Importer of Record (IOR): Role and Responsibilities

An importer of record (IOR) is a business or individual who takes responsibility for moving a shipment through U.S. customs while ensuring all relevant regulations are followed. They play an important role in international trade, facilitating trouble-free customs clearance.

In this guide, we’ll explore the role and responsibilities of an IOR and clarify how they contribute to the customs clearance process in the United States.

Key Takeaways

• An importer of record is accountable for the import compliance of shipments to which they’re assigned.
• The IOR isn’t always the purchaser of the goods in question.
• Consignees, brokers, and importers of record are distinct roles, but their duties occasionally overlap.

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Importer of Record Definition

As noted above, the individual or entity responsible for ensuring import compliance is known as the importer of record. They assume legal responsibility for the imported goods and have temporary ownership of them during customs clearance.

While the Incoterms® of a shipment often dictate who is responsible for fulfilling the IOR role in a given transaction, that individual or business can still hire a licensed customs broker to act in their stead. 

Brokers who act as professional importers of record often work with firms that have access to freight forwarders and other import professionals. This gives them an edge in moving shipments through customs quickly and compliantly.
There is a lot to know when it comes to Incoterms. For more information, take a look at our blog What Are Incoterms?

What Are an Importer of Record’s Responsibilities?

The duties and responsibilities of an Importer of Record are numerous and critical. With so many important tasks to be completed, it’s imperative to be aware of exactly what needs to be done.

Below are the responsibilities of an importer of record:

• Assessing duties on imports based on their value and classification
• Securing and providing payments for duties, fees, and taxes on imported goods
• Ensuring imported goods have correct entry documents, including CBP form 7501, the Entry Summary
• Obtaining any necessary authorization, certifications, or licensing for the import as needed when importing goods subject to regulations by the FDA, EPA, DOT, and others. 
• Abiding by all local, state, and federal regulations with imported goods
• Making customs declarations, including the shipment’s value and country of origin.
• Exercising power of attorney
• Dealing with tariffs, and referencing a tariff database as needed
• Preparing for audits and inspections from CBP agents
• Maintaining all import records for at least five years after goods are brought into the U.S.
• Securing custom bond paperwork for imports

Failure to execute any of these tasks correctly can have severe consequences. Daily fines for held goods, harsh financial penalties for filing errors, and seized goods are just some of the problems that arise occur when these responsibilities aren’t handled properly. 

In the following table, you can see some of the penalties issued to importers by CBP over the course of the 2022 fiscal year.

Source: cbp.gov

If you’re acting as the IOR for your own shipment, be certain that you have a complete understanding of what’s required and needs to be done. If you’ve hired a third party, clearly communicate all the details of your shipment to ensure nothing is missed.

Need help navigating customs requirements?  Our Customs brokers can assist you! They’re licensed by CBP and have extensive experience handling tricky government regulations.

Is the Consignee the Same as the Importer of Record?

While they can and sometimes do overlap, an IOR is not the same thing as a consignee. 

The consignee of a shipment is the individual or entity that is the end receiver of the goods. It’s common for a consignee to hire an IOR, since consignees simply receive the imported goods after they have traveled through the U.S. port of entry. 

In short, while the IOR is responsible for the goods at the time of import, the consignee ultimately receives the shipment.

Does the Importer of Record Own the Goods?

Yes and no. The IOR always takes temporary ownership of imported goods during the customs clearance process. Once cleared, final ownership of the goods depends on a couple of different factors.

• If the final recipient of the goods acted as their own IOR, they take permanent ownership pending any potential resale.

• If the final recipient employed the services of a professional importer of record, the IOR’s ownership of the goods is strictly temporary. The IOR will transfer ownership to the recipient, who is usually the purchaser. 

Since different individuals or entities can potentially act as an importer of record, deciding who should fulfill this role is one of the most important decisions you can make when importing goods.

Who Should Be the Importer of Record?

