If you are the Importer of Record (IOR), your company must have a knowledgeable individual on staff who understands the requirements of the U.S. government agencies that regulate your products.
Too often, importers rely on their customs broker to identify compliance requirements—sometimes only after a shipment has already arrived in the United States. Documents are forwarded to the broker, only to discover that the goods are subject to restrictions, permits, labeling requirements, or other regulatory controls. The response is often, “Why hasn’t this been an issue before?” or the familiar refrain, “My previous broker never had a problem with this.”
The reality is that today’s import environment demands a different approach. Customs brokers play a critical role, but they cannot replace the importer’s responsibility to understand and comply with applicable laws and regulations. Compliance begins with the Importer of Record.
Importers should ensure that:
- Someone within their organization is responsible for import and export compliance.
- Commercial invoices and supporting documentation provided to forwarders and brokers are complete, accurate, and compliant.
- Internal staff understand the regulatory requirements that apply to their products and supply chains.
- Compliance personnel participate in ongoing education through seminars, webinars, training programs, import/export boot camps, and industry conferences.
- Their teams engage with trade associations and pursue professional credentials such as Certified Customs Specialist (CCS) and Certified Export Specialist (CES).
We are operating in an era of heightened enforcement by U.S. Customs and other government agencies. During an audit, “My broker handles that for me” is not an acceptable answer. Regulators expect the Importer of Record to understand its obligations and to identify the individual within the organization who is responsible for compliance oversight.
The companies that invest in compliance knowledge today will be better positioned to avoid delays, penalties, audits, and supply chain disruptions tomorrow.
Compliance is not something that can be outsourced entirely—it remains the responsibility of the Importer of Record.
Regards, Carl
