What Is an Importer of Record?

The importer of record is the party that makes entry for imported merchandise with CBP and completes it, in person or through an agent authorized in writing, using reasonable care. Federal law requires one of the parties qualifying as importer of record to do this for each entry.

Making and completing entry has two parts:

• Release. Filing the documentation or electronic data CBP needs to decide whether the merchandise may be released from its custody.
• Assessment. Filing the declared value, classification and rate of duty, and any other information CBP needs to assess duties, collect accurate statistics and check other legal requirements.

Entries are signed by the importer of record or its agent. When an entry is filed electronically, each transmission is certified by the importer of record or its agent, one of whom must be resident in the United States to receive service of process.

The obligations that follow the entry stay with the importer:

• Duties. CBP's regulations make the liability for duties a personal debt of the importer, and paying a broker for duties does not relieve the importer if the broker does not pay them.
• Bond. Delivering a customs bond with the entry protects the revenue of the United States and does not relieve the importer of its liabilities.
• Records. Records relating to an entry are generally kept for 5 years from the date of entry, with exceptions the regulations list.

This is general information, not legal or customs advice.

CBP's definition of importer, the person primarily liable for paying duties, lists the consignee and the importer of record as separate possibilities. The statute lets the consignee designate a licensed broker to file, and when a consignee declares on entry that it is the owner or purchaser, CBP may accept that declaration. A consignee that is not the actual owner can declare that when the entry summary is filed, to be relieved of statutory liability for increased and additional duties, and can file a bond of the actual owner to be relieved of the matching bond liability.

A manufacturer in Texas buys $25,000 of motors from a supplier abroad, so as the purchaser it can be the importer of record. First, it files CBP Form 5106 with its first formal entry, using its IRS employer identification number. Then it designates a licensed customs broker, who files the entry with the declared value and classification.

At an illustrative 2.5 percent duty rate, that is $25,000 x 0.025 = $625. The manufacturer owes the $625 even if it pays the broker and the broker never pays CBP, and it keeps the entry records for 5 years.

Shopify tells international merchants that sell to the United States, and US merchants that dropship, to add Harmonized System (HS) codes and country of origin to all their products, individually, in bulk or by CSV file. Customs duty is calculated from the declared value and shipping costs, the HS code, the country of origin, the destination's tariff rates and any applicable trade treaties.

For stock you import, Shopify's purchase order records the agreement with your supplier and the linked inventory transfer handles shipments, receiving and cost adjustments. Customs duties are one of the adjustment types you can add to a shipment, so you can compare the agreed cost on the purchase order with the actual cost to receive the goods.

On Uncap's Acumatica integration page, the product catalog card lists real-time product information, descriptions, pricing, UoMs and HS codes, pulled directly from Acumatica.

• Customs broker
• HTS code
• Country of origin
• Consignee
• Landed cost

• LII: 19 U.S. Code 1484, Entry of merchandise
• eCFR: 19 CFR 141.1, Liability of importer for duties
• eCFR: 19 CFR 24.5, Filing identification number