Importer of Record
Also known as: IOR, Importing Entity, Registered Importer
Definition
The importer of record (IOR) is the person or company legally responsible for an international shipment when it enters a country. The IOR ensures goods comply with all import regulations and is liable for paying customs duties, taxes, and any penalties.
IOR Responsibilities
Legal Obligations
- Ensure goods comply with import laws
- Provide accurate customs documentation
- Pay all duties and taxes
- Maintain import records
- Respond to customs inquiries
Documentation Duties
- Commercial invoice accuracy
- Correct HS classification
- Country of origin verification
- Valuation compliance
- Required permits and licenses
Who Can Be the IOR?
Common IOR Scenarios
| Scenario | Typical IOR |
|---|---|
| Business importing for resale | The business |
| Consumer buying from overseas | The consumer |
| E-commerce international sale | Buyer or seller (depends on terms) |
| Multinational company | Local subsidiary |
Requirements to Be IOR
- Legal presence in importing country (usually)
- Tax/VAT registration
- Customs registration (some countries)
- Financial ability to pay duties
IOR in Different Countries
United States
- Can be US resident, citizen, or business
- Non-residents can import with bond
- Customs bond required for commercial imports
- CBP Form 5106 registration
European Union
- Must have EU establishment (EORI)
- Non-EU sellers need fiscal representative
- VAT registration required
- EORI number mandatory
Other Countries
- Requirements vary significantly
- Some require local entity
- Others allow foreign IOR with agent
IOR vs. Other Parties
| Role | Responsibility |
|---|---|
| Importer of Record | Legal compliance, duties |
| Consignee | Receives goods |
| Customs Broker | Processes paperwork (agent) |
| Buyer | Pays for goods |
| Notify Party | Receives shipment notifications |
Note: These can be the same entity or different parties.
IOR for E-Commerce
DDP (Delivered Duty Paid)
- Seller is typically IOR
- Seller handles customs
- Buyer pays nothing at delivery
- Requires seller to register in destination
DAP/DDU
- Buyer is typically IOR
- Buyer responsible for clearance
- Buyer pays duties at delivery
- Simpler for sellers
IOR Services
When to Use IOR Services
- No legal entity in destination country
- Occasional shipments (not worth registering)
- Complex compliance requirements
- Temporary imports
IOR Service Providers
- Customs brokers with IOR services
- Freight forwarders
- Specialized IOR companies
- Trade compliance firms
Costs
- Per-shipment fees: $50-$500+
- Monthly retainers: $200-$1,000+
- Percentage of value: 1-5%
- Plus duties and taxes
IOR Risks and Liabilities
Potential Issues
- Incorrect classification = wrong duties
- Valuation errors = penalties
- Missing permits = seizure
- Record-keeping failures = fines
Penalties
- Duty underpayment: Back duties + interest
- Negligence: Additional penalties (often 2-4x)
- Fraud: Criminal prosecution possible
- Seizure: Loss of goods
Best Practices
For Companies Acting as IOR
- Verify HS codes before shipping
- Keep complete records (5+ years)
- Use qualified customs brokers
- Stay current on regulations
- Conduct periodic compliance audits
For Choosing IOR Services
- Verify provider’s track record
- Understand liability allocation
- Get clear pricing upfront
- Confirm they cover your countries
- Review their compliance procedures
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