Importer of Record (IOR) Services in India

An Importer of Record (IOR) is the person or company named as the importer on the Bill of Entry. It holds the IEC the goods come in under, pays the customs duty and IGST, and answers to Customs for everything declared. If you sell into India without an Indian entity, JPARKS INDIA can be your Importer of Record: the goods are imported in our name, under our IEC, GSTIN and ICEGATE registration, and a licensed customs broker files the Bill of Entry.

Our IOR fee is from Rs 10,000 + GST, or 5% of the CIF value, whichever is higher, quoted per shipment. Customs duty and IGST are billed to you at actual cost. We have served 500+ clients, are rated 5.0 from 123 Google reviews, and come from a family that has worked in EXIM since 1990.

What an Importer of Record is in India

Indian customs law defines the importer, not the “importer of record”. Under Section 2(26) of the Customs Act, 1962, the importer of goods, until they are cleared for home consumption, includes any owner, beneficial owner or person holding himself out to be the importer. The party that presents the Bill of Entry (Section 46) and self-assesses the duty (Section 17) is what the trade calls the Importer of Record.

IOR is simply the short form of Importer of Record, in shipping and in customs. There is no separate “importer of record number” in India. The importer is identified by its Importer Exporter Code (IEC), a 10-character code that is the same as the entity’s PAN, and the Foreign Trade Policy says no import of goods may be made without an IEC unless specifically exempted.

The IOR is not always the consignee. The consignee is the party the goods are delivered to; the importer is the party named on the Bill of Entry and liable to Customs. Our guides explain what IOR means in India and importer of record vs consignee in detail.

Who needs an IOR in India

Anyone who has to get goods into India but has no Indian importer able or willing to stand on the Bill of Entry:

• Foreign sellers with no Indian entity. An IEC needs a PAN, a bank account in the applicant’s name and a valid address, a large step for a market you are still testing.
• Sellers on DDP terms. You agreed to deliver duty paid, so the import duty is yours, but you cannot present a Bill of Entry in India yourself.
• Project imports. Machinery, tools and spares for an Indian project site, before or without an Indian entity of your own.
• Samples. Bona fide technical and trade samples of restricted items need no DGFT authorisation, except defence and security items, seeds, bees and new drugs, but they still need an importer with an IEC.
• Demo and test equipment that is later sent back out.
• IT hardware for an Indian office or data centre (see “IOR for IT equipment” below).
• Indian businesses importing once in a while, who would rather not learn customs compliance on a live consignment.

If your Indian volumes grow, see foreign company registration in India and the two-routes table below.

Who does what in an IOR import

Four parties, each with its own job; Customs verifies the self-assessment, examines goods when selected and orders clearance.

What the IOR is legally responsible for

The obligations sit on the importer, so they sit on the IOR. Under the Customs Act, 1962 and the rules made under it, the importer must:

• present the Bill of Entry electronically on the customs automated system (Section 46(1)) and sign a declaration as to the truth of its contents, supported by the invoice (Section 46(4));
• ensure the accuracy and completeness of the information, the authenticity and validity of every supporting document, and compliance with any restriction or prohibition on the goods under the Customs Act or any other law (Section 46(4A));
• self-assess the duty (Section 17(1)), which Customs may verify, and pay it within the time Section 47(2) sets;
• hold the origin information if it claims a preferential duty rate under a trade agreement (Section 28DA);
• keep the assessed Bill of Entry and all supporting documents for 5 years from the date the Bill of Entry was presented, and produce them to Customs when asked (Bill of Entry Regulations, 2018, regulation 6), including in a customs audit under Section 99A.

The liability outlasts the delivery. Customs can demand short-paid duty within two years, or five years for collusion, wilful misstatement or suppression (Section 28), with interest (Section 28AA). Goods that do not match the Bill of Entry in value or any other particular are liable to confiscation (Section 111(m)), with penalties under Sections 112 and 114A. More on this in importer of record responsibilities and liability.

How an IOR shipment works, step by step

1. Product and policy check. HS code, ITC(HS) import policy (free, restricted or prohibited), new or second-hand, and the approvals that apply.
2. Quote and IOR agreement. Scope, fee, ownership structure and who bears what risk, signed before anything ships.
3. Approvals in place before dispatch, not at the port.
4. Shipping documents in the importer’s name. The bill of lading or air waybill and the commercial invoice cum packing list must match what will be declared.
5. Bill of Entry. A licensed customs broker files it on ICEGATE under the IOR’s IEC. It can go in up to 30 days before the expected arrival and is due before the end of the day before the vessel, aircraft or vehicle arrives (Section 46(3)).
6. Duty and IGST. The IOR pays them on the day the Bill of Entry is presented, for a self-assessed entry, or within one day (excluding holidays) after Customs returns it for payment on assessment (Section 47(2)).
7. Assessment and Out of Charge. Customs may verify the assessment and examine the goods, then orders clearance once the goods are not prohibited and the duty is paid, also electronically on risk evaluation (Section 47(1)). You can follow the stages with our bill of entry status guide.
8. Delivery, title and records. The goods go to your consignee, title passes as the agreement says, and the Bill of Entry and documents stay on file for five years, with copies to you.

