Can the IOR be different from the buyer?

Yes. The IOR can be the buyer, the actual owner of the goods, or a licensed customs broker acting as IOR. The parties agree on who assumes IOR responsibility.

What records must the IOR keep?

Under 19 CFR Part 163, the IOR must retain entry records, invoices, and all supporting documentation for 5 years from the date of entry.

Participants

What is Importer of Record?

The person or entity responsible for paying duties and complying with all customs regulations on imported goods. In the context of U.S. customs and tariff recovery, understanding importer of record is essential for navigating the CAPE refund process and ensuring accurate duty assessment.

Definition

The Importer of Record (IOR) is the entity legally responsible for paying all duties, taxes, and fees on imported goods and for complying with all customs regulations. The IOR can be the owner, purchaser, or a licensed customs broker. The IOR's identity is declared on the entry summary and determines who bears liability for duty accuracy, record retention (5 years per 19 CFR Part 163), and penalties for violations. The IOR is identified in CBP's systems by their IOR number (EIN + 2-digit suffix).

How Importer of Record Relates to Tariff Refunds

The Importer of Record is the entity that receives CAPE refunds, since they originally paid the duties. When Tariffi analyzes your ES-003 data, the IOR number links each entry to the responsible importer. CAPE refund payments are made to the IOR's designated bank account.

Example

XYZ Corp (IOR 12-3456789-00) imports electronics from China. They are the Importer of Record, responsible for all duties. When their broker files a CAPE declaration, the refund is paid to XYZ Corp as the IOR, not to the broker or freight forwarder.

Frequently Asked Questions

Can the IOR be different from the buyer?: Yes. The IOR can be the buyer, the actual owner of the goods, or a licensed customs broker acting as IOR. The parties agree on who assumes IOR responsibility.
What records must the IOR keep?: Under 19 CFR Part 163, the IOR must retain entry records, invoices, and all supporting documentation for 5 years from the date of entry.

Legal References

19 U.S.C. § 1484 — Entry of Merchandise
19 CFR Part 163 — Record Retention

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