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.
Right to make entry
Held by an owner or purchaser under 19 U.S.C. §1484, never by a forwarder or a nominal consignee.
Filed by licensed brokers
Every entry is filed by a licensed United States customs broker under 19 C.F.R. Part 111.
Structured before importation
The import structure and its documentation are established before the first entry, not after.
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.
Where each part stands today:
In effect since September 18, 2026
Importer of Record data accuracy enforcement. CBP voids the IOR number of any importer whose Form 5106 lists a borrowed address, a broker’s contact details, or a power of attorney that was not executed directly with the importer.
In rulemaking, no effective date
The asset and bonding minimums, the formal and informal entry restrictions, the good standing requirement, and the penalty floor. 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.
The goods that carry the most at entry
The duty on an entry is set by what the Importer of Record declares: the heading, the country of origin, where the metal was melted and poured, the customs value, and for some products the end use. In 2026 the gap between a correct declaration and a wrong one is widest in five product groups. Each has its own page.
Pharmaceuticals
Since September 29, 2026, patented pharmaceuticals and their ingredients enter under Section 232 duties that run from zero to 100 percent. The rate on a given entry turns on origin, patent status, agreements with the Department of Commerce, and end use, all declared by the IOR.
Steel and aluminum
Since April 6, 2026, Section 232 duties on steel, aluminum, and derivative articles apply to the full customs value at 50 percent, 25 percent, or a combined 15 percent. The melt and pour or smelt and cast country is the IOR’s declaration.
Chemicals and plastics
Articles of Harmonized Tariff Schedule Chapters 28 to 39 carry more than one Section 301 duty. The rate on a line turns on the 8-digit classification, the origin, and for a short list of products, the use.
Oil and gas equipment
Casing and tubing carry the 50 percent steel rate. The machines and parts around them sit in the derivative tiers, and antidumping and countervailing duties apply on top for many tubular products.
Drones and components
Since September 3, 2026, unmanned aircraft, docking stations, and listed parts from any country carry a Section 232 duty of 100 or 25 percent on top of every other duty, with a further class of parts added on February 9, 2027.
Every other product
The same rules decide who may hold the role for apparel, electronics, food, machinery, and consumer goods. The breakdown by situation shows where your company sits.
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.
What an Importer of Record structure is, and what it is not
A United States Importer of Record structure places a US company in the IOR role for goods it did not make and does not sell. That company is named on the entry under a shipment-specific authorization from the company whose goods are moving. It files through a licensed customs broker, holds the customs bond in its own name, pays the duties from funds provided before entry, keeps the entry records for five years, and answers CBP’s questions about the entry. The commercial relationship does not change. The supplier still invoices. The customer still receives the goods. What changes is the name on the entry and the party answerable for it.
Three things it is not:
- It is not customs brokerage. A broker is licensed under 19 U.S.C. §1641 to transact customs business for others. The broker files. The Importer of Record is the party the broker files for.
- It is not freight forwarding. A forwarder arranges transportation under a commercial contract. It has no right to make entry unless it owns or purchased the goods, which it does not.
- It is not a way around the rules. The Importer of Record owes the duties at the rate the tariff schedule sets. Classification follows the Harmonized Tariff Schedule and valuation follows 19 U.S.C. §1401a, whoever holds the role. What the structure changes is who is answerable, and whether that party can meet the requirements CBP places on importers.
There is no CBP program that certifies Importer of Record providers. A provider is a United States importer that meets the ordinary requirements and holds the role for others, which is why the questions to ask any provider matter more than the label.
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.
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.
Dates on the calendar
Each of these sits in a Federal Register document that is already published, and each lands on whoever is named as Importer of Record on the entry date, not the shipping date or the invoice date.
November 9, 2026
The 178 remaining product exclusions from the Section 301 duties on goods of China expire unless the Trade Representative extends them in a new notice. After the expiry time the Section 301 rate applies, and the IOR owes it.
December 4, 2026
Minimum import prices for polysilicon, ingots, wafers, solar cells, and solar modules take effect under Proclamation 11052, with an additional 15 percent duty on polysilicon ingots and the listed derivatives. The price certification is made in the IOR’s name.
January 1, 2027
Section 232 rates on upholstered wooden furniture rise from 25 to 30 percent and on kitchen cabinets and vanities from 25 to 50 percent, except for countries that reach an agreement with the United States.
Questions importers ask first
Do I need a United States Importer of Record?
If you own or purchase the goods at the moment of entry, you are eligible to be the IOR, and your name or your broker’s filing on your behalf puts you in the role. If you do not own the goods at entry, the role belongs to someone else, and a forwarder, a supplier, or an agent that lists itself has no standing to hold it. The four situations, and the facts that decide each.
Can a foreign company be the Importer of Record?
Yes. A nonresident corporation may make entry under 19 C.F.R. §141.18 if it has a resident agent in the state of entry to accept service of process and a bond with a resident corporate surety. Since September 18, 2026, the physical address on its Form 5106 must be its own actual location, not a registered agent, broker, or forwarder. What a nonresident importer must have in place.
Can my freight forwarder or my consignee be the Importer of Record?
Not unless that party owns or purchased the goods. The right to make entry under 19 U.S.C. §1484 belongs to the owner or purchaser, or to a licensed customs broker they designate. A nominal consignee named in the shipping papers does not hold it. Who has the right to make entry.
What does the Importer of Record owe?
The duties, taxes, and fees on the entry, a bond before release, five years of entry records, and the reasonable care standard for every declaration on the entry: classification, value, origin, and the Chapter 99 headings that set the additional duties. The role on a United States entry, in full.
What changed in 2026, and is it in effect?
Importer of Record data accuracy enforcement has been in effect since September 18, 2026, and CBP voids the IOR number of an importer whose Form 5106 is inaccurate. The asset and bonding minimums, the restrictions on foreign IORs, and the good standing requirement in Executive Order 14411 are in rulemaking with no effective date. The tracker carries the dated position of each.
How the Insights section is written
Every post on this site is written from the primary source: the Federal Register document, the proclamation, the statute, the regulation, or the CBP message, cited by number and date. Posts carry an update note when the position changes. There are no forecasts and no commentary on what an agency might do. If a requirement is not yet in effect, the post says so. Read the latest.
This page summarizes publicly available federal actions for general information. It is not legal advice. Requirements are subject to rulemaking and change. Verify current requirements against the Federal Register and CBP guidance.
See if you qualify
Tell us what you import and how your entries are filed today, and we’ll show you where you stand.
