Is Importer of Record the buyer?

The Importer of Record (IOR) is not always the buyer of the goods. While the buyer can act as the IOR, especially in standard B2B transactions, it ultimately depends on the shipping arrangement and who takes responsibility for customs compliance.

The IOR is the legal entity responsible for ensuring that goods are imported in accordance with the destination country’s laws, which includes filing customs documents, paying duties and taxes, and securing permits. If the buyer is equipped and willing to handle these obligations, they typically act as the IOR.

However, in many cases, the buyer may not wish to take on this responsibility. Instead, the seller, a customs broker, or a third-party IOR service provider may be designated as the IOR—especially when the buyer lacks a legal presence in the importing country or prefers to avoid the administrative burden of import compliance.

Under shipping terms like DDP (Delivered Duty Paid), the seller often acts as the IOR. Conversely, under EXW (Ex Works) or FOB (Free on Board) terms, the buyer usually assumes the IOR role.

In summary, while the buyer can be the IOR, it is not mandatory. The IOR is determined by who agrees to take on the legal responsibility for clearing goods through customs and ensuring regulatory compliance.