Frequently asked questions

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.

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.

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.

It depends on your structure. Foreign manufacturers, overseas ecommerce sellers, and nonresident importers are the most commonly affected. See the breakdown by situation.

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.

One part is. Since September 18, 2026 CBP voids the IOR number of any importer whose Form 5106 lists a borrowed address, a third party’s contact details, or a power of attorney not executed directly with the importer. The asset and bonding minimums, the entry restrictions, the good standing requirement, and the penalty floor still run through rulemaking and have no effective date. A separate proposed rule published October 8, 2026 would require a bond for informal entries of $2,500 or less and is also not in effect. The tracker page carries the current position of each.

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.

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.

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.

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.

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.

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.

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.

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.

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.

Terms are set by the Importer of Record provider after reviewing your import profile. Hamburg Logistics does not quote pricing.