First Time Importer Requirements: The Pre-Shipment Checklist

Key Points

• CBP Form 5106 must be on file with CBP before entry is made; it establishes your identity as an importer of record.
• Every formal entry requires a customs bond, either a single-transaction bond covering one shipment or a continuous bond covering all entries for a year, governed by 19 CFR Part 113.
• If a licensed customs broker will file entries on your behalf, a written power of attorney is legally required under 19 CFR 141.46.
• The reasonable-care standard in 19 U.S.C. 1484 places the legal duty to classify and value goods correctly on the importer of record, not the broker.
• An ACE portal account and a continuous bond (versus a single-transaction bond) are useful but are not legally required before a first shipment.

On this page

1. Direct answer: what you need before goods ship
2. Required item 1: importer identity on CBP Form 5106
3. Required item 2: a customs bond under 19 CFR Part 113
4. Required item 3: power of attorney if a broker files
5. Required item 4: classification and valuation under the reasonable-care standard
6. Other agency requirements to plan for
7. What is optional, not required
8. What importers should do
9. Key references

Before the first shipment leaves the origin port, a first-time importer must have four things in place: an importer identity registered on CBP Form 5106, a customs bond (single-transaction or continuous) that satisfies 19 CFR Part 113, a written power of attorney if a licensed broker will file on the importer's behalf under 19 CFR 141.46, and documented classification and valuation work meeting the reasonable-care standard of 19 U.S.C. 1484. Everything else, including an ACE portal account and a continuous bond, is useful but not mandatory for the first entry.

The links in this article go to the primary documents: the statutes, regulations, and official CBP pages themselves. Read the source.

Required item 1: importer identity on CBP Form 5106

CBP Form 5106, the Importer Identity Form, is how U.S. Customs and Border Protection creates or updates an importer's account in its systems. Without an active record in CBP's importer database, no entry can be filed in your name.

What the form captures

• Legal business name and address
• Employer Identification Number (EIN), Social Security Number, or CBP-assigned number
• Business type and contact information

When to file it

Form 5106 must be on file before the first entry is made. If a broker is handling the entry, the broker can submit the form on the importer's behalf, but the importer is responsible for ensuring the information is accurate and current. The form must be updated whenever material information changes. The current version of the form and instructions are available at cbp.gov.

Required item 2: a customs bond under 19 CFR Part 113

A customs bond is a financial guarantee that the importer of record will pay all duties, taxes, and fees owed and comply with CBP requirements. For formal entries, a bond is not optional. 19 CFR Part 113 governs bond types, amounts, and conditions.

Single-transaction bond

A single-transaction bond (also called a single-entry bond) covers one specific shipment. The bond amount is set to cover the full value of the merchandise plus estimated duties. It is the right choice when a company is importing once or experimenting before committing to ongoing imports. The surety company or broker obtains it for each entry.

Continuous bond

A continuous bond covers all entries filed at all ports of entry for a twelve-month period. Importers who expect to file more than a handful of entries per year almost always find a continuous bond more cost-effective and operationally simpler. However, for a first-time importer making a single test shipment, a single-transaction bond is entirely sufficient and legally equivalent.

Who obtains the bond

Bonds are issued by surety companies approved by CBP. A licensed customs broker can arrange a bond on the importer's behalf, or the importer can work directly with a surety. The bond must be in place, or transmitted electronically, before or at the time of entry filing.

Required item 3: power of attorney if a broker files

Most first-time importers rely on a licensed customs broker to prepare and file entry documents. That is a sensible choice. But it creates a legal requirement: the importer must execute a written power of attorney authorizing the broker to act on its behalf.

19 CFR 141.46 specifies what that document must contain. The power of attorney must be signed by an individual with authority to bind the business, such as an officer or owner, and must clearly grant the broker authority to make entry, sign documents, and perform other customs business. Brokers typically supply their own standard power-of-attorney form that complies with this regulation; the importer reviews it, completes it, and returns a signed copy before the broker can file anything.

If the importer files its own entries directly through ACE without using a broker, no power of attorney is needed. But filing without a broker requires an ACE portal account and direct responsibility for all entry preparation.

