Importer of Record: Who Can File an IEEPA Tariff Refund Claim

What Is an Importer of Record?

The importer of record (IOR) is the party identified on CBP Form 7501 as responsible for ensuring that goods comply with all U.S. laws and regulations at the time of importation. The IOR is legally liable for the accuracy of the entry, the payment of duties, and compliance with any applicable laws, regulations, and import restrictions.

For IEEPA tariff refund purposes, the IOR designation is decisive: only the importer of record listed on the 7501 can file a CAPE claim for duties collected on that entry.

How the IOR Is Determined

On a standard commercial entry, the IOR is typically:

• The U.S.-based buyer purchasing goods from a foreign seller
• A customs broker filing on behalf of the buyer under a power of attorney
• The foreign seller if they have a U.S. presence and chose to bear the import duty burden (less common)

The IOR is identified on the 7501 by their IRS Employer Identification Number (EIN) or Social Security Number (for individuals). This is the definitive identifier for CAPE purposes — CBP will match CAPE claim submissions against the IOR EIN on the original 7501 forms.

Common IOR Scenarios

You Bought Goods on DDP Terms (Delivered Duty Paid)

If you purchased goods from a foreign supplier on DDP (Delivered Duty Paid) Incoterms, the supplier or their logistics agent arranged the import and paid the duties. In this scenario, the foreign party — or their U.S. agent — may be the IOR on the 7501, not you. Check your 7501 forms carefully. If someone else is listed as IOR, you are not the eligible claimant.

In some DDP arrangements, importers signed a power of attorney allowing their supplier’s freight forwarder to file entries under the importer’s EIN. In that case, the 7501 would show the U.S. buyer’s EIN and the U.S. buyer would be the IOR and eligible claimant.

You Used a Customs Broker

Most importers work with licensed customs brokers, who file entry summaries on the importer’s behalf. The broker files under the importer’s EIN (or the broker’s EIN if they hold the goods on their own account, which is rare). The importer is the IOR; the broker is their agent. The importer is eligible to file CAPE claims, and can also authorize the same broker to file CAPE claims on their behalf.

You Are an Amazon FBA Seller

Amazon FBA sellers are a special case. When you ship goods into Amazon’s fulfillment centers, you are typically the IOR on the import entries — you used your own EIN (or the EIN of your LLC) and directed a freight forwarder to file entries on your behalf. You are the eligible claimant. If Amazon arranged and paid for your imports as part of a program where Amazon is the IOR, Amazon would be the claimant, not you.

Review your shipping documents and CBP 7501s to confirm your IOR status for each shipment.

Confirming Your IOR Status

To confirm that you are the IOR on a given set of entries:

1. Obtain copies of all CBP Form 7501s from your customs broker or directly from ACE
2. Locate the “Importer of Record Number” field (Box 23 on the standard 7501 format)
3. Confirm it matches your EIN or SSN
4. Note that the IOR number on the 7501 is the party eligible to file CAPE claims for those entries

If the IOR number on your 7501s belongs to your customs broker’s EIN rather than yours, contact your broker immediately. This may indicate an error in how your entries were filed, or it may reflect a legitimate arrangement where the broker took title to the goods.

When Your Customs Broker Can File for You

Even if you are the IOR, your customs broker can file CAPE claims on your behalf provided:

1. The broker holds a valid CBP Form 5291 Power of Attorney from your company
2. The POA covers post-entry and drawback-type filings (not just entry filing)
3. The broker’s ACE credentials are active and linked to your IOR number

Many customs brokers are actively offering CAPE filing services. If you plan to use your existing broker, confirm that their POA from you is current and covers the scope of CAPE filings.

IOR Changes and Successor Companies

If your company has undergone name changes, mergers, acquisitions, or EIN changes since 2025, this can complicate CAPE filing. CBP ties entries to the EIN on file at the time of entry. If your company’s EIN has changed, work with a customs attorney to document the corporate succession and ensure CAPE claims are filed under the correct identifier.