Documents for an IOR import

For every shipment

The Foreign Trade Policy lists three mandatory documents for any import into India: the bill of lading, air waybill or other transport document; the commercial invoice cum packing list (separate invoice and packing list are accepted); and the Bill of Entry. Supporting documents are entered on the customs automated system with a digital signature.

When the goods or the deal need more

• Regulated goods: the approval, licence or registration the goods need (next section). The Policy lets the regulator concerned notify extra documents for goods under restrictions or product-specific compliance.
• Restricted goods: the DGFT authorisation.
• A trade-agreement duty rate: the certificate of origin and the origin information Section 28DA expects the importer to hold.
• A supplier related to the Indian buyer: valuation may need review; see SVB registration.

What we need from you for a first look

The goods with quantity, value and HS code if known; a data sheet, and whether they are new, used or refurbished; the supplier’s invoice and packing list; the Incoterm, origin and port of arrival; any approval the goods already have; the consignee’s address and whether the goods are sold or stay yours; and your company details for the agreement.

Approvals your goods may need before import

An IEC lets you import; it does not make every product importable. The Foreign Trade Policy (para 2.03) applies the domestic laws, rules, orders, technical specifications and safety and health norms that bind goods made in India to imports as well, unless specifically exempted. Section 46(4A)(c) then makes the importer responsible for compliance. The common ones:

The last column matters with an IOR: a manufacturer’s approval stays with your factory and must cover the exact models shipped, while an importer’s approval has to be in the IOR’s name. We arrange BIS certification, WPC approval and plastic EPR registration as separate services.

IOR for IT equipment

IT hardware is where IOR imports most often go wrong, for three reasons:

• BIS registration. If the product is notified under the Compulsory Registration Scheme, the exact model must carry its manufacturer’s BIS registration, just as it would if it were made in India.
• Second-hand status. Under Foreign Trade Policy para 2.31, second-hand desktop computers, refurbished PC and laptop spares, and second-hand electronics and IT goods notified under the Compulsory Registration Order need a DGFT authorisation; unregistered or non-compliant notified products are prohibited. Goods imported for repair are free if re-exported.
• Wireless parts. Equipment that transmits on radio frequencies also needs an Equipment Type Approval.

Customs duty and IGST: who pays and who claims the credit

Imports are treated as inter-State supplies, so imported goods attract IGST on top of basic customs duty, levied under the Customs Act read with the Customs Tariff Act, 1975 and collected with the duty on the Bill of Entry. It is charged on the assessable value plus the customs duty and any other duty charged on the goods. CBIC’s own worked example, scaled up:

Rates are illustrative; yours depend on the HS code. In an IOR import:

• Who pays: the importer pays duty and IGST on the Bill of Entry (Section 47(2)). As IOR we pay them, and bill them to you at actual cost.
• Who claims the IGST credit: “input tax” includes IGST on imported goods, and CBIC states the credit is available to the importer against tax on its outward supplies, taken on the Bill of Entry (CGST Rules, rule 36(1)(d)). So it sits with the IOR, not the foreign seller. Basic customs duty is never creditable.
• Your Indian customer: when the IOR buys and resells, it charges GST on its sale invoice, and a GST-registered buyer takes credit on that invoice in the normal way.
• Which State: the place of supply of imported goods is the importer’s location (Section 11, IGST Act).

Timelines and deadlines

The official time limits that shape every IOR shipment:

Our side has no fixed turnaround: it depends on the goods and their approvals, so the plan comes with the quote.

IOR fee and charges

Every IOR quote has two layers, and it helps to keep them apart:

• Government charges: basic customs duty, IGST and any cess, anti-dumping or safeguard duty on your HS code. These are the same whichever IOR you use, and we bill them at actual cost.
• The IOR service fee: what the Importer of Record charges for taking the liability and doing the compliance work. Ours is from Rs 10,000 + GST, or 5% of the CIF value, whichever is higher.

What changes a quote

• the goods: electronics, IT hardware, wireless devices, food and other regulated items need more checks;
• approvals to be arranged, such as BIS or WPC, which are separate services;
• the number of product lines to classify and document;
• freight, warehousing, local transport, packing and delivery, if you want us to arrange them.

How to compare IOR quotes

If one quote is far cheaper, the difference is almost never in the duty. Check whether duty and IGST pass through at actual cost, which approvals are covered, how the IGST credit is treated, whether delivery is included, and who files the Bill of Entry.

