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Blog · Policy & compliance · October 31, 2026

Importer of Record: What Amazon Sellers Need to Know

If you manufacture abroad and sell in the US, someone is legally responsible for every shipment that enters the country. That party is the importer of record. Many sellers have never checked who theirs is, because a freight forwarder handled it. New US customs rules aimed at foreign importers of record make that question important. This guide explains what an importer of record is, what is changing, and how to prepare.

What an importer of record is

The importer of record (IOR) is the person or company that is legally responsible for goods entering the United States. The IOR makes sure the goods are declared correctly, classified under the right tariff codes, valued accurately, and that all duties, taxes and fees are paid. If something goes wrong, such as a misclassified product, an undervalued invoice or a missing safety certificate, US Customs and Border Protection (CBP) holds the IOR responsible.

The IOR is not always the seller. Common arrangements include:

  • Your own US company as IOR. A US LLC or corporation, with its own customs bond, imports the goods.
  • Your foreign company as IOR. A company registered outside the US, for example in China, the UK or Pakistan, is listed as the importer.
  • A freight forwarder or third party acting as IOR. Some forwarders offer "IOR services" or delivered duty paid shipping, where their own entity is listed.

Note that Amazon does not act as importer of record for FBA inventory. Amazon's FBA rules require the seller's side to arrange the import.

What is changing

In June 2026 the US government issued Executive Order 14411, Strengthening Customs Enforcement. It directs federal agencies to tighten rules for importers of record and treats foreign IORs differently from US IORs. Under the order, a foreign IOR is any importer that does not meet the definition of a US importer, which includes individuals who are not US citizens or permanent residents.

Among the measures the order directs, as published in the Federal Register:

  • Foreign importers of record are to be barred from filing informal entries, the simpler process used for lower value shipments.
  • Foreign IORs will need to be validated in the CTPAT program where eligible, or use a CTPAT-validated licensed customs broker to file entries.
  • CBP is to set risk-based tiers for importers based on compliance history, and importers not in good standing can be barred from importing.

Most of these measures need formal rules from the Department of Homeland Security and CBP before they take full effect. Amazon told sellers in October 2026 that a rule for foreign importers of record is under government review and could be implemented quickly. Nothing has changed in day to day operations yet, but Amazon recommends that sellers review their customs arrangements now.

Why it matters for Amazon sellers

A large share of third-party sellers import through a foreign entity or through a forwarder's foreign entity. If foreign IORs face asset, bonding and good-standing requirements, some of those arrangements may become slower, more expensive or unavailable. The risk is a shipment held at the port during a busy season, followed by stockouts, lost ranking and storage fees on the inventory that does arrive.

Sellers with a US-based IOR are likely to see fewer changes. That is one more reason many international founders set up a US company, as covered in our guide to forming a US LLC to sell on Amazon.

How to prepare

  1. Find out who your IOR is. Ask your freight forwarder or customs broker directly: "Is my importer of record a US entity or a foreign entity?" You can also check the importer name on your entry documents (CBP Form 7501). If you do not know who your forwarder is, check your shipping agreement.
  2. If your IOR is foreign, ask how they are preparing. Ask about bonding, CTPAT status, and how they plan to meet good-standing requirements. A vague answer is a warning sign.
  3. Get your paperwork in order. Accurate HTS classifications, commercial invoices with true transaction values, country of origin marking, and any product certificates your category needs. Under stricter enforcement, errors carry more weight.
  4. Consider a US IOR structure. A US LLC with an EIN, a continuous customs bond and a licensed customs broker gives you direct control over your imports. It takes a few weeks to set up, so start before you need it.
  5. Build buffer stock. While the rules are being finalised, carry a little more safety stock on your best sellers so a delayed shipment does not take them out of stock.

Setting up a US importer of record

For a foreign founder, the usual path is:

  • Form a US company, often an LLC in a state such as Wyoming, Delaware or Texas. See our LLC formation service.
  • Obtain an EIN from the IRS. See EIN registration.
  • Open a US business bank account. See US business banking.
  • Buy a continuous customs bond through a licensed broker or surety, and register the company as an importer with CBP.
  • Appoint a licensed customs broker to file entries on your behalf.

Once in place, the same company can also hold your Amazon seller account, which keeps your corporate, tax and import records aligned.

What this means for sellers

The importer of record has always carried the legal risk of an import. The new rules make the choice of IOR a business decision rather than a detail left to a forwarder. Confirm who your IOR is this month, ask hard questions if it is a foreign entity, tidy up your import paperwork, and consider whether a US company should take that role. This article is general information, not legal or customs advice. Speak with a licensed customs broker about your specific situation.

Need a US company for importing and selling?

We help international sellers form a US LLC, get an EIN and open a bank account.

See US company formation Book a free strategy call →

Sources

  • Amazon Seller Central, Seller News: "Prepare now for U.S. regulatory import changes" (October 19, 2026), sellercentral.amazon.com/seller-news
  • The White House: Strengthening Customs Enforcement (June 2026), whitehouse.gov
  • Federal Register, Volume 91, Number 111 (June 10, 2026), Executive Order 14411, govinfo.gov
  • U.S. Customs and Border Protection: Importing into the United States, cbp.gov

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Blog · Policy & compliance · October 31, 2026

Importer of Record: What Amazon Sellers Need to Know

If you manufacture abroad and sell in the US, someone is legally responsible for every shipment that enters the country. That party is the importer of record. Many sellers have never checked who theirs is, because a freight forwarder handled it. New US customs rules aimed at foreign importers of record make that question important. This guide explains what an importer of record is, what is changing, and how to prepare.

