Importer of Record (IOR) Number: Who Qualifies and How to Apply

An Importer of Record (IOR) number is the identifier U.S. Customs and Border Protection uses to tie every commercial shipment entering the country to a single legally responsible party. For most U.S. businesses it is simply your IRS Employer Identification Number; sole proprietors and individuals can use their Social Security Number; foreign companies without a U.S. tax ID apply to CBP for a Customs Assigned Importer Number.¹ No IOR number, no customs clearance.

What the Number Is For

When goods arrive at a U.S. port, CBP needs to know who is on the hook for filing accurate entry documents, classifying the merchandise correctly, and paying the duties, taxes, and fees owed. The IOR number is how the agency connects those obligations to a specific person or company.²

That accountability sticks to you even when a customs broker handles the paperwork. A broker acts as your agent, not your replacement. If the entry contains errors or the wrong duty rate is applied, CBP looks to the importer of record, not the broker, for the money and the penalty.²

The number itself appears on virtually every piece of import documentation. On CBP Form 7501, the entry summary, it sits alongside the declared value, tariff classification, and duty amounts. CBP uses that data to assess what you owe, enforce trade requirements, and feed import statistics to the U.S. Census Bureau.³

Who Can Be the Importer of Record

Federal law defines the importer of record as the owner or purchaser of the merchandise, or a licensed customs broker designated by the owner, purchaser, or consignee. In everyday practice, this is usually the U.S. business that bought the goods from a foreign supplier. Whoever files entry must do so using “reasonable care,” the legal standard CBP applies when it later decides whether an importer met its obligations.⁴

A consignee who declares at the time of entry that they are the owner or purchaser can also serve as the importer of record, and CBP may accept that declaration without further verification.⁴

One boundary worth noting up front: licensed customs brokers are the only third parties U.S. tariff law authorizes to act as agents for importers in customs transactions. You cannot designate a freight forwarder, a shipper, or any other intermediary to stand in as IOR in place of a licensed broker.⁵

How to Get an IOR Number

What you do depends on whether you already have a U.S. tax identification number.

If You Are a U.S. Business or Individual

If your company has an IRS Employer Identification Number, that is your IOR number. CBP entry paperwork asks for it directly, and there is no separate application to file with CBP. Sole proprietors and individuals importing for personal use can use their Social Security Number in the same slot.¹

If You Are a Foreign Entity

Foreign companies without a U.S. tax ID need a Customs Assigned Importer Number, known as a CAIN. To get one, submit CBP Form 5106, the Create/Update Importer Identity Form, which collects the identifying information CBP needs for individuals and businesses involved in importing.⁶ The form can be submitted at a CBP port of entry.²

When a paper Form 5106 arrives with correct information, CBP typically processes and activates the new importer identity within two business days.⁷ That turnaround matters if a shipment is already in transit. Plan ahead rather than counting on same-day activation.

What Else You Need Before You Can Actually Import

The IOR number alone will not get your goods released. CBP also requires a customs bond, a financial guarantee that duties, taxes, and fees will be paid. If you fail to pay, CBP collects from the surety company that backs the bond.⁸

You will choose between two types:

A single entry bond covers one shipment. The bond amount is generally at least the total entered value of the goods plus any duties, taxes, and fees.⁹
A continuous bond covers all your imports for a 12-month period. The amount is set at 10% of the duties, taxes, and fees you paid over the prior 12 months, with a $100 minimum.⁹

If you import more than occasionally, a continuous bond almost always makes better financial sense. Single entry premiums add up fast. Most importers buy a continuous bond through a surety company or their customs broker.

Recordkeeping That Comes With Holding an IOR Number

Getting a number is quick. The obligation it triggers is not. As the importer of record you must keep all records related to your imports for five years from the date of entry. CBP reads “records” broadly: entry documents, invoices, correspondence, financial accounting data, and any electronically stored information tied to the transaction.¹⁰

A few exceptions shorten or shift the window:

Drawback claims: records must be kept until three years after the claim is paid.
Packing lists: 60 calendar days from the end of the release or conditional release period.
Informal entries filed by a non-owner consignee using a broker: two years from the date of the informal entry.
Duty-free articles under 19 USC 1321(a)(2): two years from the date of entry.¹⁰

Set up a filing system on day one. Five years is a long time, and reconstructing records after the fact is expensive.

What Happens If the Entry Is Wrong

Inaccurate entry information filed under your IOR number, whether a wrong classification, an understated value, or false IOR details, can trigger penalties under 19 U.S.C. § 1592. The size of the penalty depends on whether CBP treats the violation as negligent, grossly negligent, or fraudulent, and each tier scales up sharply from the last.

For negligence, the most common category, penalties run from 0.5 to 2 times the lost duties when there was a revenue loss, or 5% to 20% of the dutiable value when there was not. Gross negligence pushes those figures to 2.5 to 4 times the lost duties, or 25% to 40% of dutiable value. Fraud carries 5 to 8 times the lost duties, or 50% to 80% of dutiable value, and CBP can go higher for violations involving public health and safety.¹¹ In every tier, the penalty cannot exceed the domestic value of the merchandise.

These are administrative penalties, which CBP imposes directly without going to court first. The “reasonable care” standard from the entry statute is what the agency uses to judge whether you were negligent, so importers with documented compliance procedures, internal audits, and good-faith reliance on broker expertise start from a stronger position when a penalty is proposed.

A Sensible Order of Operations for a First Import

Confirm your IOR number first. For most U.S. businesses that means verifying your EIN is active with the IRS. Foreign entities should submit CBP Form 5106 well before the first shipment arrives, leaving at least a few business days for processing.⁷

Secure a customs bond before your goods ship. Without an active bond on file, CBP will not release your merchandise no matter how clean the paperwork is. Then decide whether to file entries yourself or hire a licensed customs broker. You are legally allowed to file on your own behalf, but many first-time importers find the procedures complicated enough that professional help pays for itself.²

1
U.S. Customs and Border Protection. Importer Numbers
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U.S. Customs and Border Protection. Tips for New Importers and Exporters
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Federal Register. Agency Information Collection Activities – Revision – Entry Summary (CBP Form 7501)
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Office of the Law Revision Counsel. 19 USC 1484 – Entry of Merchandise
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U.S. Customs and Border Protection. Importing into the United States – A Guide for Commercial Importers
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U.S. Customs and Border Protection. CBP Form 5106 – Create/Update Importer Identity Form
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U.S. Customs and Border Protection. Importer Create/Update Identity Form (CBP Form 5106) FAQ
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eCFR. Part 113 – CBP Bonds
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U.S. Customs and Border Protection. Bonds – How Are Continuous and Single Entry Bond Amounts Determined?
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eCFR. Part 163 – Recordkeeping
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eCFR. Appendix B to Part 171 – Guidelines for the Imposition and Mitigation of Penalties for Violations of 19 USC 1592