Customs authorities need a clearly identified party who can be held accountable for every shipment. The Importer of Record fulfills this role, ensuring that there is a single responsible entity for accurate declarations and compliance with Canadian import rules.
Every shipment entering Canada must have an Importer of Record (IOR).
This designation represents the party legally responsible for ensuring goods meet all Canadian customs requirements.
For many businesses new to importing, the scope of this responsibility isn’t always clear.
Understanding who can serve as the IOR, what obligations come with the role, and what risks are associated with it is essential for smooth and compliant importing.
In this article, we outline the key responsibilities, liabilities, and best practices that every importer should know.
According to the Canada Border Services Agency (CBSA), the Importer of Record (IOR) is “the person identified as the importer on the customs declaration when goods are accounted for.”
In other words, it is the party whose name and number appear on CBSA’s accounting documents.
The IOR is not the only role in the process.
The CBSA also defines an importer as the person who brings goods, or causes goods to be brought, into Canada, and an owner as the person who owns the goods at the time they are released by the CBSA.
Together, the importer, the owner, and the Importer of Record are jointly and severally liable for duties and taxes, including any reassessments, as well as for maintaining accurate declarations and records.
However, in the case of shipment reviews or audits, the CBSA generally looks to the Importer of Record.
Not every party involved in moving goods can serve as the Importer of Record.
Under CBSA policy, the IOR is the party identified as the importer on the customs declaration.
For commercial imports into Canada, the Importer of Record generally falls into one of three categories:
The Importer of Record is most often a Canadian-resident company with a Business Number and import/export account registered to transact with CBSA.
This company is responsible for declaring goods, paying duties and taxes, and ensuring compliance with customs requirements.
An NRI is a business located outside Canada that registers to act as the Importer of Record for its shipments into Canada.
To qualify, the company must obtain a Business Number and register for an import/export account, and then use these to transact with the CBSA through the CARM Client Portal (CCP).
Once registered, an NRI carries the same obligations as a Canadian importer.
In some cases, a customs broker or another authorized agent may be designated as the Importer of Record, but only when acting under the direction of the importer or owner of the goods.
When an agent is listed as the IOR, it assumes the same legal responsibilities as any importer, including duty liability and compliance with CBSA requirements.
While carriers and freight forwarders support the logistics process, they cannot act as the Importer of Record in their transport role.
They may only do so if they are licensed and specifically authorized to account for goods on behalf of the importer.
An IOR's key responsibilities include:
These obligations remain with the Importer of Record even if a customs broker files declarations on their behalf.
They also apply equally to Canadian resident importers and non-resident importers.
The most common risks IORs could face include:
To manage responsibilities effectively and reduce risks, importers of record are advised to:
At Cole International, we provide trade consulting and customs brokerage services to help Canadian businesses understand their IOR responsibilities and comply with CBSA requirements.
Our team works with importers every day to:
We don’t believe in guesswork. We get it right the first time.
If you act as the Importer of Record in Canada, reach out to one of our trade professionals to make sure your responsibilities are met and that your imports move through customs without delays.