Importer of Record USA: who holds the role, what it carries, and what is in effect in 2026

The Importer of Record (IOR) for a United States entry is the party that makes entry under 19 U.S.C. §1484 and is primarily liable for the duties on the goods. It is the owner or purchaser of the merchandise, or a licensed customs broker that the owner, purchaser, or consignee has designated. Every formal entry has exactly one, and CBP looks to that party for the accuracy of the entry, the bond, and the records.

This page is the starting point for the Importer of Record topic on this site. It states the rule once, shows where the 2026 changes sit, and links to the page that covers each question in full: who needs one, what is required, how foreign companies handle the role, and what a service structure is and is not. It is written for compliance, finance, and supply chain leaders, including those at importers of pharmaceuticals, steel and aluminum, oil and gas equipment, chemicals, copper, machinery, semiconductors, and vehicles.

What the statute says

Under 19 U.S.C. §1484(a)(1), entry is made by one of the parties qualifying as importer of record under paragraph (2)(B), in person or through an agent authorized in writing. Under §1484(a)(2)(B), the entry documentation is filed by the owner or purchaser of the merchandise, or by a person holding a valid license under 19 U.S.C. §1641 when designated. The statute closes by stating that the importer of record must be one of the parties eligible to file.

The test is ownership or purchase at the time of entry. It is not the country where a company is based, and it is not a title a forwarder or supplier gives itself. The right to make entry post covers who counts as owner or purchaser.

What the role carries

19 C.F.R. §101.1 defines the importer as the person primarily liable for the payment of any duties on the merchandise, or an authorized agent acting on that person’s behalf. That liability sits with the IOR for every duty collected at entry, including Section 232 and Section 301 duties.

Under 19 C.F.R. §24.5, a party importing files CBP Form 5106 with its first formal entry. The identification number on the form is the IRS employer identification number, or a Social Security number if there is no EIN, and CBP assigns a number where the filer has neither. The Importer of Record page lists the remaining obligations, and the definitions post gives the legal source for each term.

The nonresident condition

A company not incorporated in the United States is a nonresident corporation. Under 19 C.F.R. §141.18 it may not enter merchandise for consumption unless it has a resident agent in the state of the port of entry authorized to accept service of process, and files a bond on CBP Form 301 with the conditions of 19 C.F.R. §113.62 and a resident corporate surety. This applies to a manufacturer in Brazil or another Latin American country selling on delivered terms, as it applies to a producer anywhere else that keeps title through delivery. The nonresident importer post walks through both conditions.

Where each question is answered

• Do I need one? Four situations decided by who owns the goods at entry: do I need a US importer of record and the who needs a US IOR page.
• What is required in 2026? The dated list of requirements: Importer of Record requirements 2026, and the Q4 2026 deadlines.
• I am a foreign company. Foreign importer of record requirements and the foreign Importer of Record page.
• What is an IOR service? What the structure is and is not: US Importer of Record services.
• What duty does the IOR owe? The customs valuation page, and the sector pages for pharmaceuticals, steel and aluminum, and oil and gas equipment.

What is in effect as of October 20, 2026

CBP published the notice Accuracy of Importer of Record Data Submitted to CBP on August 19, 2026. It states that enhanced enforcement, including immediate voiding of IOR numbers with inaccurate Form 5106 information, would commence on September 18, 2026. The notice requires the physical address to be the actual location of the business or individual, and it cannot be a registered agent, customs broker, freight forwarder, P.O. box, or business service center. The email address and phone number must be valid and belong to the IOR. A customs broker must hold a power of attorney executed directly with the IOR. The Form 5106 post covers the notice.

What is in rulemaking

Executive Order 14411, Strengthening Customs Enforcement, signed June 3, 2026 and published at 91 FR 35125 on June 10, 2026, directs several changes for Importers of Record. Section 2(a)(i) calls for a minimum level of tangible domestic assets, bonding, or both. Section 2(b)(i) calls for prohibiting a foreign IOR from filing informal entry. Section 2(c)(i) provides that a foreign IOR may not rely on a continuous bond for formal entry except as CBP permits, and must be CTPAT validated or use a CTPAT validated and licensed customs broker. Section 2(d) calls for a good standing requirement for all IORs. Section 4(c) calls for a minimum penalty floor of not less than 50 percent of the assessed penalty.

None of those provisions has an effective date. CBP’s advance notice of proposed rulemaking, Heightened Import Disclosures for Supply Chain Visibility, published September 2, 2026, takes comments through December 1, 2026. A separate proposed rule on informal entries of $2,500 or less, published October 8, 2026 at 91 FR 64532, takes comments through December 7, 2026 and is not in effect. The tracker carries the dated position of each.

The facts that decide

• Who owns or purchases the goods at the moment the entry is filed, under your contract terms and title documents
• Whether that party is incorporated in the United States, which decides whether 19 C.F.R. §141.18 applies
• Which party is named as importer on your entries today
• Whether the Form 5106 for that party carries a physical address, email, and phone that belong to it
• Whether the broker filing holds a power of attorney executed directly with the IOR
• Whether a bond is in place that matches the entry type
• Where the records for each entry are kept, and by whom

Tell us what you import and how your entries are filed today, and we’ll show you where you stand: see if you qualify or write to ship@iorusa.com.

Sources

• 19 U.S.C. §1484, entry of merchandise
• 19 C.F.R. §101.1, definitions
• 19 C.F.R. §24.5, filing identification number
• 19 C.F.R. §141.18, entry by nonresident corporation
• CBP, Accuracy of Importer of Record Data Submitted to CBP, August 19, 2026
• Executive Order 14411, Strengthening Customs Enforcement, 91 FR 35125, June 10, 2026