An importer of record (IOR) is a person or entity that is legally responsible for ensuring that imported goods comply with all customs and legal requirements of the importing country.

With all the changes in our industry and businesses, we thought it would be helpful if we listed off some of your responsibilities as importer of record:

• You must ensure that ISF filings are timely and correct. Please refer to CFR 149.2(b), CFR 149.2(c) and CFR 149.2 (d). Note: Shipment tracking for every ISF filing and every entry we prepare on your behalf is available to you via our portal, Shapiro 360°.  We encourage you to review this information routinely and advise us if any information needs to be corrected, so we can adjust the filing/entry declaration immediately.
• Fully understand the products you are importing as well as the U.S. regulations that affect them; do not depend on your vendors for this information.
• Please alert us whenever any information that needs to be declared to Participating Government Agencies (PGA) has changed.  As an example, Food and Drug Administration (FDA) product codes include detail to the packaging level. If the packaging changes, the product code will change, and we need to update.
• When/if you receive a notice from Customs and Border Protection (CBP) or a PGA, read it closely. Research as needed and ensure responses are comprehensive and timely.
• Ensure your commercial invoices include all the information that Customs and PGAs require, such as full manufacturer detail. Please refer to 19 CFR 141.86 and CFR 141.89.
• Tariff classifications must be accurate. Review your classifications to be sure they are correct.
• Review Trade Remedies to see if your product is affected by additional tariffs.
• Confirm the value of your merchandise is correct and meets Customs requirements.
• If your cargo is subject to antidumping/countervailing duties (ADD/CVD), ensure you have supplied us with a non-reimbursement statement for our files. Also, ensure that you provide us with the actual manufacturer of the goods. The Importer is responsible for determining whether ADD or CVD applies to your products. It is important to inform Shapiro. If there is an ADD or CVD case on file for your product and it does not apply to your specific product, please provide us with the reason why.
• Ensure your declaration for a Free Trade Agreement fully meets the requirements set out by Customs.
• Be sure your commodity is marked properly with the country of origin per CBP.
• If your commodity is protected by Intellectual Property Rights (IPR) such as patents, trademarks, and copyrights, be sure you have the authorizations and licenses in place to import the merchandise. Please refer to 19 CFR 133, Subpart C.
• Remember to alert us if you receive a binding ruling on your product; this must be reported with each customs entry.
• It is a good practice to review your 7501 within 10 days (duty payment due to CBP) to ensure accuracy of your information submitted to U.S. Customs.
• If you receive a CBP form 28 (Request for Information) or CBP form 29 (Notice of Action) Respond and review carefully to ensure complete and accurate responses are provided on form 28, and you agree with the proposed action that CBP is taking. Be sure to respond within the designated time frame to these notices.
• Importers must comply with all recordkeeping requirements and be familiar with the “(a)(1)(A) list” found in CFR 19 Part 163 Appendix.  

In addition to shipment level detail, please remember that there are many analytical tools and reports available to you on Shapiro 360°. As always, please reach out to [email protected] if you have any questions about your responsibilities.