Do you need a United States Importer of Record?
Find the description that matches your situation.
You are a foreign manufacturer selling into the United States
Your goods are made abroad and sold to US buyers. Someone has to be legally answerable to CBP for the entry, and increasingly that party needs to be a US entity that can demonstrate assets, bonding, and good standing.
What to check: who is named as Importer of Record on your current entries, and whether that party meets the requirements coming out of the 2026 rulemaking.
You are an overseas ecommerce seller
You ship to US customers directly, or into US fulfillment centers. You may have been relying on informal entry, on a carrier’s arrangement, or on your customers acting as importer.
What to check: the order restricts informal entry filing to US Importers of Record. If your volume has been moving under informal entry, that route is narrowing.
You are a nonresident importer
You act as your own Importer of Record without a US entity. This has been permitted, and it is becoming harder.
What to check: foreign entities face heightened requirements for formal entry under the 2026 order. Confirm whether your current structure clears the bar being set.
Your overseas supplier currently acts as Importer of Record
Common in DDP arrangements. Your supplier handles everything and you take delivery. It works right up until it does not.
What to check: whether your supplier can meet the asset, bonding, good standing, and vetting requirements. If they cannot, the goods stop, and it is your inventory that is sitting at the port.
You are a US importer with a working arrangement
You have a US entity, a customs broker, a continuous bond, and entries that clear without drama. You may not need an Importer of Record at all.
What might still be worth a look: whether your entries are filed under the correct method in the valuation hierarchy under 19 U.S.C. ยง1401a. That is a different question from IOR, and it is covered on the customs valuation page.
Not sure which one you are
That is a common and reasonable place to be, particularly if imports are handled by a forwarder or a supplier and you have never had to look closely at the paperwork.
Tell us what you import and how shipments reach the United States today. We will tell you which situation you are in.