Importer of Record (IOR)
The importer of record (IOR) is the party legally responsible for a U.S. customs entry — including the correct HTS code, duty payment, trade remedy compliance, and all applicable PGA requirements. The IOR bears ultimate classification liability regardless of who performed the classification analysis, and cannot delegate that liability to a customs broker or supplier.
In Detail
The importer of record is typically the owner or purchaser of the imported goods, or a licensed customs broker acting under a valid power of attorney. The IOR is identified by name and CBP-assigned filer code on the entry summary (CBP Form 7501). By filing — or causing a broker to file — the entry summary, the IOR certifies that all information in the filing is accurate and complete to the best of their knowledge. This certification carries legal weight: providing materially false information on a customs entry is a violation of 19 USC §1592, whether the error is intentional or negligent.
The IOR's classification liability is non-delegable under U.S. customs law. The Customs Modernization Act of 1993 established a "reasonable care" standard requiring importers to take positive steps to ensure classification accuracy — not simply rely on a broker's code or a supplier's documentation. Reasonable care, as CBP has defined it in guidance, includes researching applicable CROSS rulings, seeking binding rulings for complex or high-value products, maintaining classification documentation, and periodically reviewing classifications for accuracy. An importer who fails to exercise reasonable care faces elevated penalty exposure if CBP discovers classification errors.
In complex global supply chains, IOR status does not always rest with the obvious party. Under DDP (Delivered Duty Paid) Incoterms, the foreign seller assumes IOR responsibility. A U.S. subsidiary may be the IOR even when the parent company negotiated the purchase. A trading company or consolidator may hold IOR status for entries they did not purchase. Understanding who holds IOR status for each entry is a prerequisite for correctly assigning classification responsibility and liability within any supply chain structure.
Classification Significance
IOR status is the key variable in understanding who bears classification risk. The IOR is the party CBP will pursue for duty underpayments, penalties, and audit findings. In supply chains where classification responsibility is diffuse — brokers, suppliers, freight forwarders, and compliance teams all touch classification — the IOR is ultimately accountable for every HTS code on every entry. Ensuring that the IOR has the documentation to support its classifications is the core obligation of any trade compliance program.
How Kanon Handles This
Kanon provides importers of record with the Classification Support Package needed to demonstrate reasonable care in any CBP enforcement scenario — audit, CF-28, CF-29, or protest. The package documents the classification methodology, not just the HTS code, giving the IOR the evidentiary foundation to defend its compliance posture.