Your Importer Of Record Is About To Become Your Biggest Liability

BusinessRetailYour Importer Of Record Is About To Become Your Biggest LiabilityByIzzy Rosenzweig,Contributor.Forbes contributors publish independent expert analyses and insights. Izzy Rosenzweig, CEO of Portless, covers e-commerce supply chains.Follow AuthorJun 15, 2026, 01:43pm EDTSummaryA new executive order signed June 3 significantly changes U.S. customs enforcement, shifting focus from *what* is imported to *who* is importing. Previously, foreign entities often used informal entry or shell U.S. companies as Importers of Record (IORs), hindering accountability. The order now bars foreign IORs from informal entry, mandating formal entry (Type 01) which requires a bond with CBP. This aims to prevent foreign sellers from evading declaration responsibility. Agencies have 180 days to implement these rules. Brands must verify their IOR's legitimacy; if it's a foreign entity or shell company, they should transition to a legitimate U.S. IOR or licensed customs broker to ensure compliance and avoid future disruptions. This signals the end of non-compliant importing practices.Show More Cargo plane flying above a stack of containers at a portiStock — PhonlamaiPhotoAsk most founders who their importer of record is and they can't tell you. I've had this conversation dozens of times. They know their factory, their freight forwarder and their landed cost to the dollar. But ask who takes legal responsibility for those goods at the U.S. border and they draw a blank. For years that didn't matter. Now an executive order signed on June 3 is about to change that.Most of the cross-border conversation this past year has been about IEEPA tariffs and the end of de minimis, the rule that let shipments under $800 enter the U.S. duty-free. CBP processed more than 1.36 billion de minimis shipments in fiscal 2024 (over four million parcels a day) before the duty-free treatment was suspended on orders from China in May 2025, then for all countries that August. This ex...