Trade Remedies & Import Compliance
Importer of Record
Also known as: IOR
The importer of record is the party legally responsible for ensuring that imported goods are declared accurately, valued correctly, and admitted in compliance with all applicable laws, and for paying the duties, taxes, and fees that result. This party — which may be the buyer, a foreign seller under a delivered term, or an authorized agent — must maintain records, exercise reasonable care in classification and valuation, and answer to the customs authority in an audit or penalty action. Because the obligations and liabilities are significant, the choice of importer of record is a deliberate contractual decision, closely tied to the Incoterm agreed between the parties.
The single most misunderstood term in this glossary, and the misunderstanding is expensive. Importers tell us the supplier "handles the customs side" or the forwarder "takes care of duties." Neither statement has standing with CBP. We file as your agent, on your authority, under a power of attorney you grant — if the classification is wrong, the value understated or the records missing, the demand comes to you.
People also become importer of record without deciding to. If your name is on a parcel held at a mail facility, CBP looks to you — and if you make entry to get the goods, you are the importer of record with everything that carries. You can also refuse the parcel and let it go back. What you cannot do is take the goods and not be the importer.
Where it matters for compliance
- The importer of record must use reasonable care in declaring the goods. Employing a broker is evidence of care, not a transfer of the duty.
- Entry records must be retained five years from the date of entry — 19 CFR Part 163 — and the obligation is the importer's.
- A broker files under a power of attorney from the party it acts for — on an import entry, the owner or purchaser who is or becomes the importer of record. A forwarder's authorization or a supplier's instruction is not a substitute.
- Penalties under 19 U.S.C. § 1592 fall on any person who causes an entry by a material false statement or omission. Usually that is the importer of record — but it is not limited to them, and a broker is not outside it.
- None of which should alarm someone clearing a single parcel. The obligations scale with what you import, and for one shipment they amount to signing a power of attorney and keeping the file.
Related terms
Reviewed by a licensed customs broker. Definitions are general information, not legal or customs advice for a particular shipment. Duty rates, tariff programs and agency requirements change frequently.