Who is the Importer of Record?

Definition of Importer of Record

The importer of record is defined as:

  • Owner or purchaser of merchandise; or
  • Consignee; or
  • Licensed customs broker when designated by the owner or purchaser of the merchandise or consignee

CBP considers an”owner” and “purchaser” to include any party with a financial interest in a transaction such as a buying or selling agent, or a person who imports for exhibition at a trade fair, or imports goods for repair or alteration.

More information from CBP may be found here.

Importer of Record Repsonsibilities

For food products the importer of record is responsible for:

  1. Payment of duty, taxes and fees
  2. Proper tariff classification of merchandise
  3. Proper valuation of merchandise
  4. Proper country of origin declaration
  5. Proper filing of entry documents
  6. Ensuring food is not adulterated or misbranded
  7. Ensuring imported merchandise does not violate intellectual property rights
  8. Redelivering merchandise to FDA (e.g. in the event it is discovered to be adulterated or misbranded)
  9. Complying with APHIS and FSIS requirements
  10. Redelivering merchandise to USDA
  11. Recordkeeping related to importation