The Importer of Record (IOR) is the party identified to U.S. Customs and Border Protection as responsible for the import entry. That role is more than a name on paperwork: it connects the shipment to an importer number and to important responsibilities for entry data, duties, classification, valuation and compliance.
A customs broker can file entry documents on the importer’s behalf, but the broker does not make the importer’s responsibilities disappear.
What an importer number is
CBP explains that an Importer Number—also called an Importer of Record Number—is the identifier used for the entity responsible for imported goods. For a U.S. business it is typically the IRS Employer Identification Number (EIN). Sole proprietors may use a Social Security Number, while qualifying foreign entities can request a Customs Assigned Importer Number by filing CBP Form 5106.
The importer number appears on entry paperwork and is used for customs clearance, duty payment and compliance records.
Importer of Record vs ultimate importer
The terminology can become confusing because customs forms and commercial transactions use several importer-related terms. CBP notes that when an individual or company purchases goods from an overseas supplier, it is generally considered the ultimate importer, and a broker clearing a formal entry uses the ultimate importer’s identification number on the entry summary where required.
In straightforward purchases, the ultimate importer and the Importer of Record may be the same company. More complex structures can involve foreign sellers, related companies or specialized IOR arrangements, so legal roles should be confirmed before shipping.
What the Importer of Record is responsible for
| Area | What must be controlled | Typical support |
|---|---|---|
| Classification | Correct HTS classification | Customs broker/classification specialist |
| Valuation | Accurate customs value and additions | Broker, trade counsel, finance |
| Origin | Correct country-of-origin treatment | Supplier documentation/compliance |
| Duties and fees | Amounts due to CBP | Broker calculates/files |
| Admissibility | Product restrictions and agency rules | Broker/agency specialist |
| Records | Entry and supporting documents | Importer compliance process |
A broker helps, but the importer owns the data problem
Customs brokers are licensed professionals and can be extremely valuable, especially for classification, valuation and filing. But a broker cannot classify a product accurately if the importer provides only a vague description such as “metal parts.” Likewise, the broker cannot validate a commercial-invoice value if assists, royalties or other required valuation elements are hidden from it.
Strong importers therefore treat their broker as a compliance partner and maintain internal product records.
Example: buying private-label products overseas
A U.S. ecommerce company buys $40,000 of branded kitchen products from a foreign factory. It hires a freight forwarder to move the cargo and a customs broker to file the entry. The importer provides product descriptions, materials, country of origin, transaction documents and the appropriate importer number.
If the product is misclassified or undervalued because the importer supplied incomplete information, the fact that a broker transmitted the entry does not automatically make the importer’s underlying compliance problem disappear.
Importer of Record and Incoterms
Incoterms allocate commercial responsibilities between buyer and seller, but they do not override customs law. Under DDP, for example, the seller assumes broad delivery and import-cost obligations commercially; however, the actual legal structure must still support whoever acts as importer in the destination country.
See DDP vs DAP and FOB vs CIF vs DDP for the cost-responsibility side of the shipment.
IOR checklist before the first import
- Confirm which legal entity will be the importer.
- Obtain or verify its importer number.
- Set up power of attorney and broker onboarding where applicable.
- Document product classifications and descriptions.
- Define the customs-valuation method and invoice requirements.
- Collect country-of-origin support.
- Identify other agency requirements before the goods depart.
- Maintain entry summaries and source documentation after clearance.
Why the role matters for landed cost
The IOR is closely tied to the costs that sit beyond freight: duty, Merchandise Processing Fee, Harbor Maintenance Fee where applicable, broker charges and other compliance costs. Use the Freight Cost Allocation Calculator and the Import Duties, Taxes and Disbursement Fees guide to keep those items visible in product economics.
Frequently asked questions
Can a foreign company be an Importer of Record in the U.S.?
Foreign entities can obtain a CBP-assigned importer number in appropriate circumstances, but the structure and entry requirements should be confirmed with a qualified customs professional.
Does hiring a customs broker transfer all liability?
No. A broker can transact customs business on the importer’s behalf, but importers retain significant obligations to provide accurate information and comply with U.S. import rules.
Is the importer number the same as an EIN?
For many U.S. businesses the importer number is based on the EIN, but CBP also provides other identification paths, including a Customs Assigned Importer Number for entities without an EIN or SSN.
Sources
PackToolbox guides are built around stated formulas, practical examples and source checks for changeable carrier, freight and logistics rules. Calculators are planning aids; final requirements should be verified with the relevant carrier or service provider.