The importer of record (IOR) is the party legally responsible for a shipment entering the United States. The IOR owes the duty, answers to Customs for the accuracy of the entry, holds the bond, and is the party CBP will pursue if something is wrong.

It is a legal position, not a logistical one. Whoever holds it accepts liability for the import, regardless of who paid for the goods or who arranged the freight.

Why the Role Exists

Customs needs a single accountable party for every entry. Not a group, not a chain of contracts. One entity that can be assessed, audited and penalised.

That is the IOR. Everything else in the import process — the broker, the carrier, the forwarder, the trucker — is a service provider to that party.

Who Can Be the IOR

The IOR must be a US entity with a US tax identification number (an EIN), or a foreign entity that has filed the necessary registration and posted a bond.

Practically, this is why overseas sellers cannot simply declare themselves the importer:

Situation Who must be IOR
US company buying from China The US company
Amazon FBA seller with a US entity The seller’s US entity
Chinese exporter selling to US customers The US buyer, or a US entity acting on their behalf
DDP arrangement Whoever contracts to be the importer

That last row carries the weight. DDP means the seller, or their agent, takes the IOR position. It is not just a delivery term.

Why It Matters More Than It Sounds

The IOR position carries four consequences.

Liability for duty. If duty is underpaid, the IOR owes it, even if the error was the broker’s.

Liability for accuracy. The IOR certifies the entry. Wrong classification, wrong value and wrong origin are the IOR’s exposure.

Ownership of the entry record. The import history accrues to the IOR. That history affects future scrutiny.

Bond exposure. The bond belongs to the IOR, and claims are made against it.

The DDP Question

In a DDP shipment there is usually a US entity on the receiving side — a forwarder’s US arm, or a partner — acting as importer of record. The seller contracts with that entity for the whole job.

This works. It is common. And it is worth being precise about what it means:

  • The IOR is not the buyer. In a DDP deal, the buyer may not appear as importer at all.
  • The entry record is not the buyer’s. It belongs to whoever held the IOR.
  • The buyer may not be able to claim the goods as their own import for tax or audit purposes.

For most importers, none of this matters day to day. For an importer with customs exposure, VAT recovery needs, or an audit coming, it matters a great deal.

What Goes Wrong

Two parties both think they are the IOR. The entry is filed under one, the bond under the other, and both are wrong.

An IOR with no bond. The entry is rejected at arrival.

An IOR that is not the consignee. Legal, but the consignee then cannot claim the goods without an authorisation.

A foreign entity declared as IOR without registration. The entry is rejected, and the cargo waits.

Key Facts

  • IOR = the party legally responsible for the import.
  • The IOR owes the duty, certifies the entry and holds the bond.
  • Must be a US entity with an EIN, or a foreign entity with registration and bond.
  • DDP transfers the IOR position to the seller or their agent. It is more than a delivery term.
  • The entry record follows the IOR, not the buyer.
  • Two parties both believing they are the IOR is a common and expensive mistake.

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