This choice comes down to the specific details of the shipment and the needs of the parties involved. When making this decision, especially if you are considering being your own IOR, consider the following questions: 

• Do I have all necessary information to safely and legally import the goods myself? 
• Will my chosen IOR be able to keep import records for at least five years?
• Does my importer of record have import expertise in my industry?
• Can my IOR help with logistics, a distribution center, or door-to-door service? If not, can they recommend a high-quality service that does?  Will my importer of record provide a power of attorney, or will I be required to find my own? (Note: if you are required to find and secure your own power of attorney agent, you may need to reconsider choosing that individual or company as your IOR.)
• Are all details and regulations totally covered by the IOR, or am I still in charge of doing substantial legwork?
• Can I repeatedly work with this entity for the foreseeable future on all my imported goods?

The first question is perhaps the most important. You might think you could act as your own IOR in the short-term, but can you also handle the required bookkeeping, or easily secure storage and transport for your goods? If not, an experienced IOR is well worth consideration. 

Those questions are also useful if you plan on entering the import business as a professional IOR yourself. 

When searching for a professional IOR, you’ll probably run across the terms “shipper” and “freight forwarder”. It’s essential to understand how these service providers fit into the import process.

Can a Freight Forwarder be Importer of Record?

A freight forwarder can take on some of the responsibilities usually handled by the IOR. However, they won’t be listed as the importer of record for a shipment. Only the owner or purchaser of the goods being shipped or a licensed customs broker can act as the importer of record

Can the Shipper be the Importer of Record?

Within the context of importing, the shipper is the entity who sells goods to importers. A foreign business must have a Customs Assigned Importer Number to act as an IOR. Alternatively, they might employ or contract with stateside brokers who can act as importers of record for their customers.

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Do I Need Importer of Record Services?

Just because you can be your own IOR does not mean you necessarily want to be. If it is your company’s first time dealing with imports, you would be wise to employ the expertise of a customs broker and/or importer of record. 

This is especially true if you plan on importing heavily regulated goods. These include:

• Firearms
• Pharmaceuticals and medical devices
• Food and drink
• Animals
• Plants

These are just a few examples of goods and commodities that require special licensure and/or certifications to be legally imported.

To get an idea of situations that do and don’t call for a professional IOR, consider the following scenarios.

You Might Not Require a Professional IOR if:

• You're bringing in goods that are clearly for personal use and fall below customs value thresholds.
• You purchase small, occasional shipments of relatively low value.
• The goods are temporarily imported for trade shows or exhibitions, then returned to the originating country.

You’ll Need An Experienced IOR when:

• Regularly importing goods for commercial resale, especially in large quantities.
• Purchasing high-priced goods exceeding $2,500 in value and require detailed customs declarations and a customs bond.
• Bringing in any of the heavily regulated goods mentioned previously in this section.

A reputable customs broker should be upfront with you during your initial consultation regarding whether you truly need an IOR service or not, and help guide you through any questions regarding the value of an IOR in your specific circumstances. 

If you require door-to-door logistics or require a distribution center to hold your imported goods, working with an IOR can prove invaluable. 
To learn more, read our article on foreign importer of record.

Importer of Record Registration With USA Customs Clearance

Whether you choose to act as your own IOR or decide to employ a professional, our team of customs experts can help. Our team of licensed customs brokers have over a century of combined experience helping importers like you with every aspect of the customs process.

Our full list of services includes:

• Importer of record registration
• Secure customs bonds
• Worry-free customs brokerage
• And more

Give USA Customs Clearance a call today at (855) 912-0406, or submit your question online to see how we can assist you in making sure your imports are handled professionally and dealt with in an efficient, secure manner. We can discuss any concerns you have and make importing goods into the U.S. a simple and hassle-free process.

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Official Importer of Record Registration with CBP

Available 1-on-1 support from our Customs Experts in completing required paperwork

Completed documents are filed directly to CBP by our Licensed Customs Brokers

*Registration is complete within 24 hours after all necessary forms are complete