What an importer of record is

The importer of record (IOR) is the person or company that is legally responsible for goods entering the United States. The IOR makes sure the goods are declared correctly, classified under the right tariff codes, valued accurately, and that all duties, taxes and fees are paid. If something goes wrong, such as a misclassified product, an undervalued invoice or a missing safety certificate, US Customs and Border Protection (CBP) holds the IOR responsible.

The IOR is not always the seller. Common arrangements include:

  • Your own US company as IOR. A US LLC or corporation, with its own customs bond, imports the goods.
  • Your foreign company as IOR. A company registered outside the US, for example in China, the UK or Pakistan, is listed as the importer.
  • A freight forwarder or third party acting as IOR. Some forwarders offer "IOR services" or delivered duty paid shipping, where their own entity is listed.

Note that Amazon does not act as importer of record for FBA inventory. Amazon's FBA rules require the seller's side to arrange the import.

What is changing

In June 2026 the US government issued Executive Order 14411, Strengthening Customs Enforcement. It directs federal agencies to tighten rules for importers of record and treats foreign IORs differently from US IORs. Under the order, a foreign IOR is any importer that does not meet the definition of a US importer, which includes individuals who are not US citizens or permanent residents.

Among the measures the order directs, as published in the Federal Register:

  • Foreign importers of record are to be barred from filing informal entries, the simpler process used for lower value shipments.
  • Foreign IORs will need to be validated in the CTPAT program where eligible, or use a CTPAT-validated licensed customs broker to file entries.
  • CBP is to set risk-based tiers for importers based on compliance history, and importers not in good standing can be barred from importing.

Most of these measures need formal rules from the Department of Homeland Security and CBP before they take full effect. Amazon told sellers in October 2026 that a rule for foreign importers of record is under government review and could be implemented quickly. Nothing has changed in day to day operations yet, but Amazon recommends that sellers review their customs arrangements now.

Why it matters for Amazon sellers

A large share of third-party sellers import through a foreign entity or through a forwarder's foreign entity. If foreign IORs face asset, bonding and good-standing requirements, some of those arrangements may become slower, more expensive or unavailable. The risk is a shipment held at the port during a busy season, followed by stockouts, lost ranking and storage fees on the inventory that does arrive.

Sellers with a US-based IOR are likely to see fewer changes. That is one more reason many international founders set up a US company, as covered in our guide to forming a US LLC to sell on Amazon.

How to prepare

  1. Find out who your IOR is. Ask your freight forwarder or customs broker directly: "Is my importer of record a US entity or a foreign entity?" You can also check the importer name on your entry documents (CBP Form 7501). If you do not know who your forwarder is, check your shipping agreement.
  2. If your IOR is foreign, ask how they are preparing. Ask about bonding, CTPAT status, and how they plan to meet good-standing requirements. A vague answer is a warning sign.
  3. Get your paperwork in order. Accurate HTS classifications, commercial invoices with true transaction values, country of origin marking, and any product certificates your category needs. Under stricter enforcement, errors carry more weight.
  4. Consider a US IOR structure. A US LLC with an EIN, a continuous customs bond and a licensed customs broker gives you direct control over your imports. It takes a few weeks to set up, so start before you need it.
  5. Build buffer stock. While the rules are being finalised, carry a little more safety stock on your best sellers so a delayed shipment does not take them out of stock.

Setting up a US importer of record

For a foreign founder, the usual path is:

  • Form a US company, often an LLC in a state such as Wyoming, Delaware or Texas. See our LLC formation service.
  • Obtain an EIN from the IRS. See EIN registration.
  • Open a US business bank account. See US business banking.
  • Buy a continuous customs bond through a licensed broker or surety, and register the company as an importer with CBP.
  • Appoint a licensed customs broker to file entries on your behalf.

Once in place, the same company can also hold your Amazon seller account, which keeps your corporate, tax and import records aligned.

What this means for sellers

The importer of record has always carried the legal risk of an import. The new rules make the choice of IOR a business decision rather than a detail left to a forwarder. Confirm who your IOR is this month, ask hard questions if it is a foreign entity, tidy up your import paperwork, and consider whether a US company should take that role. This article is general information, not legal or customs advice. Speak with a licensed customs broker about your specific situation.

Need a US company for importing and selling?

We help international sellers form a US LLC, get an EIN and open a bank account.

See US company formation Book a free strategy call →

Sources

  • Amazon Seller Central, Seller News: "Prepare now for U.S. regulatory import changes" (October 19, 2026), sellercentral.amazon.com/seller-news
  • The White House: Strengthening Customs Enforcement (June 2026), whitehouse.gov
  • Federal Register, Volume 91, Number 111 (June 10, 2026), Executive Order 14411, govinfo.gov
  • U.S. Customs and Border Protection: Importing into the United States, cbp.gov

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