Frequently asked questions
About the Importer of Record role
What is an Importer of Record?
The party legally responsible to CBP for entry accuracy, declared value, classification, and duty payment. The IOR is accountable for compliance with United States import law and for recordkeeping under 19 C.F.R. Part 163.
Is my consignee the Importer of Record?
Not automatically. A consignee is the party to whom goods are shipped. A party named in shipping papers without the substantive financial interest the law requires is a nominal consignee and cannot make entry in its own name.
Who may act as Importer of Record?
Under 19 U.S.C. §1484, the owner, purchaser, or a properly authorized agent. 19 C.F.R. §141.18 addresses an authorized agent in that role, and CBP Directive 3530-002A sets out the financial interest standard for the right to make entry.
Do I need a US Importer of Record?
It depends on your structure. Foreign manufacturers, overseas ecommerce sellers, and nonresident importers are the most commonly affected. See the breakdown by situation.
About the 2026 customs enforcement order
What changed?
The June 3, 2026 executive order directs minimum tangible domestic assets or bonding for Importers of Record, heightened formal entry requirements for foreign entities, restriction of informal entry filing to US Importers of Record, a good standing requirement with increased vetting, disclosure and certification requirements, and a 50 percent minimum penalty floor.
Are these requirements in effect now?
No. The reforms run through standard rulemaking. DHS and CBP will engage stakeholders, and affected parties are being given time to adjust. Anyone telling you these rules are in force today is mistaken.
Then why act now?
Because rulemaking takes months, not years, and the direction is already clear. Sorting out your Importer of Record arrangement during the rulemaking period is calmer and less expensive than doing it against a deadline alongside everyone else.
About how this works
Are you a customs broker?
No. Neither the Importer of Record provider nor Hamburg Logistics operates as a customs broker. All entries are filed through licensed United States customs brokers under 19 C.F.R. Part 111.
Does this replace my customs broker?
No. Your broker remains the licensed filer. The Importer of Record carries the IOR obligations and compliance oversight. The two roles exist on every formal entry.
Does this change my supplier relationships?
No. Your supplier relationships remain unchanged. The structure operates at the import and compliance layer, not the commercial sales layer. Suppliers continue issuing invoices, and your pricing, margins, and commercial terms remain intact.
How is risk allocated?
The Importer of Record assumes responsibility for entry accuracy, valuation methodology, and duty payment. The client is responsible for providing accurate commercial and product information and disclosing all relevant transaction details. This allocation aligns with the reasonable care standard under 19 U.S.C. §1484.
Does this affect my financial reporting?
No. Customs value is a legal construct under 19 U.S.C. §1401a. Financial reporting follows GAAP and IFRS. They are different measurements and neither disturbs the other.
What happens if CBP issues a CF-28 or CF-29?
A CF-28 is a request for information. A CF-29 is a notice of action. The Importer of Record coordinates with the customs broker and prepares the response, supported by documentation created at the time of entry rather than assembled afterward.
Will this structure attract a CBP audit?
CBP scrutiny follows inconsistency, missing documentation, and improper valuation methodology. The objective is a file that is consistent, complete, methodologically sound, and explainable on first review.
What is required to get started?
Typically a SKU list with product descriptions, current invoices and landed cost structure, supplier and country of origin details, and historical entry data if available.
What does it cost?
Terms are set by the Importer of Record provider after reviewing your import profile. Hamburg Logistics does not quote pricing.
About Hamburg Logistics
Are you the Importer of Record?
No. Hamburg Logistics LLC is not a customs broker, is not the Importer of Record, and does not provide legal, customs, or valuation advice. We identify companies that need this structure and introduce them to the firm that provides it, named on our Disclosures page.
Are you compensated for referrals?
Yes. Hamburg Logistics LLC may be compensated for referrals to the Importer of Record provider. We would rather tell you that up front than have you find out later.
What happens after I submit the form?
Will Hamburg reviews your submission and follows up directly. If the structure is a fit, we make the introduction. If it is not, we tell you that.
This page summarizes publicly available federal actions and authorities 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.