Does the importer of record have to own the goods?

No, the Importer of Record (IOR) does not have to own the goods. Ownership and legal responsibility for import compliance are two separate things. The IOR is the entity or individual who takes responsibility for ensuring that goods are imported in accordance with all applicable laws and regulations of the destination country, including customs documentation, payment of duties and taxes, and obtaining required licenses or permits.

While the IOR is often the owner or purchaser of the goods, this is not mandatory. In many cases, especially in international logistics, the IOR may be a third-party service provider, customs broker, or freight forwarder who assumes the legal liability for the import process on behalf of another party.

This distinction is especially important in situations where the actual buyer or consignee does not have a legal presence in the importing country and therefore cannot act as the IOR. In such cases, companies may engage a local entity to act as the IOR, even though that entity does not own or take possession of the goods.

In summary, the IOR must ensure compliance with import regulations, but they do not need to hold title or ownership of the goods. The key requirement is that the IOR has the authority and legal capacity to manage and be accountable for the import.