Importer of Record: A guide to responsibilities & services for the EU and UK

This guide explains what an Importer of Record (IOR) is, when you need one, what the IOR must do, and how it works for EU and UK imports. It also covers how the IOR compares to the consignee, Exporter of Record (EOR) and customs broker, plus practical steps for compliant imports.

Table of contents

What is an Importer of Record?
Do I need an IOR?
What must the IOR do?
IOR vs consignee vs EOR vs customs broker
IOR for different scenarios
Common mistakes to avoid
How to act as the IOR (5 steps)
Enforcement & penalties if you don’t have a compliant IOR
Selecting a value-added IOR
Conclusion
Frequently asked questions
Q&A section
Ask Your Question now Cancel reply

What is an Importer of Record?

The Importer of Record (IOR) is the legal entity or individual responsible for ensuring that goods entering a country comply with all applicable customs laws and regulations. The IOR is named on customs declarations, pays import duties and taxes (including VAT), and assumes legal liability for the accuracy of the import process. In the EU and UK, the IOR must be established in the destination market or use a third-party IOR service provider with local presence.

Do I need an IOR?

You generally need an IOR whenever goods are imported into the EU or UK and you (the seller) aren’t established locally to act in your own name. Common cases include:

Non-EU/UK sellers shipping directly to EU/UK buyers.
DDP (Delivered Duty Paid) promises, where the seller is responsible for duty/VAT.
Amazon FBA / e-commerce models where stock is imported into EU/UK fulfillment centers.

Returns/RMA flows that re-enter customs territory.
Temporary imports (trade shows, demos) where an accountable importer must file and keep records.

If you’re unsure whether you need an IOR for your specific setup, contact us and we’ll explain what applies in your case:

What must the IOR do?

Obtain/hold a valid EORI (EU or UK) and set up VAT arrangements where needed.
Classify goods (HS tariff), determine customs value and origin.
File customs declarations (directly or via a broker/forwarder) and keep statutory records and statements.
Pay or account for duty & VAT (e.g., Postponed VAT Accounting in UK where applicable).
Ensure product-compliance evidence is available on request (e.g., DoC/UK DoC, labels, technical documentation)

Keep a complete audit trail linking commercial records (like invoices) to customs declarations.
Secure any licences/permits (dual-use, SPS, chemicals, batteries, etc.) when required.
Adjust the declared price to reflect the correct customs value.
Include in the declared price any royalties related to intangible property rights, like patents, trademarks, and copyrights.
Respond to customs/market-surveillance queries and maintain audit-ready documentation.

IOR vs consignee vs EOR vs customs broker

Role	Responsibility
Importer of Record (IOR)	Legal entity responsible for import; named on customs declarations; pays duties/taxes; liable for compliance
Consignee	Party receiving physical goods; not responsible for customs unless also acting as IOR
Exporter of Record (EOR)	Responsible party in origin country; handles export customs
Customs Broker	Service provider facilitating customs clearance; acts on behalf of IOR; does NOT assume legal liability

Key distinction: The IOR is always legally responsible, even when using a customs broker.
IOR vs Exporter of Record (EOR): Every international shipment requires both. The EOR handles export from the origin country, while the IOR handles import into the destination country, they are typically different entities.

IOR for different scenarios

IOR for Amazon FBA & e-commerce

Stocking in EU/UK fulfillment centres typically requires an IOR to clear goods on arrival. Expect checks on product compliance (e.g., DoC/labels), EORI/VAT, and the accuracy of customs values. Marketplaces may request proof of your IOR arrangements.

IOR for DDP shipments

If you sell DDP, you’re promising to handle duty/VAT and the import formalities. That usually means acting as (or appointing) the IOR. Clarify in contracts who is IOR, how VAT will be accounted for, and who keeps the import records.

IOR for EU imports

Use an EU EORI and import via a chosen Member State. Ensure any required product compliance documents (e.g., CE/DoC, labels) are in order; some goods also need licences. VAT registration or arrangements depend on your business model and Member State rules.

IOR for UK imports

Use a GB EORI. Consider Postponed VAT Accounting (PVA) to manage cash flow on import VAT. For product compliance, understand when UKCA vs CE applies and ensure labels/DoC align with current UK rules.

Common mistakes to avoid

Assuming a broker is your IOR by default (they aren’t, unless explicitly appointed).
Using the wrong HS code or customs value, leading to reassessments and fines.
Importing without the correct EORI/VAT setup.
Promising DDP without defining who is IOR and how VAT/duty will be handled.
Missing or outdated product-compliance documents (DoC/labels/technical file).
Poor record-keeping that fails an audit.

How to act as the IOR (5 steps)

1
Identify the entity that will be the IOR.
2
Obtain the required EORI (EU or GB) and VAT registration/arrangements.
3
Appoint a customs broker/forwarder and provide a POA if needed.
4
Prepare documents: commercial invoice, packing list, HS codes, origin statements, licences/permits, and product-compliance docs (DoC/labels).
5
File entries, pay/account for duty & VAT, and retain records for the statutory period.

