Almost every Chinese-language article about the Importer of Record is written for Amazon sellers: how to become a “foreign importer” yourself and get your goods into an FBA warehouse. A Taiwanese factory doing B2B export is in a completely different position. You are not selling small parcels one box at a time; you are shipping full containers of food, parts or equipment, where duties start at several thousand dollars and a single customs penalty can be several times the value of the cargo. At that point “who is the IOR” is not a process question — it is the question of whose company name goes on the customs documents.
What the IOR is responsible for to Customs
US Customs and Border Protection (CBP) requires every import shipment to have an Importer of Record, whose responsibilities are spelled out in black and white:
- Entry filing: submitting the correct description, HS classification, quantity, value and country of origin; for ocean freight, the ISF (10+2) data must be filed 24 hours before loading
- Paying duties and fees: including regular duties, anti-dumping duties, and the reciprocal tariff imposed on Taiwanese products since 2025
- Reasonable care: Customs holds the IOR responsible for confirming the declaration is correct — “the broker filled it in wrong” is not a defense
- Keeping records for five years: all import documents must be kept for five years from the date of import, and Customs can call for them at any time
- Bearing penalties: false declarations can be penalized at two to four times the value of the goods depending on severity, with criminal liability in serious cases
In other words, the IOR is the party Customs goes to for money, for documents and with penalty notices.
What the Customs Bond is
Commercial imports valued above US$2,500 (or goods regulated by another agency, such as FDA-regulated food) must be covered by a Customs Bond — a guarantee the IOR provides to Customs that duties and penalties can be paid. Two kinds:
| Type | Suited to | Cost concept |
|---|---|---|
| Single Entry Bond | Occasional imports | Calculated from cargo value and duties, purchased per shipment |
| Continuous Bond | Multiple imports per year | Common limit of US$50,000, annual fee of a few hundred dollars, covering all imports and ISF filings for the year |
The bond is in the IOR’s name, not the exporter’s. If a US company acts as IOR, its bond is used; if you act as a foreign IOR yourself, you have to buy your own — and Customs applies stricter bond and guarantee requirements to foreign importers.
The 15% reciprocal tariff: who pays and how it is calculated
Under the Taiwan–US trade agreement, most Taiwanese goods now carry a 15% reciprocal tariff on a non-stacking basis — items whose schedule rate is below 15% pay a combined 15%, while items already at or above 15% keep their original rate (the regime has changed twice in two years, so check the current CBP/USTR notice before shipping; see the tariff calculation guide for a full worked example). The IOR pays the duty to Customs; who ultimately absorbs it is a matter for you and the buyer under the trade terms (Incoterms):
- DDP (Delivered Duty Paid): the exporter is responsible door-to-door including duties; the IOR is usually a US agent appointed by the exporter, and the duty cost must be built into the quote
- FOB / CIF: the buyer acts as IOR and pays the duties; the exporter is responsible only to the port
In practice US buyers increasingly ask Taiwanese suppliers to quote DDP — that is, to find a US-side IOR who pays the duty. This is why “is there a US company willing to be your IOR” now directly determines whether you can take the order.
Act as a foreign IOR yourself, or appoint a US company
US Customs allows a non-resident (foreign) company to act as IOR, but the conditions keep tightening: a Customs-issued importer number, a designated agent in the US to accept legal documents, a bond underwritten by a US surety, and in recent years increasingly frequent requests for foreign IORs to provide additional documents and verify their identity. For a Taiwanese plant shipping a few containers a year, the administrative cost and risk of being your own foreign IOR usually exceeds that of appointing a US company.
Three options for a US-side IOR:
- The US buyer: the most direct, but many channels decline because it means carrying the duties and the FDA / FSVP responsibility
- A customs broker or trading company lending its name: some are willing, but they usually do not take food and do not handle FDA inspection
- A logistics company with US warehouses and customs capability: putting the IOR, consignee, FDA / USDA agent, inspection and delivery in one company
SKYCARGO INC is a US-registered company holding FDA and USDA agent status, and can act as your Importer of Record and consignee: we file the entry under our bond, handle duties according to your trade terms, deal with FDA / USDA / APHIS inspection, and move the released cargo into our Los Angeles or Oregon warehouse for delivery. You keep the product and the buyer; what you hand over is the responsibility and paperwork at the customs end.
Three questions to ask before appointing an IOR
- Are the trade terms DDP or FOB? Is it written into the quote who absorbs the duty?
- Does the other party hold a continuous bond, and have they handled FDA-regulated goods before?
- When Customs inspects, penalizes or orders re-export, who pays and who decides?
Answer those three, and only then put a company name on the customs documents. Tell us your cargo and trade terms and we will reply within one working day with the IOR arrangement and fee structure.
This article summarizes US CBP import rules and the relevant provisions of 19 CFR for reference only. Tariff rates and the scope of the reciprocal tariff change with policy — always check the latest CBP and USTR announcements.
