Importer of Record (IOR)

The importer of record (IOR) is the party that makes entry of goods into the United States and answers to U.S. Customs and Border Protection (CBP) for it. Under 19 U.S.C. 1484(a)(2)(B), the entry may be filed only by the owner or purchaser of the merchandise or, when designated by the owner, purchaser or consignee, by a licensed customs broker, and the importer of record must be one of those parties.

What the importer of record is responsible for

• Reasonable care: 19 U.S.C. 1484(a)(1) requires the IOR, in person or through an agent authorized in writing, to use reasonable care in filing the entry and declaring the value, classification and rate of duty. Errors made through negligence, gross negligence or fraud are penalized under 19 U.S.C. 1592
• Duties: under 19 CFR 141.1(b) the duty is a personal debt of the importer to the United States. Paying the broker does not discharge it if the broker fails to pay CBP, and a bond does not remove the importer's own liability
• Bond: CBP will not release a formal entry without a customs bond on file, or cash or government obligations deposited in its place (19 CFR 142.4)
• Power of attorney: a broker must hold a valid customs power of attorney before transacting customs business in the importer's name (19 CFR 141.46)

The IOR number and CBP Form 5106

Every importer files CBP Form 5106, Create/Update Importer Identity Form, with its first formal entry (19 CFR 24.5). The importer number is the IRS employer identification number (EIN); a Social Security number if there is no EIN; or, where neither has been assigned, a number CBP issues on receipt of the form. The regulation also requires a Form 5106 for the ultimate consignee.

Beginning September 18, 2026, CBP voids any IOR number whose Form 5106 information it finds inaccurate or incomplete, under a general notice implementing Executive Order 14411 (Customs Bulletin, Vol. 60, No. 26, September 2, 2026). The physical address must be the importer's actual location, not a registered agent, broker, forwarder or P.O. box, and the email address and phone number must belong to the importer. The notice also restates that a broker must execute the power of attorney directly with the importer, not through a freight forwarder or other third party.

Importer of record vs consignee vs customs broker

• Consignee: the party the goods are shipped to on the bill of lading or air waybill. For the entry, CBP uses the ultimate consignee: the US party the overseas shipper sold the goods to or, if they are unsold, consigned them to (CBP Directive 3550-079A). On a DDP sale the seller or its agent usually acts as importer of record while the buyer is the consignee
• Customs broker: licensed by CBP under 19 CFR part 111. The broker prepares and files the entry as the importer's agent; the importer of record stays responsible for its accuracy and for the duty

Common mistakes

• Waiting until the goods arrive to file Form 5106, buy a bond and sign a power of attorney. Each takes time, and demurrage runs while the entry waits
• Putting a broker's or forwarder's address, email or phone number on Form 5106, which is now grounds for voiding the number
• Assuming the broker carries the risk. Underpaid duty and penalties fall on the importer of record

On the shipments Airlift moves, entries are filed through its licensed customs-broker network under a power of attorney from you, the importer of record. See customs clearance and formal entry.