Before products enter the U.S., businesses must understand one important question: Who is responsible for the import?

The answer involves the Importer of Record (IOR). The Importer of Record plays an important role in the U.S. import process by ensuring that required import information, documentation, and responsibilities are properly managed.

But what exactly is an Importer of Record? Who can act as the importer? What responsibilities come with the role? And should your company manage importing internally or work with an experienced import support provider?

In this first issue of the IOR Services Brief, we explain the fundamentals of Importer of Record requirements and the different approaches businesses can take when entering the U.S. market.

Understand the requirement. Build the structure. Support your import process.

What Is an Importer of Record?

The Importer of Record (IOR) is the party responsible for ensuring imported merchandise complies with applicable U.S. import requirements.

The IOR is involved in the customs entry process and assumes responsibility for providing accurate information related to the imported goods. Depending on the shipment and product type, responsibilities may include:

• Providing importer information
• Coordinating with customs brokers
• Ensuring accurate customs documentation
• Supporting classification and entry information
• Managing applicable duties, taxes, and fees
• Maintaining required import records

IOR Is More Than a Name on a Customs Entry

A common misconception is that the Importer of Record is simply a company name placed on shipping documents. It is not. The IOR represents responsibility for the import transaction.

Before asking, “How do we ship this product?” businesses should first ask:

“Who is responsible for importing this product into the United States?”

Who Can Be the Importer of Record?

This is one of the most important questions international companies must answer before shipping. Many foreign businesses assume that another party automatically becomes their importer.

Why This Matters

Foreign companies entering the U.S. market should determine:

• Who will act as the Importer of Record?
• Who will coordinate customs activities?
• Who will maintain import documentation?
• Who will manage import-related responsibilities?

These questions should be answered before the shipment leaves the country of origin.

The Import Process: Five Connected Levels

Importer of Record requirements become easier to understand when the complete import process is reviewed.

1. Company

   Who is importing the product?

   The business must determine whether it will:

   • Import using its own U.S. entity
   • Use an approved importer structure
   • Engage professional import support

2. Product

   What is being imported?

   Product type may affect documentation requirements, regulatory obligations, import procedures, and government agency requirements.

3. Supplier

   Who manufactured or supplied the product?

   Understanding the supplier relationship helps ensure accurate product and shipment information.

4. Shipment

   How will the shipment enter the United States?

   The shipment requires proper coordination between the importer, the customs broker, the carrier, and supporting documentation.

5. Records

   Can import information be retrieved when needed?

   Import records should be organized and maintained to support future reference and compliance needs.

What Does an Importer of Record Actually Do?

The responsibilities of an Importer of Record may involve several ongoing activities.

1. Customs Coordination

   The importer works with customs brokers and provides required information needed for entry processing.

2. Documentation Management

   Importers should ensure shipment documentation is accurate and available. Examples may include:

   • Commercial invoice
   • Packing list
   • Bill of lading or airway bill
   • Importer information
   • Product details
   • Supporting regulatory documents

3. Import Responsibility

   The importer structure should clearly identify who is responsible, what information is required, and how issues will be handled.

4. Record Maintenance

   Import-related records should be maintained and organized for future reference.

Three Ways to Manage Your Importer of Record Responsibilities

There is no single approach that fits every company. The important question is: which import model fits your organization?

Your Shipment Arrived at Customs. Are You Ready?

The challenge is often not transportation. The challenge is whether the import structure was prepared before arrival.

A successful import process begins before the shipment reaches the United States.

Common Importer of Record Challenges

International companies often face challenges when:

1. Shipping Without a Clear Importer Structure

   A shipment may be arranged before determining who will take importer responsibility.

2. Assuming Logistics Providers Handle Everything

   Transportation providers support movement of goods but do not automatically assume importer responsibilities.

3. Entering the U.S. Market Without Planning

   Companies expanding internationally may need to establish their import process before launching products.

4. Managing Multiple Shipments

   As shipment volume increases, organized documentation and consistent processes become increasingly important.

Importer of Record vs. FSVP Importer

For food products, businesses should understand that these roles are not automatically the same.

A company may need to evaluate both roles depending on the product and import structure. Understanding the difference helps businesses build the correct compliance framework.

Which Import Approach Is Right for You?

You now understand the fundamentals. The next question is: how will your organization manage its U.S. import responsibilities?

Import responsibility does not begin at customs. It begins before your shipment leaves the country of origin.

Start with five questions:

1. Who will act as the Importer of Record?

2. Who will manage customs communication?

3. Are the required documents prepared?

4. Are product requirements understood?

5. Where are import records maintained?