How do I check if I am the IOR?

Pull CBP Form 7501 from ACE portal. Box 26 shows the Importer Number — an EIN or CBP-assigned importer ID. Match it against your EIN. That's your IOR determination.

Can I change IOR status on past entries?

No. IOR on a filed 7501 is final. Future entries can switch to your EIN if you file 7501 under your own Filer Code (or through your broker using your EIN).

What if my IOR was wrong on filed entries?

Contact the listed IOR and request an assignment of the refund claim. If they are cooperative, you can get the refund indirectly through contract. If not — no legal claim against CBP.

Can two parties share IOR status?

No. IOR is a single entity per entry. Joint ventures should designate one party in advance and handle refund split privately.

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● QUICK ANSWER

Am I the importer of record?

Tariff Refund Credits·Updated 2026-04-22·~2 min read

● Quick answer

The importer of record (IOR) is the entity legally responsible for making entry and paying duty under 19 USC 1484, listed on CBP Form 7501 Block 22 (Importer of Record Name and Number). To confirm, look at Block 22 of your 7501. If your company EIN appears there, you are the IOR for that entry. If another party (supplier, Amazon, 3PL, or DDP shipper) is listed, they are.

Why IOR status matters for refunds

Only the IOR can claim a tariff refund. CBP will not disburse refund funds to anyone other than the entity that paid the duty. If you purchased goods DDP (Delivered Duty Paid) and the seller was IOR, the seller holds the refund right, not you — even though economically you paid the duty through a higher purchase price.

This is the single most important eligibility question in a refund analysis. See who qualifies for a tariff refund for the full eligibility matrix.

How to confirm from the 7501

Pull any entry summary (7501). The form shows:

Block 22 — Importer of Record Name and Number (your EIN-based IOR number, typically 13 digits)
Block 14 — Importing Carrier
Block 15 — Country of Origin
Block 26 — Ultimate Consignee (the party receiving the goods)
Block 29 — Declared value
Block 34 — Total duty paid

The IOR (Block 22) and the Ultimate Consignee (Block 26) are often different. You can be the consignee without being the IOR.

Common IOR scenarios

Scenario 1: Direct importer — Your company buys FOB factory, arranges ocean freight, and acts as IOR. Block 22 is your EIN. You hold the refund right.

Scenario 2: DDP from overseas seller — The foreign supplier or their US agent acts as IOR. You receive the goods but never appear on the 7501 as importer. You do not hold the refund right; the DDP seller does.

Scenario 3: Amazon FBA with "Amazon Import Services" — In some setups Amazon acts as IOR for you. Check the entry paperwork. If your EIN isn't on Block 22, you are not the IOR. See Amazon FBA seller refunds.

Scenario 4: Section 321 de minimis — Low-value shipments under $800 entered de minimis do not generate a 7501 with a formal IOR in the same way. Refund pathway is different and typically not available for de minimis.

Scenario 5: Foreign principal with US-resident agent — Non-resident IORs can appear on Block 22 if they have a US bond and a resident agent for service of process.

IOR responsibilities under 19 USC 1484

Being IOR isn't just a refund right; it's a package of duties:

Accurate classification and valuation of merchandise
Timely entry filing (typically within 15 calendar days of arrival)
Duty payment
Recordkeeping for 5 years under 19 CFR 163
Response to CF-28 Requests for Information and CF-29 Notices of Action
Liability for penalties under 19 USC 1592 for errors

Changing IOR after entry

You generally cannot retroactively become the IOR of an entry someone else filed. The 7501 is a legal filing and the IOR designation is final. Going forward, if you want to claim refunds directly, switch to importing under your own EIN:

Obtain an EIN if not already (IRS Form SS-4)
File CBP Form 5106 to establish IOR record
Post a continuous bond (recommended for any regular importer)
Instruct suppliers to ship on terms where you are IOR (FOB, FCA, or DAP — not DDP)
Engage a licensed customs broker under 19 CFR 111

If your supplier is IOR and won't file

If you're a downstream buyer and the IOR supplier will not pursue the refund, your options are limited:

Negotiate a contract amendment requiring them to file and remit the refund to you
Renegotiate future terms to make you the IOR
Accept that past economic duty cannot be recovered by you directly

Many suppliers will pursue the refund and pass back part of it under existing contract language or because it strengthens the customer relationship. It does not happen automatically.

Non-resident importers

Foreign companies can be IOR under 19 CFR 141.36 provided they:

Hold a continuous customs bond
Designate a resident agent for service of process
Register with CBP via Form 5106

Non-resident IORs face additional scrutiny and bond conditions. For CAPE refund eligibility, non-resident IORs qualify on the same terms as US-resident IORs.

Calculate your tariff refund → /calculators/ieepa-refund

What's the difference between 3461 and 7501? See 3461 vs 7501.

Can my broker file my refund? Yes, with POA. See broker file.

What if I shipped DDP? The DDP seller is IOR and holds the refund right.

Not legal advice. Customs business performed by licensed customs broker partners under 19 CFR 111.

Not legal advice. Customs business performed by licensed customs broker partners under 19 CFR 111. Refund amounts are estimates only and subject to CBP adjudication.