The importer of record is the entity legally responsible for ensuring imported goods comply with all U.S. laws and regulations. The IOR is liable for paying duties, taxes, and fees — and for the accuracy of all customs filings. Greenwich Mercantile helps companies establish and manage their importer of record status.
Book a Free ConsultationA customs broker is a licensed professional who files entries on behalf of the IOR. The broker acts as agent — the IOR retains legal responsibility. Even when a broker prepares and submits filings, the importer of record is liable for accuracy and compliance.
The consignee is the party to whom the goods are shipped. The IOR is the party legally responsible for customs compliance. They can be the same entity, but they do not have to be — and the legal obligations are entirely different.
The IOR must correctly classify every imported product under the Harmonized Tariff Schedule. Misclassification is the single most common cause of CBP penalties, accounting for 42% of all penalty cases. Classification determines duty rates, trade agreement eligibility, and regulatory requirements.
The IOR is responsible for paying all duties, taxes, and fees assessed on imported goods. This includes regular duties, antidumping and countervailing duties, merchandise processing fees, and harbor maintenance fees. Payment must be timely — late payments incur interest and potential penalties.
Federal law requires the IOR to maintain all import records for five years from the date of entry. This includes commercial invoices, packing lists, bills of lading, entry summaries, and all correspondence with CBP. Records must be produced within 30 days of a CBP request.
Depending on the product, the IOR must satisfy requirements from participating government agencies: FDA registration and prior notice for food, USDA permits for agricultural products, EPA compliance for chemicals, and CPSC testing for consumer products.
CBP can request additional information, documentation, or samples at any point after entry. The IOR must respond promptly and accurately. Failure to respond can result in liquidated damages, increased examination rates, and referral to the Office of Trade.
The IOR must exercise "reasonable care" in all customs transactions. This means taking affirmative steps to ensure compliance — not merely relying on a broker's expertise. CBP evaluates reasonable care based on the complexity of the transaction and the importer's resources.
If your company is based outside the United States and does not have a U.S. legal entity, you need an importer of record to bring goods into U.S. commerce. Without a U.S. entity, you cannot obtain a customs bond or receive an IOR number from CBP. A licensed customs broker or U.S.-based partner can serve as your IOR and assume the compliance obligations on your behalf.
Companies importing for the first time face a steep learning curve: IOR registration, customs bond procurement, HTS classification, ACE portal setup, and compliance with participating government agencies. Professional IOR services compress this process from weeks of trial and error to days of guided setup.
Many direct-to-consumer brands start by shipping individual packages under the $800 de minimis threshold, where no formal customs entry is required. But as order volumes grow and the de minimis exemption faces increasing restrictions, these brands need to transition to formal entries — which requires an IOR and a customs bond.
Some importers already have IOR status but lack the internal resources to manage ongoing compliance: classification reviews, duty optimization, PGA requirements, and CBP audits. IOR services from a licensed broker provide the compliance infrastructure without the overhead of a full-time trade compliance team.
We prepare and file CBP Form 5106 to register your entity as an importer of record. We verify your EIN, ensure your business information is accurate, and submit to CBP. Most registrations are processed within 1 to 5 business days.
We configure your Automated Commercial Environment (ACE) portal access, giving you visibility into your entry filings, duty payments, and compliance status. ACE is CBP's primary system for trade processing, and proper setup is essential for efficient operations.
We work with surety companies to secure your customs bond — either a single-transaction bond or a continuous bond that covers all entries for a year. Continuous bonds are required for importers who file more than occasional entries.
Every customs entry filed by Greenwich Mercantile costs a flat $100 — any product, any size, any origin country. No per-line-item charges, no surcharges for complex classifications, and no hidden fees. Compare our pricing against the industry.
We monitor your import activity for classification accuracy, duty rate changes, trade remedy updates, and regulatory shifts. When something changes that affects your supply chain, you hear from us before it becomes a problem.
We review your tariff classifications and sourcing structure to identify legitimate opportunities to reduce duty costs. This includes trade agreement qualification, tariff engineering, and first sale valuation where applicable.
U.S. companies use their Employer Identification Number (EIN) from the IRS. Foreign companies without a U.S. entity can apply for an EIN using IRS Form SS-4 — which typically takes 1 to 2 weeks for non-U.S. applicants. Individual importers may use their Social Security Number. The EIN or SSN becomes the basis of your IOR number and is tied to all future customs entries.
CBP Form 5106 registers your entity in CBP's system as an importer of record. It requires your legal entity name, address, EIN, business type, and contact information. Greenwich Mercantile prepares and submits this form on your behalf, ensuring all fields are accurate and complete. Processing typically takes 1 to 5 business days.
A customs bond is a financial guarantee required by CBP for all formal entries (shipments valued over $2,500). The bond ensures payment of duties, taxes, and fees. Continuous bonds — which cover all entries for a year — typically cost $300 to $500 annually and are recommended for regular importers. Learn more about what a customs bond is and how it works.
The Automated Commercial Environment (ACE) is CBP's online portal for managing import transactions. Setting up access allows you to view entry summaries, track duty payments, and monitor compliance status. Greenwich Mercantile configures your ACE access and ensures your broker permissions are properly linked.
Once your IOR number is active, your customs bond is in place, and your ACE access is configured, you are ready to file customs entries. Greenwich Mercantile files each entry at a flat rate of $100. Your first entry can typically be filed within 2 to 3 weeks of initial engagement, depending on EIN and bond processing times.
The importer of record (IOR) is the entity legally responsible for ensuring imported goods comply with all U.S. laws, paying duties and taxes, and maintaining accurate customs documentation. The consignee is the party to whom the goods are being shipped. In many transactions, the IOR and consignee are the same entity — but they do not have to be. A foreign seller might be the consignee while a U.S.-based customs broker or designated agent serves as the IOR. The distinction matters because liability for compliance and duty payment rests entirely with the IOR, not the consignee.
Yes, but with significant limitations. A foreign company can serve as the IOR for U.S. imports, but it must have a U.S. address for CBP correspondence, obtain an Employer Identification Number (EIN) from the IRS, and post a customs bond. In practice, most foreign companies without a U.S. entity choose to designate a licensed customs broker or a U.S.-based partner as their IOR. This avoids the administrative burden and ensures someone with U.S. legal standing is accountable to CBP.
CBP Form 5106 — Create/Update Importer Identity Form — is the document used to register an entity with U.S. Customs and Border Protection as an importer of record. It collects identifying information including the entity's name, address, EIN or SSN, and business type. Filing Form 5106 is required before making your first customs entry. It assigns your IOR number, which appears on every subsequent entry filing. Greenwich Mercantile handles Form 5106 preparation and submission as part of our IOR registration service.
IOR registration through CBP typically takes 1 to 5 business days once Form 5106 is submitted. However, the total timeline depends on prerequisites: obtaining an EIN (1 to 2 weeks for foreign entities), securing a customs bond (1 to 3 business days), and setting up ACE portal access (1 to 2 business days). With Greenwich Mercantile managing the process, most companies are fully registered and ready to file entries within 2 to 3 weeks from initial engagement.
Greenwich Mercantile charges $100 per customs entry filing — flat rate, any shipment size, any origin country. IOR registration and setup are handled as part of onboarding. There are no monthly minimums, no per-line-item surcharges, and no hidden fees for compliance monitoring or CBP correspondence. The customs bond, which is a separate requirement, typically costs $300 to $500 per year for a continuous bond.
Book a free 30-minute consultation. We will walk you through the IOR registration process and have you filing entries within weeks.
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