Importer of Record

The Importer of Record (IOR) is the party legally responsible for ensuring that imported merchandise complies with all applicable U.S. laws and regulations, filing the entry summary, paying duties and fees, and maintaining records for five years.

Under 19 U.S.C. § 1484, the IOR must be one of three parties:

1. The owner of the merchandise at the time of importation
2. The purchaser of the merchandise
3. The licensed customs broker acting as importer of record (rare, but permitted for specific transactions)

The IOR's responsibilities include:

• Filing accurate and complete entry information, including HTS code, country of origin, and customs value
• Posting a customs bond to secure payment of duties
• Paying all duties, taxes, fees (MPF, HMF), and any trade remedy duties
• Exercising reasonable care in classification, valuation, and origin determinations
• Maintaining import records for five years from the date of entry
• Responding to CBP requests for information (CF-28)

Critically, even when the IOR uses a customs broker, the legal responsibility — and any penalty exposure — remains with the importer. Foreign sellers selling to the U.S. on a DDP basis often act as IOR through a "non-resident importer" arrangement, which requires special bond and surety considerations.