Importer of Record services
Your goods need a United States Importer of Record.
Federal customs rules are tightening who may act as Importer of Record and what that party must be able to demonstrate. Hamburg Logistics connects importers with a legally structured United States Importer of Record operating under 19 U.S.C. §1484.
The rules are moving. Most importers have not adjusted.
On June 3, 2026, an executive order directed the Department of Homeland Security and U.S. Customs and Border Protection to overhaul customs enforcement. Among the directives:
- Importers of Record must maintain a minimum level of tangible domestic assets, bonding, or both.
- Foreign entities face heightened requirements for formal entry.
- Only United States Importers of Record are authorized to file informal entry.
- All Importers of Record must meet a new good standing requirement, with increased vetting of individuals and entities conducting activities related to importation.
- CBP must establish a 50 percent minimum penalty floor, limiting its discretion to reduce assessed penalties on importers who violate customs laws.
These reforms run through standard rulemaking and are not yet in effect. That is the window. Companies that sort out their Importer of Record arrangement now will not be scrambling when the rules land.
Who this is for
Foreign manufacturers selling into the United States
You need a US party with the legal standing to make entry.
Overseas ecommerce sellers
Shipping to US customers or into US fulfillment centers, with no US entity of your own.
Nonresident importers
Currently acting as your own Importer of Record and facing heightened formal entry requirements.
US importers whose supplier is the IOR
Your overseas supplier files as Importer of Record today. Confirm that arrangement still holds.
What the Importer of Record is actually responsible for
The Importer of Record is the party legally answerable to CBP. Not the shipper. Not the consignee. Not the freight forwarder.
- Payment of all duties, tariffs, and fees
- Compliance with United States import law
- Accurate declared value and classification
- Recordkeeping for five years under 19 C.F.R. Part 163
- The reasonable care standard under 19 U.S.C. §1484
A party named in shipping papers without the substantive financial interest the law requires cannot make entry in its own name.
Who serves as your Importer of Record
The Importer of Record role is filled by an established United States firm, a Service-Disabled Veteran-Owned Small Business, that operates as the legally structured Importer of Record. It assumes responsibility for entry accuracy, valuation methodology, and duty payment. Entries are filed through licensed United States customs brokers in the Automated Commercial Environment.
Hamburg Logistics LLC is not a customs broker and is not the Importer of Record. We identify companies that need this structure and introduce them to the firm that provides it. The arrangement is described on our Disclosures page.
How it works
Intake and review
Your products, classifications, and landed cost components.
Compliance and valuation strategy
The appropriate methodology for your facts.
Import structuring before entry
Everything established prior to importation.
Execution through licensed brokers
Entries filed in ACE.
Ongoing monitoring and audit support
Records maintained, CBP inquiries supported.
See if you qualify
Tell us what you import and how your entries are structured today. If your company qualifies, we will make the introduction. If not, we will tell you that.