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October 2024, question 17
Practical Exercise · ACE entry summary data and business rules
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?
- Echo does not need to register as an IOR and will not need an Importer Number in Box 23 of the 7501.
- CBP will assign Echo an Employer Identification Number for NBB to use on behalf of Echo as Echo's Importer Number in Box 23 of the 7501.
- NBB can file a Form 5106 to provide Echo’s Canadian Corporation Number to CBP to use as Echo’s Importer Number in Box 23 of the 7501.
- NBB can file a Form 5106 and CBP will assign a number (Customs Assigned Number) to use as Echo’s Importer Number in Box 23 of the 7501.

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CBP's answer: D. D: NBB can file a Form 5106 and CBP will assign a number (Customs Assigned Number) to use as Echo’s Importer Number in Box 23 of the 7501.
Echo is a foreign company with no U.S. EIN or SSN. Under the BRPD, CBP typically gives CBP-Assigned Numbers to foreign entities without an SSN or EIN, so NBB files Form 5106 and CBP assigns a number for Box 23 (D). Echo does need an importer number for a formal entry, since only de minimis entries skip registration, and CBP does not issue EINs.
CBP typically gives CBP-Assigned Numbers to foreign entities that do not have an SSN or EIN. ACE BRPD Section 23.2
Registering as an IOR with CBP is necessary if an entity intends to be involved as an importer ACE BRPD Section 23.1
Search for: CBP-Assigned Number foreign entities
CBP's key cites: ACE BRPD Chapter 23; 19 CFR 24.5
Question and key from CBP's October 2024 exam and answer key. The walk-through is ours; quotes are from the pinned editions in the reference viewer (HTSUS 2026 Basic, 19 CFR 2025 edition).