Home / October 2024 CBLE / Question 17

Importer number for a Canadian company with no EIN or SSN

October 2024 examPractical ExerciseQuestion 17 of 80
Exhibit from CBP's October 2024 exam booklet, PDF page 9
Exhibit from CBP's published October 2024 exam (PDF page 9). Click to enlarge.

Echo will be filing a CBP Form 7501 (7501) for the importation of its paper products, with an entered value of over $1,000. Box 23 on the 7501 requires an Importer Number. An entity’s Importer Number stems from first registering with CBP as an Importer of Record (IOR). Each IOR, in turn, has its own Importer Number. Registering as an IOR with CBP is necessary if an entity intends to be involved as an importer on an informal or formal entry. However, individuals and organizations do not need to be registered as an IOR with CBP to make a section 321 entry (also referred to as de minimis). De minimis entries are for shipments imported by one person on one day valued at $800 or less. Therefore, which below statement is TRUE ?

How to get there

Echo's entry is over the de minimis level, so it needs an importer of record number in Box 23 of the 7501. As a Canadian company, Echo has neither an IRS EIN nor an SSN.

19 CFR 24.5(a), (c)(a) Each person, business firm … shall file Customs Form 5106 … with the first formal entry …
(c) Upon receipt of a Customs Form 5106 without an Internal Revenue Service employer identification number or a Social Security number, an importer identification number shall be assigned … This identification number shall be used in all future Customs transactions when an importer number is required. …
ACE BRPD § 23.2The number used to identify an IOR will be either an Internal Revenue Service (IRS) Employer Identification Number (EIN), a Social Security Number (SSN), or a CBP-Assigned Number (CAN). … EINs are the only IRS provided number that CBP accepts on the CBP Form 5106 …

NBB files the 5106 for Echo, and CBP assigns a CAN for Box 23. The answer is D.

Why the other choices are wrong

A) No IOR registration needed: that applies only to de minimis (section 321) shipments. This is a formal entry.
B) CBP assigns an EIN: EINs come from the IRS, not CBP. CBP assigns its own CAN.
C) Use Echo's Canadian corporation number: CBP accepts only an EIN, an SSN or a CBP-assigned number on the 5106.
Tip
IOR number types: EIN (with an optional 2-character suffix), SSN, or CAN for parties with neither, which is typical for foreign importers. Numbers lapse after a year of non-use (§ 24.5(e)).

Sources: 19 CFR 24.5; CBP ACE Business Rules and Process Document, § 23.2 (CBP Form 5106 Identification Numbers); facts p. 9.

CBP answer key: Answer D · ACE Business Rules and Process Document (BRPD) Chapter 23, Section 23.2; 19 CFR 24.5Source: CBP past exams ↗