Enforcement & penalties if you don’t have a compliant IOR

Customs holds and inspections leading to delays and storage/demurrage costs.
Administrative fines and post-clearance reassessments of duty/VAT.
Seizure, re-export, or destruction of non-compliant goods in serious cases.
Civil penalties for regulatory non-compliance in the UK typically range between £1,000 and £2,500.

Acts of fraud, such as deliberate misclassification or undervaluation, constitute serious infringements and may lead to criminal proceedings.
Supply-chain disruption (brokers/refused entries) and marketplace account issues.
Follow-up audits requiring full documentation and proof of declarations.

Selecting a value-added IOR

Remember, most shipping delays at borders are not due to lorry breakdowns.
The real culprits are almost always compliance failures and incorrect documentation.

An IoR with deep regulatory expertise will smooth customs clearance.
They operate on the principle that paperwork is the final step in a much deeper compliance process.

Your goal should be to find a partner whose core strength is not merely logistics but legal and technical compliance.

They must be equipped to provide these value-added services:

Product compliance & CE/UKCA marking support: They ensure your products meet all essential health, safety, and environmental requirements long before they approach the border, preventing the most common reasons for delays.
Technical documentation & user manual creation: They prepare legally sound, easy-to-follow user-friendly instructions that customs authorities or market surveillance agencies can demand to see.
Fiscal representation: For companies based outside the EU, they can arrange VAT compliance, a critical element of the General Product Safety Regulation (GPSR) for EU/UK sellers.
Legal consultancy: They offer expert advice on the specific national interpretations of EU or UK regulations, helping you steer through the subtle legal variances that can stop a shipment.
Expert customs brokerage: They specialise in the precise classification and valuation of goods, backed by knowledge of the unique inspection demands of each country’s customs authority.
End-to-end compliance management: They act as your single point of contact for the entire product compliance journey, from testing and certification to managing your authorised representative services and IOR duties.

Conclusion

Importing into the EU or UK requires a designated Importer of Record with proper EORI and VAT credentials, compliant documentation, and robust record-keeping. Whether you act as IOR yourself or appoint a service provider, ensure the legal responsibilities are clearly assigned and properly managed. If you havy any questions, please feel free to reach out to us:

Author Ferry Vermeulen is the Co-Founder of 24hour-AR, a company dedicated to providing authorised representative services as well as CE marking services. With a background in industrial design engineering, Ferry specialises in facilitating swift compliance with EU regulations, enabling manufacturers to enter markets seamlessly.

Frequently asked questions

What happens if I don’t have an Importer of Record?2025-11-25T15:26:52+00:00

What happens if I don’t have an Importer of Record?

Goods cannot clear customs without a designated IOR. Your shipments will be held at the border, accumulating storage and demurrage fees. You risk forced re-export, destruction of goods, fines, and penalties.

How much do Importer of Record services cost?2025-11-21T16:14:41+00:00

How much do Importer of Record services cost?

Third-party IOR services typically charge setup fees (€200-500), per-shipment fees (€50-150), and VAT registration fees if needed. Some charge based on shipment value. The cost is usually far less than establishing your own legal entity in the destination country.

Can a freight forwarder be the Importer of Record?2025-11-21T16:10:45+00:00

Can a freight forwarder be the Importer of Record?

Yes, if the freight forwarder has the necessary registration (EORI and potentially VAT) and agrees to assume IOR responsibility. However, many freight forwarders prefer to act only as logistics providers and customs brokers rather than taking on IOR liability.

Do I need an Importer of Record for Amazon FBA?2025-11-25T15:19:43+00:00

Do I need an Importer of Record for Amazon FBA?

Yes. All shipments to Amazon fulfillment centres in the EU or UK require proper IOR designation and customs clearance. Amazon will refuse shipments without compliant IOR setup. Most non-EU/UK sellers use third-party IOR services.

What’s the difference between Importer of Record and consignee?2025-11-21T16:09:44+00:00

What’s the difference between Importer of Record and consignee?

The IOR is legally responsible for customs compliance and pays duties/taxes. The consignee is simply the party receiving the physical goods. They’re often different entities—particularly in DDP shipments where the seller acts as IOR but ships to the buyer (consignee).

Do I need an EORI number to be an Importer of Record?2025-11-21T16:05:57+00:00

Do I need an EORI number to be an Importer of Record?

Yes. Every IOR in the EU or UK must have an EORI (Economic Operators Registration and Identification) number. For EU, register with customs in any member state. For UK, register with HMRC. Registration is free and typically takes 3-5 business days.

Does the Importer of Record pay VAT and duties?2025-11-21T16:01:30+00:00

Does the Importer of Record pay VAT and duties?

Yes. The IOR is responsible for paying all import duties and VAT at customs. If the IOR is VAT-registered, they can typically reclaim the import VAT through their VAT returns.

Who can act as the Importer of Record?2025-11-21T16:01:44+00:00

Who can act as the Importer of Record?

The IOR must be established in the destination country. This can be your own company (if you have local presence), a third-party IOR service provider, the buyer, a distributor, or a logistics partner. The IOR must have an EORI number and may need VAT registration.

Q&A section

Any unanswered questions? Let us know below and we will get back to you: