The importer of record is the name customs holds responsible when something is wrong with an entry, even when a broker filed it and a supplier caused it. This guide sets out those responsibilities in plain language, where delegation helps and where it does not, and the records an importer must be able to produce.
When customs finds an error, the first door it knocks on belongs to the importer of record. That includes undervalued goods, wrong classifications, missing licences, and products that should never have been admitted. Penalties, back duty, and seizure are addressed to the importer, who may then have a separate argument with a supplier or broker about who caused the problem.
This surprises businesses that buy on delivered terms and assume the seller handled importing. Sometimes the seller genuinely is the importer, through a local entity. Sometimes the buyers details have been used as importer by arrangement, or worse, without clear understanding. Every importer should know, in writing, for each route, whose name and tax or customs identifier appears on entries.
A good broker is an expert agent: they classify with your information, file accurately, and flag problems. Their work depends on what you give them. If product information is vague or values come from a supplier invoice that excludes assists or fees that should be declared, the entry can be wrong despite competent filing. Reviewing a sample of entries against source documents is the importers job.
Put the relationship in writing: who decides classifications, what product data you supply, how changes are communicated, and how errors are corrected. Voluntary corrections, made promptly when an error is found, are treated very differently from the same error found by an audit. A broker who welcomes entry reviews is a good sign. A broker who resists them is not.
Importers must keep entry and supporting records for a set period, often five years, and be able to produce them on demand. That includes invoices, packing lists, classification reasoning, origin evidence, licences, and correspondence about value. Records held only by a broker who you later leave, or a supplier who goes out of business, are records you effectively do not have.
Keep your own copies in a structure organised by entry or shipment, not by inbox. Test retrieval once a year: pick an old entry and ask your team to produce the full pack within a day. The gaps that exercise reveals, missing supplier declarations, unsigned documents, unclear valuation notes, are exactly the gaps an audit would find, with less friendly timing.
Your customs and tax identifiers are valuable and abusable. Unauthorised parties have used real importers details to bring in goods the named importer knows nothing about, leaving them with enquiries and liabilities. Limit who is authorised to act under your importer of record, instruct your broker in writing who may give them instructions for your account, and check entry summaries for shipments you do not recognise.
When staff leave or suppliers change, update authorisations. A power of attorney or broker instruction from a relationship that ended years ago is a loose thread. Treat importer identity like bank access: reviewed regularly, granted narrowly, and withdrawn promptly. It is unglamorous work that prevents the worst customs surprise of all, a shipment that is yours on paper and nothing to do with you in fact.
Keep reading: Customs exam holds: why containers get flagged and what importers can do while they wait, Entry summary filing mistakes: the small errors that turn a clean import into a customs bill, and Bonded warehouses explained: delaying duty without breaking the rules cover the nearby cases in this series.
No. A broker acts as your agent and files entries on your behalf, but legal responsibility for classification, value, origin, and admissibility stays with the importer of record named on the entry.
Entry documents and the evidence behind them: invoices, packing lists, classification and valuation reasoning, origin evidence, licences, and relevant correspondence, usually for around five years depending on the market.
It depends on whose entity and customs identifier are used for the entry. Do not assume. Confirm in writing for each route who is importer of record, because that party carries the liability.
Authorise users narrowly and in writing, tell your broker who may instruct them for your account, review entry summaries for unknown shipments, and withdraw authorisations when relationships end.