Importer of Record (IOR)

Definition

An importer of record (IOR) is the person or company that U.S. Customs and Border Protection (CBP) holds legally responsible for an import. The IOR is either the owner or purchaser of the goods, or a licensed customs broker that the owner, purchaser, or receiver of the goods appoints, as set out in 19 U.S.C. § 1484.

The easiest way to picture the IOR is as the name on the customs bill. Whoever’s name sits in that box owes the import taxes, called duties, and answers for whether the paperwork is correct. Hiring a broker to file the paperwork does not change that, so if the broker makes a mistake or never pays CBP, the bill still comes back to the IOR (19 CFR 141.1(b)).

Every import goes through this. An entry is the filing that asks CBP to let a shipment in. On a typical day in fiscal year 2025, CBP handled about 137,000 of them, and each one named an IOR.

What it contains

An IOR is not a single document. It is a record that CBP keeps about each importer, and that record is built from one form, CBP Form 5106, also called the Create/Update Importer Identity form.

CBP uses it to know exactly who is bringing goods into the country. The form requires six details.

1. Importer name: The importer name is the legal name of the company or person.

2. Importer number: The importer number is the ID that CBP uses to find the importer, and it is usually the company’s IRS Employer Identification Number (EIN). A person can use a Social Security number instead, and CBP can assign a number to an importer that has neither.

3. Mailing address: The mailing address is where the importer receives its mail.

4. Physical address: The physical address is where the business really operates, and it is required whenever it differs from the mailing address. It cannot be a broker’s office, a freight forwarder’s office, a registered agent, a business service center, or a P.O. box.

5. Phone number: The phone number has to be real and has to belong to the IOR, not to the broker who sent in the form.

6. Email address: The email address also has to belong to the IOR, because CBP sends its notices there.

The form has optional spaces too, for the business structure, the owners, and the company officers.

Once the record exists, the IOR shows up in a few more places. Its number and name go on the release request, which is CBP Form 3461, and on the entry summary, which is CBP Form 7501 and lists the goods and the duty owed. The IOR is usually the principal on the customs bond, which means the bond guarantees its duty payments. The IOR also signs a power of attorney, the paper that lets a broker file on its behalf.

Accuracy matters more than it used to. Since September 18, 2026, CBP has said it will void any IOR number it finds has inaccurate or incomplete identity data. A voided number is useless for any purpose, including bringing in goods (91 FR 53627).

What an IOR record looks like

The six required fields on an importer record. The importer number is the one that follows the IOR onto every entry.

Where it’s used

The IOR role applies to goods coming into the United States, so any company that imports will run into it. The people who handle it fall into three groups.

1. Importers: Importers are the companies that own or buy the goods, and they are usually the IOR themselves. A manufacturer that buys parts from an overseas supplier is the most common example.

2. Licensed customs brokers: Customs brokers are licensed professionals who file import paperwork for other companies. They usually file under a power of attorney, and in some cases the broker is named as the IOR.

3. Foreign sellers shipping duty paid: A foreign seller that promises to deliver goods with the duties already paid may act as the IOR for its own shipments.

Inside a manufacturer or a logistics company, the work usually lands with the operations team or the trade-compliance team. Finance gets pulled in because it pays the duties and chases refunds.

The IOR matters at every stage of a shipment. It is set up before the goods ship, it is named on the paperwork when they arrive, and it stays responsible for years afterward, because CBP can ask for the records for five years.

How it’s used

Getting set up

A company cannot import until it has an importer number, so the first step is filing CBP Form 5106. A broker can send it through CBP’s electronic filing system, the Automated Broker Interface, or it can be emailed to a CBP Center of Excellence and Expertise.

Most formal entries also need a customs bond on CBP Form 301. A bond is a promise, backed by an insurance company called a surety, that the duties will get paid. For a standard importer’s continuous bond, CBP’s guide sets the minimum at $50,000 or 10% of the estimated duties, taxes, and fees from the previous 12 months, whichever is greater.

Last, the IOR signs a power of attorney with its broker. CBP’s 2026 notice says this paper must be signed directly with the IOR, not through a freight forwarder or any other outside party.

Making entry

When the goods arrive, the broker files the entry on the IOR’s behalf. The entry is due within 15 calendar days after the goods land, and the entry summary follows within 10 working days after entry. The summary lists what the goods are, what they are worth, and how much duty is estimated.

The broker gets those numbers from three papers: the commercial invoice, which is the seller’s bill, the packing list, which says what is in each box, and the bill of lading, which is the carrier’s receipt. Because of that, the IOR is responsible for each paper being right, including the tariff code, the value, and the country where the goods were made.

After release

Once CBP releases the goods, the IOR pays the duties, either directly or through the broker. If someone finds a mistake later, the IOR fixes it with a Post Summary Correction, and the records stay on file, generally for five years from the date of entry.

