What Is an Importer of Record (IOR)? IEEPA Tariff Refund Edition

The importer of record (IOR) is the legal entity responsible for ensuring that imported goods comply with U.S. customs laws and for paying the associated duties. For IEEPA tariff refunds, the IOR designation is critical: only the importer of record — or an authorized agent filing on their behalf — can submit a CAPE refund claim.

How to Identify the Importer of Record

The importer of record appears in Box 26 of CBP Form 7501 (Entry Summary). Box 26 lists either:

• An EIN (Employer Identification Number) — for U.S. businesses importing under their company tax ID
• A CBP-assigned importer number — a number issued by CBP to importers who don’t have a U.S. EIN (common for foreign-owned entities)
• A Social Security Number — for individual importers (uncommon in commercial contexts)

If your company’s EIN appears in Box 26, your company is the IOR and holds the refund rights directly. If a different number appears — one belonging to your customs broker, freight forwarder, or logistics provider — that entity is the IOR of record, and the situation is more complex.

When a Customs Broker or 3PL Is Listed as IOR

It is common — particularly for smaller businesses and for air freight shipments — for a customs broker or third-party logistics provider to act as the nominal IOR. Brokers sometimes file as IOR to streamline the customs process, especially for clients without U.S. entities or for one-time shipments.

If your broker is listed as IOR, the broker holds the formal legal claim to any duty refund. Your options are:

1. Ask the broker to file on your behalf: Most brokers that act as IOR maintain a power of attorney or agency relationship with the beneficial importer. They can file the CAPE claim and pass the refund to you, either directly or as part of a coordinated arrangement.

2. Obtain an assignment of the refund right: A customs attorney can structure a legal assignment of the refund claim from the broker (IOR of record) to you (beneficial importer). This is sometimes preferred by businesses that want to maintain direct control of the refund process.

3. Engage a recovery partner with IOR coordination experience: Recovery firms often have established workflows for multi-IOR situations and can coordinate across brokers to consolidate the refund claim.

When Amazon or a 3PL Is the IOR

For e-commerce sellers using Amazon FBA, fulfilled-by-merchant with Amazon Logistics, or other 3PL warehouse services, it’s worth confirming whether Amazon or the 3PL was listed as IOR. Amazon has certain programs where it assumes IOR status. Contact Amazon’s customs compliance team or your freight forwarder for a copy of your Form 7501 entries to confirm.

IOR Number in ACE

Your IOR number is also associated with your ACE portal account. When you log into ACE, your account should be linked to your IOR number (or you can have your broker’s IOR number linked if you’re filing as their agent). This linkage is required to access the CAPE module.

Related Resources

• ACE Portal Setup Guide — Configure your ACE account for CAPE
• How the Refund Process Works — Full process overview
• DIY vs. Expert Help — When to handle IOR issues yourself vs. with a partner
• Check Your Eligibility