Last reviewed: October 4, 2026. Reading time: about 10 minutes.
Every guide on this site, including our own, keeps repeating one phrase: refund rights follow the importer of record. It is the single most important fact in this whole process, and it is also the one most businesses have never actually confirmed for themselves. Assuming you are the importer of record because you placed the order, paid the invoice, or received the goods, is not the same as actually being named that way on your customs entries.
This guide explains what the term legally means, how it gets set on an entry, the real-world situations where it gets confusing, and how to confirm yours before you file anything. If you have not yet worked through our eligibility checklist, Part A covers this same question in checklist form.
The short version: the importer of record (IOR) is the specific party named on a customs entry as legally responsible for the shipment and its duties. It is a formal designation, not just “whoever paid for the goods,” and only the IOR, or the licensed broker who filed on their behalf, can claim an IEEPA refund on that entry.
Transparency note: this guide is educational. At the end, we link to a referral partner and may earn a commission if you apply through that link. Read our affiliate disclosure and disclaimer.
In this guide
What “importer of record” actually means
The importer of record is the party formally named on a customs entry as legally responsible for the shipment, for declaring it accurately, and for paying the applicable duties. It is a specific legal role under U.S. customs law, not an informal description of who was involved in the transaction.
- The IOR must have a valid importer number, typically an IRS Employer Identification Number (EIN), or a CBP-assigned number for parties without one.
- The IOR is responsible for a customs bond, covering the duties and compliance obligations on the entry.
- The IOR’s name appears on the entry summary, CBP Form 7501, in the field for importer of record.
- Being the IOR is a legal and financial responsibility, not simply a label. It carries liability for the accuracy of the declared value, classification and duties.
How it gets set on an entry
When a shipment is imported, someone, usually a licensed customs broker acting on instructions, files the entry with CBP. That filing names the importer of record. A few points often cause confusion:
- A customs broker is not the importer of record simply by filing the entry. The broker acts as the IOR’s agent. The IOR is whoever the broker was instructed to name, based on the commercial arrangement.
- The “ultimate consignee” and the “importer of record” can be different parties on the same entry, though they are often the same company in a straightforward purchase.
- The IOR designation is set at the time of filing, based on the facts of that specific transaction, the terms of sale, who is bearing the risk and responsibility for the goods at the border.
Five common scenarios
You bought directly and your broker filed under your company
Usually clearIf you placed the purchase order, your company’s name and EIN appear on the entry, and your broker filed on your instructions, you are almost certainly the IOR. This is the simplest and most common case.
Your supplier shipped on delivered-duty-paid (DDP) terms
Needs verificationOn a DDP shipment, the supplier often arranges and pays for customs clearance as part of the delivered price. Depending on how that was structured, the supplier, or an agent acting on the supplier’s behalf, may have been named as the importer of record, not you. This does not automatically mean you have no financial interest, but it does mean you are not the party who files a CAPE Declaration.
You are a non-resident or foreign company importing into the US
Possible, with conditionsA foreign company can serve as importer of record if it secures a customs bond and works through a US-based agent or broker. This is less common for smaller businesses but is a recognized structure for larger international sellers.
You sell through a marketplace or fulfillment arrangement
Varies significantlyDepending on the specific program and contractual structure, the marketplace, the fulfillment provider, or you as the seller could be the importer of record. These arrangements vary enough that a general rule does not apply. Check your specific program’s terms or ask your broker directly.
Your company has multiple entities or recently changed names
Check carefullyIf a subsidiary, a renamed entity, or a related company was named on past entries, the refund rights follow that exact legal entity as named at the time of filing, not necessarily your current corporate structure. This is a detail worth confirming before assuming eligibility.
Why this matters specifically for refunds
CAPE Declarations can only be submitted by the importer of record, or the licensed customs broker who originally filed the entries for that IOR. There is no separate process for someone who bore the economic cost of the duty but was not named as IOR. This is the single most common reason a would-be claimant discovers they cannot file, covered in our mistakes guide as the top reason declarations get rejected at file level.
Economic cost and legal right are different questions. If you believe you ultimately bore the cost of a duty even though another party was the IOR, any claim to that money is a contractual matter between you and that party, not something CBP will resolve. Raise it with a contracts attorney, not with CBP.
How to confirm yours
- Pull a copy of your entry summary. CBP Form 7501 shows the importer of record field directly. Your customs broker can provide this for any entry.
- Check the name and EIN match your company exactly. A close but not exact match, a former name, a different entity, a typo, is worth investigating further.
- Ask your broker directly who they were instructed to file under. If you did not personally arrange the customs filing, your broker holds this information and can confirm it in one message.
- Review your purchase terms, especially for DDP or marketplace arrangements. The shipping terms in your contract or purchase order often explain who was responsible for import clearance.
- When in doubt, ask in writing and keep the answer. A documented confirmation from your broker or supplier is useful both for filing and for any later contractual questions.
Once you have confirmed your status, our pillar guide and eligibility checklist walk through the rest of the filing process.
Frequently asked questions
Not necessarily. It is whoever was formally named on the entry as legally responsible for the shipment, which depends on the shipping terms and who arranged customs clearance, not simply who paid the invoice.
Generally no. A broker acts as an agent, filing on behalf of the importer of record. The broker itself is not usually the IOR unless a specific, unusual arrangement makes it so.
Ask your customs broker for a copy of your entry summaries (CBP Form 7501). The importer of record field will show exactly who was named.
Not directly through CBP's process. Refund rights follow the IOR. Any claim you have to funds your supplier receives would be a contractual matter between you and them.
Each entry is evaluated on its own filing. If your company's name, structure, or EIN has changed, confirm which legal entity was actually named on the specific entries you are trying to claim.
No. CBP Form 7501 names one importer of record per entry, though the ultimate consignee (who the goods are delivered to) can be a different party from the importer of record.
Confirmed you’re the importer of record?
Once you know your status, the next step is finding out what you may actually be owed. Tariff Refund Agency offers a free eligibility check that takes about five minutes, with no commitment.
Start Your Free Eligibility Check
Affiliate disclosure: if you apply through this button, we may earn a commission from Tariff Refund Agency. Refund eligibility, amounts and timing depend on individual circumstances and are never guaranteed. Read our affiliate disclosure and disclaimer.
Sources and further reading
Educational only. Tariff Refunds Finder is not CBP, U.S. Customs or a government agency, and this guide is not legal, tax or financial advice. Importer of record status depends on the specific facts of your transactions. Confirm your status with your customs broker or a qualified professional before you act.
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