What is an Importer of Record?
The Importer of Record (IOR) is the person or company that takes legal responsibility for goods entering a country. The IOR is named on the customs entry or declaration, owes the duties and taxes, and answers to customs if anything is wrong. It is often the buyer, but it doesn’t have to be: under DDP terms, for example, the seller acts as importer.
Core principle: The IOR carries the liability. A broker can file for you and a supplier can make the goods, but customs will hold the importer responsible.
What the IOR is responsible for
- Correct classification, customs value and origin
- Paying duties, taxes and fees such as the MPF in the US or import VAT in the EU
- Making sure goods meet product-safety, labelling and licensing rules
- Keeping records, generally for five years in the US and at least three years for EU customs purposes (often longer under national VAT rules)
- Responding to audits, corrections and penalties
Who can act as IOR
The buyer or brand
What it is: The most common set-up: you import your own stock.
Why it matters: You control classification, timing and costs.
The seller (DDP)
What it is: The supplier imports and delivers duty paid.
Why it matters: Simple for the buyer, but the seller needs a local customs and tax set-up.
An IOR service provider
What it is: A third party that acts as importer for non-resident companies, common for samples or market tests.
Why it matters: Convenient, but you depend on their compliance and pay for the service.
IOR in the US and the EU
Two systems, similar responsibilities
US: the IOR needs an importer number and a customs bond, and usually appoints a broker under a power of attorney. Non-resident companies can act as IOR. EU: the equivalent is the importer or declarant, who needs an EORI number. Non-EU companies usually need an indirect customs representative and an EU VAT registration. For B2C parcels up to €150, the Import One-Stop Shop (IOSS) handles import VAT.
Reducing IOR risk
- Agree in writing who the IOR is for every trade lane.
- Check suppliers and product compliance before the first shipment.
- Review the broker’s classifications and values instead of signing off blindly.
- Check whether your cargo insurance covers duty liabilities.
Frequently asked questions
Is the importer of record the same as the consignee?
Not necessarily. The consignee receives the goods; the IOR is legally responsible for the import. They are often the same company, but not always.
Can a freight forwarder be the importer of record?
It can act as importer in some set-ups, but more often it files as an agent while the buyer remains the IOR.
What happens if the IOR fails to pay duty?
Customs can pursue the IOR for the debt, claim on the customs bond or guarantee, and impose penalties.
