Maintaining control over importer information is an important part of an effective customs compliance program. U.S. Customs and Border Protection (CBP) offers a voluntary Freeze Program that allows importers to control who can authorize name and address changes, via a CBP form 5106, against their Importer of Record Number (IRN).
What Is the CBP Freeze Program?
The CBP Freeze Program allows an importer to designate specific individuals within the company who are authorized to make name or address changes to its IRN.
Once an IRN is frozen, CBP will only process applicable changes when the request is properly authorized by one of the individuals designated by the importer.
The program provides an additional layer of control over changes to an importer’s identification information.
CBP Freeze Program at a Glance
- Is it required? No. Participation is voluntary.
- What does it control? Name and address changes to an IRN.
- Who can authorize changes? Individuals designated by the importer.
- What regulation applies? 19 CFR 24.5(f).
- Can an importer leave the program? Yes. An importer can request that an IRN be removed from the program.
Why Freeze Your IRN?
Freezing an IRN can help importers establish clear authorization for changes to their CBP information and strengthen internal controls.
The program may be particularly useful for companies with multiple locations, multiple employees involved in customs activities, or established authorization procedures.
How Does the Freeze Program Work?
To participate, an importer must submit a written request identifying:
- The IRNs and suffixes to be frozen
- The individuals authorized to make name or address changes
- The required company and contact information
- A reference to 19 CFR 24.5(f), “Freezing” importer identification information
CBP provides specific requirements and a sample Freeze Letter. Importers should refer to CBP’s current guidance for submission instructions and contact information.
View CBP’s Freeze Program Guidance and Freeze Letter Sample
How Do You Remove an IRN From the Freeze Program?
Participation is voluntary, and an importer can request that an IRN be removed from the program.
The request must be submitted in writing and identify the IRNs and suffixes to be unfrozen. CBP provides an Unfreeze Letter Sample to help importers prepare the request.
View CBP’s Unfreeze Letter Sample
Is the Freeze Program Part of CTPAT or AEO Compliance?
No. The CBP Freeze Program and CTPAT are separate programs.The Freeze Program focuses on controlling changes to importer identification information. CTPAT, CBP’s supply-chain security partnership and part of the broader Authorized Economic Operator (AEO) framework, focuses on supply-chain security and risk management.
While the Freeze Program is not a CTPAT requirement, the internal controls it establishes can complement a company’s broader customs compliance and security practices.
What Should Importers Do?
Companies considering the Freeze Program should review their existing controls around importer information and determine who should have authority to approve changes.
Because CBP requirements and procedures can change, importers should always refer to CBP’s current guidance for the latest requirements.
Strengthen Your Customs Compliance Strategy
The CBP Freeze Program can be one component of a broader approach to customs compliance and risk management. Mohawk Global’s customs experts can help you evaluate your current processes, identify potential risks, and develop practical strategies to strengthen your import compliance program.