Importer of Record - Who is the IOR and what are the responsibilities?

Importer of Record - Who is the IOR and what are the responsibilities?

Overview

The Importer of Record (IOR) is the person or legal entity that customs recognizes as responsible for the import and for complying with all import laws.
Simply, the Importer of Record is the party legally responsible for the shipment when it enters a country.

Who is the Importer of Record (IOR)?

Most commonly, the IOR is one of the following:

1. The Buyer / Owner of the Goods
  1. The most common scenario
  2. Usually listed on the commercial invoice
  3. Has a tax ID/import registration in the destination country (e.g. EIN in the U.S.)
2. The Consignee
  1. If they own the goods at time of import
  2. Often the buyer, but not always
  3. Customs looks at ownership and responsibility, not just the name
3. A Local Subsidiary or Branch
  1. Used when the foreign seller has a registered entity in the importing country
4. A Third-Party Importer of Record Service
  1. Used when the buyer has no local entity
  2. That third party legally assumes all import liability

Who is not automatically the Importer of Record (IOR)?

(unless specifically agreed)
  1. Freight forwarder
  2. 3PL / warehouse - 3PLs should never be IOR by default
  3. Carrier
  4. Customs broker (normally acts on behalf of the IOR)

What is the difference between Responsible Person (RP) and IOR?

While Expandly may act as your Responsible Person representative, this role is separate and distinct from that of the Importer of Record. Acting as Responsible Person means we support you with regulatory compliance and representation requirements, but it does not transfer ownership of the goods or responsibility for the customs import declaration.

If I have goods in your Warehouse locations, does Expandly become the IOR?

Our warehouse locations do not become the Importer of Record (IOR) because control, ownership, and legal responsibility for the goods do not transfer to us.
As a warehouse and logistics service provider, we:
  1. Store and handle your goods
  2. Coordinate transportation and delivery
  3. Support customs clearance on your behalf
However, we do not own the products and do not control how they are declared to customs, so we cannot legally take on the role of Importer of Record.

The Importer of Record must be the buyer, seller, or another authorized party that:
  1. Owns the goods at time of import
  2. Has a local tax or importer number
  3. Accepts responsibility for customs compliance

Can Expandly offer a stand alone Importer of Record service? 

At this time, Expandly does not offer a stand-alone Importer of Record service and is unable to act as the IOR for your goods. The Importer of Record must be the goods owner or an authorized third party that can assume full customs and regulatory responsibility.

That said, Expandly is happy to support you with end-to-end logistics to move your goods into the region. In addition, our trusted partner GEL can assist with Importer of Record–related questions and guide you through the customs and compliance requirements as part of this process.

To summarise:

If your name and tax ID are on the customs entry — you are the Importer of Record.

Need more help? 

If you need more support, please Contact Us and the Team will be happy to help. 

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