and compliant.
Thank you, as always, for your continued engagement and communication across the hobby industry.
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Hobby Industry Coalition -Clear Signals Advisory
CBP Form 5106: Why It Suddenly Matters to Every Hobby Importer 

Summary

U.S. Customs and Border Protection (CBP) is now strictly enforcing how Form 5106 (Create/Update Importer Identity) is completed and signed. What was once routine paperwork has become a gatekeeper document affecting cargo release, potential duty refunds, and electronic payments.

This development impacts all hobby importers, regardless of size.

What Changed

CBP is enforcing the technical requirements of Form 5106 as written.

Key points:

1. The form must be completed electronically using the fillable PDF.
2. It must be signed with a true digital signature (certificate-based), including a date and time stamp.
3. Scanned or handwritten signatures are not acceptable.
4. Forms not completed as intended are increasingly being rejected rather than corrected.

CBP has emphasized that when completed properly, the form’s fillable fields remain blue, confirming electronic entry.

What Form 5106 Controls

Form 5106 establishes and maintains an importer’s official identity record with CBP. It links a company to:

1. Its Importer of Record (IOR) number
2. EIN or CBP-assigned number
3. Addresses and contact information
4. Company officers and beneficial owners

CBP uses this information to:

1. Release cargo
2. Process duty payments
3. Refund processing and potential recovery
4. Conduct compliance reviews

This information underpins CBP’s ACE and ACH systems.

Why This Matters Now

CBP’s own instructions state that incomplete or inaccurate Form 5106 information may result in:

1. Delays in cargo release
2. Delays or inability to process potential refunds
3. Inability to make or receive electronic payments
4. Disruption to import transactions

In practical terms, Form 5106 compliance is enforced at the moment CBP processes a transaction, not on a fixed calendar date.

February 6, 2026: What It Is—and What It Is Not

CBP has announced that mandatory electronic refunds via ACH take effect on February 6, 2026.

CBP has not announced a universal deadline requiring all importers to refile Form 5106 by that date.

However, importers who may expect to receive refunds electronically should confirm that:

1. Their ACE Portal account is properly set up, and
2. A current, compliant Form 5106 record is on file

Failure to meet these prerequisites may delay or prevent future electronic refund processing once the new system is in effect.

CBP enforcement of Form 5106 compliance occurs transaction-by-transaction, not via a one-time mass refiling requirement.

The Hidden Risk for Long-Time Importers

Many importers:

1. Filed Form 5106 years ago
2. Used scanned or handwritten signatures
3. Never updated addresses, officers, or contact information

Those forms may no longer meet CBP’s technical requirements, even if they were previously accepted.

What Importers Should Do

Importers should:

1. Locate their most recent Form 5106
2. Confirm it is the current version
3. Verify it was:
   
   
1. Electronically completed
2. Digitally signed (not scanned)
4. Confirm all listed information is current
5. Confirm acceptance with their customs broker

Responsibility for accuracy ultimately rests with the importer.

Why This Matters Across the Hobby Industry

This applies equally to:

1. Model railroading
2. R/C vehicles
3. Plastic kits
4. Games and accessories
5. Component and finished-goods importers

CBP is tightening identity controls across all sectors.

Bottom Line

Form 5106 is no longer passive paperwork.

It is now a critical compliance document that affects cargo movement, cash flow, and potential refund recovery.

Clear signal: review it now—before CBP needs it.

Disclaimer

This article is provided for informational purposes only and reflects information believed to be accurate as of its date of publication. It does not constitute legal, regulatory, customs, financial, or business advice. Importers should independently verify requirements and consult their customs broker, legal counsel, or U.S. Customs and Border Protection regarding their specific circumstances.

Source: U.S. Customs and Border Protection, CBP Form 5106 (06/25).