One more job landed on the IOR in 2026. The Supreme Court ruled on February 20, 2026 that the IEEPA tariffs were not allowed, and CBP now pays refunds of those tariffs only to the IOR or to a party the IOR names on CBP Form 4811. That means a company that paid the tariff through a supplier’s or broker’s price does not get the refund from CBP if that supplier or broker was the IOR.

Example

Picture a Texas manufacturer that buys 2,000 pump housings from a supplier in Vietnam. It buys on FOB terms, which means it takes over responsibility for the goods once they are loaded on the ship. Because it is the buyer, it is the IOR. It signs a power of attorney with its customs broker, and the broker files the entry.

A month later, CBP found that the broker used the wrong tariff code, so the duty paid was too low. The bill for the missing duty goes to the manufacturer, not to the broker who typed the code. One wrong code leads to one bill, and the bill lands on the IOR.

Now change one detail. Suppose the supplier had sold on DDP terms, which means the seller promises to deliver the goods with the duties paid. If the supplier’s broker still named the manufacturer as the IOR without a signed power of attorney, the bill would land on the manufacturer anyway, even though it never prepared the entry data.

A real CBP ruling shows how strict this is. In 2009, CBP ruled (HQ H080181) that Gap, Inc. could not act as IOR for goods bought by its wholly owned subsidiaries, even though it had signed an agreement to pay their duties. Each subsidiary was a separate legal company, and the agreement did not give Gap a financial stake in the goods. The company that actually buys the goods needs its own IOR setup, even inside one corporate family.

Types

There are four common kinds of IOR. They all do the same job, so the real difference is who fills the role and what that party has to show.

Owner or purchaser

The owner or purchaser is the standard IOR, and it is the kind most importers are. CBP counts any party with a financial interest in the goods, so the buyer, a buying or selling agent, and even a seller that keeps a security interest until it is paid can all qualify (ruling HQ 116344). This type is the default, because the party that bought the goods is the one CBP expects to answer for them. The operations or trade-compliance team at that company usually deals with it. A manufacturer that buys machine parts from an overseas supplier and files its own entries is a typical case.

Designated customs broker

A designated customs broker is a licensed broker that the owner, purchaser, or consignee has chosen to act as the IOR. The broker’s own name and number go on the entry instead of the importer’s, so CBP looks to the broker for the duties and the accuracy. This is a deliberate choice, and it is not what happens when a broker simply files on your behalf. The broker’s compliance team handles it. An importer that wants a broker to carry the entry from start to finish could appoint it this way.

Broker for a nominal consignee

A nominal consignee is a party named on the bill of lading that has no real stake in the goods, such as a freight consolidator or courier that only holds the shipping papers. CBP does not let a nominal consignee enter goods in its own name, even through a broker. If it hires a broker, that broker must be listed as the IOR on both the entry and the entry summary. This comes up when a forwarder is named as the receiver on the paperwork, and the broker doing the filing ends up carrying the IOR role.

Nonresident importer

A nonresident importer is a corporation that is not set up under U.S. law. It can still be an IOR, but it needs a resident agent in the state of the port of entry who can accept legal papers on its behalf. It also has to file a customs bond on CBP Form 301 with a U.S. surety company (19 CFR 141.18). This type is used when a foreign company wants to bring goods in under its own name. A foreign equipment maker that sells to U.S. customers on duty-paid terms is a typical example.

Variations

IOR vs. consignee

The IOR and the consignee are two different roles that people often mix up. The consignee is the party named on the bill of lading to receive the goods, while the IOR is the party that answers to CBP for them. They can be the same company, but they do not have to be, because a consignee can receive goods without being the importer. This matters most for forwarders and other middlemen, since being named on a shipping paper does not make them the importer.

Broker files for you vs. broker is the IOR

In the usual setup, the broker is your agent. It files under your power of attorney, so you stay the IOR and keep both the duty debt and the responsibility for accurate data. When a broker is designated as the IOR instead, its name goes on the entry and CBP looks to the broker. The two setups can look alike on a shipment, so it is worth confirming in writing which one you have. A broker that only acts as your agent is not the IOR.

DDP vs. other Incoterms

Incoterms are standard shipping terms that a buyer and seller agree on, and they split up cost and risk. They do not decide who qualifies as the IOR under U.S. law. On terms like FOB or DAP, the buyer is responsible for import clearance, so the U.S. buyer is usually the IOR. On DDP, which stands for delivered duty paid, the seller promises to handle import clearance and pay the duties. The risk shows up when a seller has no U.S. presence and its broker names the U.S. buyer as the IOR instead, because the buyer then owes the duties on an entry it did not prepare.

U.S. IOR vs. foreign IOR (rules pending)

Executive Order 14411, signed June 3, 2026, splits IORs into two groups, U.S. and foreign, partly based on who controls the company. A U.S. subsidiary of a foreign maker could be counted as foreign unless it owns a significant amount of U.S. real property. The order directs CBP to stop foreign IORs from filing informal entries, which are the lower-value ones, and to limit their use of continuous bonds. As of October 2026, CBP had not issued the final rules, so a company in this position should check for updates before it plans around the order.

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