When Is an Importer of Record Not Required?

Most shippers assume that every shipment crossing into another country needs a formal Importer of Record (IOR). That’s no longer a safe assumption, but it’s also not yet false. The exceptions are real. They’re just shrinking fast.

What Does an Importer of Record Actually Do?

An Importer of Record (IOR) is the party legally responsible for the customs entry: supplying correct registration details, valuing the goods accurately, and paying whatever duties and taxes fall due. Whenever a shipment is commercial in nature, that party must be a registered business: one with a tax or business number and, where required, an importer’s code. The consignee can still be an individual; however, the IOR cannot.

Quick Answer

Whether you need to be named as the Importer of Record depends on the destination country, the type of shipment and who makes the customs declaration. A low value shipment or the use of an indirect customs representative does not, by itself, mean no importer or declarant is required.

Strip away the paperwork and the rule is simple: customs only needs a named, legally responsible declarant when someone has to be liable for duties and taxes at the border. Where nobody owes anything at the border, there is no IOR requirement to satisfy.

There are two situations where that condition never arises.

1. Low-Value and De Minimis Shipments

Shipments under a country’s de minimis threshold have historically skipped the IOR requirement entirely, meaning no named declarant is needed, because no duty is owed. But that principle is coming to an end almost everywhere at once:

• United States: the $800 de minimis exemption was suspended almost entirely in August 2025.

• European Union: the €150 exemption ended in July 2026, replaced by a flat €3 duty per declaration line while full tariffs phase in through 2028.

• United Kingdom: the £135 exemption is now set to be phased out by October 2028, brought forward from the original March 2029 deadline.

As these thresholds fall away, more and more shipments that once cleared duty-free now need a properly named IOR.

2. Indirect Representation

The other route around a named IOR is indirect representation: a customs broker declares the goods in their own name, on your behalf, instead of you being named as the Importer of Record. It’s a genuine workaround, provided the destination country allows it.

Indirect representation is not allowed everywhere. Germany, China, India, Mexico, Brazil, Singapore, Spain and Italy all prohibit indirect representation on import. In each of these markets, you’re pushed into one of two positions: register as the named Importer of Record yourself through direct representation, or appoint a Fiscal Representative to act as the declarant on your behalf.

Japan is the standout exception. Indirect representation is permitted there with no Fiscal Representative required, making it a rare case where the workaround still holds up cleanly.

The Bottom Line

An Importer of Record isn’t universally required; however, both paths around it, de minimis relief and indirect representation, are narrowing. Low-value thresholds are being dismantled market by market, and the list of countries barring indirect representation keeps growing. Shippers relying on either exception today should treat it as temporary, not permanent.

If you’re expanding into a market where the importer, customs representative or tax obligations are unclear, GLOBAL GATEWAY by Shipping Solutions can help you work through the requirements before you ship. Our team brings together logistics, export documentation and compliance support, including guidance on VAT and tax documentation. Talk with us about your next shipment.

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