Last updated: September 18, 2026

In short: what is an importer of record?

The importer of record (IOR) is the person or business legally responsible to US Customs and Border Protection (CBP) for a shipment: they file the entry, pay duties and fees, and carry the liability if something is wrong with the paperwork or the goods. For most US businesses importing from China, the IOR is the US company itself, represented by a licensed customs broker who files on their behalf. You generally cannot use your Chinese supplier as IOR, and a foreign-registered business without a US presence usually needs a licensed customs broker acting as IOR, backed by a customs bond.

Who can legally be the importer of record for a China shipment?

Three groups can serve as IOR: the owner or purchaser of the goods, a licensed customs broker acting on the owner's behalf, or, in specific cases, the consignee. Most small and mid-sized US importers act as their own IOR, using a customs broker only to file the entry paperwork rather than to assume legal responsibility. If your business is not registered in the US, you typically cannot self-file as IOR and will need either a US-based subsidiary, a trusted partner who takes on the role, or a broker who can act as IOR of record under specific bonded arrangements.

What is the importer of record actually responsible for?

The IOR is on the hook for four things: accurate HS code classification, correct valuation for duty calculation, timely duty and tariff payment (including any Section 301 or antidumping duties that apply to China-origin goods), and compliance with any agency requirements, such as FDA, CPSC, or FCC rules for the product category. If CBP later finds an error, even an honest one, the IOR is who gets the bill, the penalty, or the audit request, not the factory and not the freight forwarder.

Do you need a customs bond as importer of record?

Yes. CBP requires a continuous or single-entry customs bond for nearly all formal entries, which is any shipment valued over 2,500 USD or subject to other agency requirements regardless of value. A continuous bond typically costs a few hundred dollars a year for a small importer and covers all your entries for twelve months; a single-entry bond is priced per shipment and makes sense if you only import occasionally. For the full step-by-step process once your bond is in place, see our guide to customs clearance from China to the USA.

Can a sourcing agent or broker act as your importer of record?

A sourcing agent does not typically act as IOR themselves, since IOR status carries direct legal and financial liability that most agents are not licensed or willing to hold. What a good sourcing agent does instead is make sure your shipment never runs into IOR problems in the first place: correct HS codes agreed before production, accurate commercial invoices from the factory, and a vetted customs broker relationship already in place, so filing is a formality rather than a scramble. Epic Sourcing coordinates this directly through our freight forwarding network so US clients are not left figuring out IOR requirements on their own mid-shipment.

Worked example: IOR responsibilities on a typical US import

Frequently asked questions

Can a foreign company be the importer of record in the US?

It is possible but harder: a non-US business generally needs a customs bond obtained through a US-based broker or resident agent, and CBP applies extra scrutiny. Most overseas brands selling into the US set up a US entity or work with a partner who takes on the IOR role instead.

What happens if you import without being properly set up as IOR?

CBP can hold the shipment at the port, assess penalties, or in repeat cases increase inspection rates on all your future entries. It is one of the more expensive mistakes to fix after the fact rather than before you ship.

Does the freight forwarder or the customs broker act as importer of record?

Neither, by default. The freight forwarder moves the cargo and the customs broker files the paperwork, but the legal IOR responsibility sits with the importing business unless a broker specifically agrees to assume it under a bonded arrangement.

How much does a customs bond cost?

A continuous bond for a small-to-mid-sized importer typically runs a few hundred US dollars per year, calculated against your expected annual duty liability. A single-entry bond is cheaper per shipment but only makes sense for occasional importers.

Do Section 321 de minimis shipments still need an importer of record?

Low-value shipments under the de minimis threshold have historically skipped formal entry, but that landscape changed in 2026 — see our guide to the Section 321 de minimis changes for what is different now and what still needs a formal IOR.

If you are also protecting a new product design before it goes into production, see our guide on NNN agreements and IP protection in China, and if your shipment volumes are large enough to benefit from duty deferral, our guide to bonded warehousing explains how that works across each market.

How Epic Sourcing helps

Epic Sourcing's bilingual team works directly with your Chinese manufacturers to get HS codes, invoices, and documentation right before goods ever leave the factory, then hands off to a vetted freight and customs network so your importer of record obligations are a formality, not a fire drill. If you are setting up your first US import and want a second set of eyes on the paperwork, get in touch with our team — no pressure, no obligation.