SSLT Global
Customs6 min read

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.

By SSLT Global Editorial·Published ·Reviewed against US 19 CFR Part 141 / Incoterms® 2020 (ICC 723E), November 2026

Quick Answer: Importer of Record (IOR)

The Importer of Record (IOR) is the party legally responsible for an import: it files or authorises the customs declaration, pays duty and tax, and answers for classification, value and origin in later audits. In the US it usually needs a customs bond, and records must be kept for five years (19 CFR Part 163). Foreign sellers quoting DDP must arrange a local IOR or registration first.

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

CountryIOR identifierRecord keeping
United StatesImporter number plus customs bond5 years (19 CFR Part 163)
European UnionEORI numberSet by each member state
United KingdomGB EORI numberTypically 4 years for customs records
IndiaImporter 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.

Standards referenced: US 19 CFR Part 141 · Incoterms® 2020 (ICC 723E)

This guide is decision-support, not banking, tax, legal or customs advice. See our editorial standards.

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Reviewed by SSLT Global Trade Compliance Team ·Methodology&Primary Sources