Who is the Importer of Record — and why E-Com Market Place never is

Executive Order 14411 tightened importer-of-record requirements in 2026. Understanding where the platform's responsibility ends is part of buying safely.

The Importer of Record is the party legally responsible for an imported shipment complying with US customs requirements: accurate entry information, correct HTS classification and valuation, duty payment, and five years of record retention.

Under the Customs Modernization Act the IOR must exercise "reasonable care" — a standard that applies from documentation through to post-entry audit. Signing a power of attorney with a customs broker does not transfer this. The broker files; the importer remains accountable.

On 3 June 2026 Executive Order 14411, "Strengthening Customs Enforcement", was signed, with deadlines at 45, 90 and 180 days. By late November 2026 it introduces importer-of-record asset and bond minimums, expanded disclosures, a "good standing" standard, registry cleanup and enhanced vetting. Non-resident importers face minimum tangible US asset requirements or specific bonds.

This is why E-Com Market Place does not act as Importer of Record and will not offer to. A platform acting as IOR across hundreds of buyers would be aggregating unlimited customs liability for products it did not manufacture and does not control — and under the 2026 rules, doing so has become considerably harder and riskier.

What E-Com Market Place does instead is make you a well-equipped IOR: a complete and validated document pack, advisory HTS classification for your broker to confirm, certificates of origin and compliance, a landed-cost model with the duty layers itemised, and a five-year document vault that satisfies the retention requirement.

If a platform offers to be your Importer of Record, ask what assets and bonds sit behind that offer, and what happens to your shipment if they withdraw it.