Importer of Record (IOR): Duties, Bonds & DDP Risks
What an Importer of Record does, why it carries duty and audit liability, and why foreign sellers quoting DDP often get trapped without a local IOR.
Quick Answer: Importer of Record (IOR)
What the IOR is liable for
The IOR answers for correct tariff codes, values and origin claims. If customs later finds an error, it bills the IOR for the duty shortfall plus interest and penalties. The liability stays with the IOR even if a broker filed the entry.
Registrations an IOR needs
Countries require a local identifier: an EORI number in the EU and UK, an Importer Exporter Code (IEC) in India, or an importer number and customs bond in the US. A foreign company without these cannot act as importer in most countries.
The DDP trap
Under DDP the seller must clear import and pay duty. If the seller has no local registration, it either cannot clear the goods or relies on the buyer to act as importer, which breaks the DDP promise and can shift VAT recovery rights. Use DAP, or appoint an IOR service or fiscal representative before quoting DDP.
At a glance
| Country | IOR identifier | Record keeping |
|---|---|---|
| United States | Importer number plus customs bond | 5 years (19 CFR Part 163) |
| European Union | EORI number | Set by each member state |
| United Kingdom | GB EORI number | Typically 4 years for customs records |
| India | Importer Exporter Code (IEC) | Set by Customs Act and rules |
Worked example
A German seller quotes DDP Chicago for EUR 40,000 of parts. It has no US importer number or bond. It must either appoint a US IOR service, typically charging a fee per entry plus a bond, or switch to DAP Chicago so the US buyer acts as importer and pays duty itself.
Frequently asked questions
Can a foreign company be Importer of Record?
Often yes, if it obtains the local registration and, in the US, a customs bond. Some countries require a local entity or fiscal representative.
Is the customs broker the Importer of Record?
No. The broker files on behalf of the IOR. The IOR stays legally liable.
Why does DDP need an Importer of Record?
DDP makes the seller clear import and pay duty, which only a registered importer can do in the destination country.
Frequently asked questions
Can a foreign company be Importer of Record?#
Often yes, if it obtains the local registration and, in the US, a customs bond. Some countries require a local entity or fiscal representative.
Is the customs broker the Importer of Record?#
No. The broker files on behalf of the IOR. The IOR stays legally liable.
Why does DDP need an Importer of Record?#
DDP makes the seller clear import and pay duty, which only a registered importer can do in the destination country.