Who Is the Importer of Record on a Bill of Lading?

The importer of record on bill of lading is a common point of confusion, because the bill of lading does not actually have an importer of record field. A bill of lading (BoL) is a transport document issued by the carrier that names the shipper, the consignee, and the notify party. The legal importer of record is the entity that holds the Importer Exporter Code (IEC) and files the Bill of Entry on ICEGATE. The consignee named on the bill of lading is often, but not always, the same entity as the importer of record.

Getting this right matters because Indian Customs holds the importer of record, not the carrier or the consignee, responsible for duties, valuation, and compliance.

Who Is the Importer of Record on Bill of Lading Documents?

There is no line on a bill of lading that says importer of record. The BoL names three parties: the shipper (the exporter sending the goods), the consignee (the party the goods are consigned to at destination), and the notify party (who the carrier alerts on arrival). The importer of record on bill of lading is inferred from the consignee, but the legal importer of record is confirmed separately on the Bill of Entry, the customs declaration filed under Section 46 of the Customs Act, 1962. In India, that filing must carry the IEC and GSTIN of the importer of record.

Bill of Lading vs Bill of Entry: Where the IOR Actually Appears

This is the distinction most guides miss. The bill of lading is a carrier document proving the contract of carriage and receipt of goods. The Bill of Entry is the customs document that names the legal importer. The importer of record appears on the Bill of Entry, filed on ICEGATE, complete with the importer’s name, address, IEC, and GSTIN. So while the consignee on the bill of lading points to who will likely be the importer of record, the legally binding identity of the importer of record is fixed on the Bill of Entry, not the BoL.

Consignee vs Importer of Record on the Bill of Lading

To pin down the importer of record on bill of lading paperwork, separate two roles. The consignee on the bill of lading is the party the goods are delivered to. The importer of record is the party legally accountable to customs. They are the same entity in a straightforward import, where the Indian buyer receives the goods and clears them under its own IEC. They are different when:

• The goods ship on DDP (Delivered Duty Paid) terms, where the foreign seller is responsible for clearance and appoints a third-party importer of record
• The consignee is a warehouse, distributor, or fulfilment centre receiving goods for another party
• The buyer has no Indian entity or IEC and cannot act as the importer of record
• A third-party IOR is named to take on customs liability while goods are delivered elsewhere

Why the Importer of Record on the Bill of Lading Matters in India

Naming the correct importer of record on bill of lading and customs paperwork is not a formality. If the party set up as the importer of record cannot legally clear the goods, the shipment stalls at the port. A foreign entity listed as consignee on the bill of lading cannot file a Bill of Entry in India because it has no IEC. Similarly, if the goods need a product licence such as BIS or WPC that the named importer does not hold, customs will detain the consignment regardless of what the bill of lading says. Confirming the correct importer of record before the goods sail prevents demurrage, penalties, and clearance delays.

How JPARKS INDIA Helps

At JPARKS INDIA, we act as your importer of record in India so your goods clear customs smoothly no matter how the bill of lading is drawn up. We already hold the IEC, ICEGATE, and AD Code registrations, and we file the Bill of Entry, pay duty and IGST, obtain product licences, and deliver to your consignee. Having served 500+ importers and exporters, we make first-time and cross-border imports into India simple and fully compliant. Learn more about our Importer of Record services or book a free consultation.

Frequently Asked Questions

Q1. Is the consignee on the bill of lading the importer of record?

Not always. The consignee is the party the goods are consigned to on the bill of lading, while the importer of record is the entity legally responsible for customs clearance. They are the same in a simple import, but under DDP terms or third-party arrangements they differ.

Q2. Does the bill of lading show the importer of record?

No. The bill of lading names the shipper, consignee, and notify party, not an importer of record. The legal importer of record is confirmed on the Bill of Entry filed with Indian Customs on ICEGATE, which carries the importer’s IEC and GSTIN.

Q3. Who is the importer of record in India on the Bill of Entry?

In India, the importer of record on the Bill of Entry is the entity whose IEC and GSTIN are declared on the filing. This entity is legally accountable for duties, IGST, classification, and compliance under the Customs Act, 1962.

Q4. Can a foreign company be the importer of record on a bill of lading into India?

A foreign company can be named as consignee on the bill of lading, but it cannot act as the importer of record in India without an IEC. It must appoint a third-party IOR that holds the required registrations to file the Bill of Entry.

Q5. What happens if the wrong importer of record is used?

If the named importer of record cannot legally clear the goods or lacks a required product licence, Indian Customs will detain the shipment. This causes demurrage, penalties, and delays, which is why the correct importer of record should be confirmed before shipping.

Related guides

• Start here: What Is IOR in India? Importer of Record Explained (2026)
• What Is the Importer of Record Responsible For in India?
• How Does an Importer of Record Work in India? (2026)
• Does the Importer of Record Have to Own the Goods?
• Who Is the Importer of Record on an Invoice?

Prefer to hand this over? We provide importer of record support for importers across India.