Required item 4: classification and valuation under the reasonable-care standard

The importer of record, not the broker, bears the legal responsibility to declare the correct Harmonized Tariff Schedule classification and the correct customs value for every entry. This obligation flows directly from 19 U.S.C. 1484, which requires the importer to use reasonable care in making entry.

Classification

Classification means assigning the correct ten-digit HTS number to each product. The number determines the duty rate and, critically for many importers, whether additional tariffs such as Section 301 or Section 232 duties apply. The official Harmonized Tariff Schedule is published at hts.usitc.gov. A first-time importer should work through the classification of each product before the shipment ships, not after it arrives. If the goods sourced from China may carry Section 301 exposure, see our explanations of 9903.91.04 and 9903.88.15 for context on how special tariff provisions layer on top of the base HTS rate.

Valuation

Customs value is generally the transaction value: the price actually paid or payable for the goods, adjusted for specific additions and deductions defined in statute. Supports for the declared value, such as the commercial invoice, purchase order, and payment records, should be organized and retained. CBP can question or reject valuations on entry review or during an audit, and the burden of proof rests with the importer.

Why this must happen before the shipment ships

Discovering a classification or valuation problem after goods have cleared customs is far more complicated and expensive than resolving it beforehand. Getting the numbers right early also surfaces any additional duties, quota restrictions, or partner government agency requirements that might delay or block the shipment. If you want to check that your broker's duty calculation reflects the correct classification and valuation, see our guide on how to verify a broker's duty calculation on an entry summary.

Other agency requirements to plan for

Many products are subject to requirements from partner government agencies beyond CBP. Common examples include the Food and Drug Administration for food, drugs, cosmetics, and medical devices; the Consumer Product Safety Commission for children's products; the Department of Agriculture for plants and certain animal products; the Environmental Protection Agency for engines and pesticides; and the Fish and Wildlife Service for wildlife and wildlife products.

These agencies have their own registration, licensing, labeling, and prior-notice requirements that can hold a shipment at the border. The specific obligations depend entirely on the product. A first-time importer should identify every agency that has jurisdiction over the goods and confirm compliance requirements well before the shipment departs. CBP does not publish a single consolidated list of all PGA requirements; each agency's own website is the authoritative source.

What is optional, not required

Two items are frequently discussed as if they were required for a first entry. They are not.

• An ACE Secure Data Portal account for the importer. ACE is the U.S. government's trade data system. A broker can file entries through ACE on the importer's behalf without the importer having its own portal account. The importer's own ACE account becomes valuable once the importer wants direct visibility into entry data, but it is not a prerequisite for the first shipment.
• A continuous bond rather than a single-transaction bond. Both satisfy the bonding requirement under 19 CFR Part 113. A continuous bond is operationally superior for ongoing import programs, but a single-transaction bond is fully legal and sufficient for a first entry or an isolated shipment.

What importers should do

• Complete Form 5106 and confirm bond coverage before goods are loaded. Submit the importer identity form through your broker or directly to CBP, select your bond type, and verify the bond is in place or will be transmitted at entry filing. Do not wait until arrival.
• Execute a power of attorney with your broker before the broker does anything on your behalf. Review the document, confirm the signatory has authority, and keep a signed copy on file for your records.
• Classify and value every product line before the shipment ships. Use the official HTS at hts.usitc.gov, identify any applicable special tariff provisions, and document the analysis so you can support the declared value and classification if CBP questions the entry.
• Identify partner government agency requirements for your specific products and confirm registration, labeling, and prior-notice obligations are satisfied before departure.

Key references

• 19 U.S.C. 1484: Importer of record obligation; the reasonable-care standard for entry, classification, and valuation.
• 19 CFR Part 113: Customs bonds, types, conditions, and amounts.
• 19 CFR 141.46: Power of attorney requirements when a customs broker files on behalf of an importer.
• CBP Form 5106: Importer Identity Form, current version and instructions.
• Harmonized Tariff Schedule of the United States (hts.usitc.gov): Official HTS for classification research.
• U.S. Customs and Border Protection (cbp.gov): Agency landing page for CBP guidance, CSMS messages, and forms.