What an IOR cannot do

• Make prohibited goods importable, or bring restricted goods in without the DGFT authorisation.
• Hold approvals that belong to the manufacturer. A BIS registration under the Compulsory Registration Scheme is your factory’s, not the IOR’s.
• Pass the import IGST credit to a foreign seller. The credit is the importer’s, and only a GST-registered person can take it.
• Act as a customs broker without a licence. Section 146 bars anyone from carrying on business as a customs broker at a customs station without a licence. JPARKS INDIA does not hold one; a licensed customs broker files the Bill of Entry.
• Declare a lower value or a different HS code to cut duty. Customs can verify the self-assessment, and goods that do not match the entry are liable to confiscation.
• Take every customs risk off you. The definition of importer includes the owner and the beneficial owner, the person on whose behalf goods are imported or who controls them (Sections 2(26) and 2(3A)). A principal that controls the goods can still be treated as an importer.
• Leave goods at the port indefinitely. After 30 days uncleared they can be sold after notice (Section 48).

Your own importer or an IOR: two routes

To become your own importer:

1. get an IEC from the DGFT: we file IEC registration for Rs 2,860 all inclusive, within 24 hours of a complete document set;
2. register for GST, so the import IGST can be taken as credit;
3. appoint a licensed customs broker; you need your own ICEGATE registration only to file or track yourself (Rs 3,500 + GST, 2 to 3 working days), with a Class 3 DSC (Rs 3,700 + GST, 1 to 2 days);
4. put the product approvals in place before the first shipment.

Many clients start with an IOR and move to their own IEC once volumes justify it; we set up both.

What goes into an IOR agreement

The contract under which the IOR imports for you, in writing, signed by both sides and preferably reviewed by your lawyer. It covers:

• Scope: the goods and shipments, compliance work, duty payment, approvals and delivery.
• Fees and duties: the IOR fee, how duty and IGST are billed, and how the IGST credit is treated.
• Ownership: whether the IOR buys and resells, or imports on your behalf while you keep title (common for project or demo equipment), and when title passes.
• Liabilities: who bears a later duty demand, penalty, delay or loss. This clause matters most, because the importer answers to Customs for up to five years.
• Parties, governing law and dispute resolution.

Importer of Record vs Exporter of Record

Same job, opposite direction. The Importer of Record is named on the Bill of Entry for goods coming into India; the Exporter of Record is named on the shipping bill for goods leaving India.

Many foreign companies need both: equipment comes in through an IOR for a project or trial and goes back out when the work is done. If duty-paid goods are re-exported within two years, Section 74 allows drawback of part of the import duty. Our Exporter of Record services handle the export side the same way, in our name.

What JPARKS INDIA does as your Importer of Record

JPARKS INDIA is an EXIM compliance consultancy in Vashi, Navi Mumbai, with 500+ clients and a 5.0 rating from 123 Google reviews. We are not a customs broker: our sister concern S. K. Agency, a licensed customs broker, clears the cargo, while we stand on the Bill of Entry as the importer. As your IOR we:

• import the goods in our name, under our IEC, GSTIN and ICEGATE registration;
• check the HS code, import policy, approvals and documents before anything ships;
• pay the duty and IGST on the Bill of Entry and bill them at actual cost;
• hand the goods to your consignee, pass title as agreed and keep the records for five years;
• arrange freight, warehousing and delivery, if you want them.

Tell us what is shipping, from where and to where. Write to [email protected], call +91 91673 79073, or schedule a meeting.

Official references

• CBIC, Customs Act, 1962 (consolidated text): Sections 2(3A), 2(20), 2(26), 17, 28, 28DA, 46, 47, 48, 50, 74, 99A, 111(m), 146, 147
• Jawaharlal Nehru Custom House, Public Notice 85/2018, on the Bill of Entry (Electronic Integrated Declaration and Paperless Processing) Regulations, 2018 (Notification 36/2018-Customs (N.T.))
• CBIC, GST flier: Imports
• CBIC, CGST Rules, 2017, rule 36
• DGFT, Foreign Trade Policy 2023, Chapter 2: paras 2.03, 2.05, 2.06, 2.25, 2.31
• BIS, Products under compulsory certification and BIS (Conformity Assessment) Amendment Regulations, 2026
• Department of Telecommunications, Equipment Type Approval (ETA)
• Department of Consumer Affairs, Legal Metrology portal: registration of importers under Rule 27
• Guidelines on Extended Producer Responsibility for Plastic Packaging, February 2022 (gazette copy, Tamil Nadu Pollution Control Board)
• FSSAI, Food Safety and Standards (Import) Regulations, 2017, compendium version VII (6 November 2025), regulation 3

Related guides

• What Is IOR? Importer of Record Full Form and Meaning in India
• Importer of Record vs Consignee: Invoice, Buyer and Bill of Lading
• Importer of Record Responsibilities and Liability in India
• Importer Of Record Case Study