Importer of Record for Goods From Thailand to the USA: When You Need One, the Customs Bond and What Duty Inclusive Covers

What is an importer of record, and who can be one?

The importer of record must file the entry and answer to CBP for duty, value and classification. The importer of record can be either the owner or purchaser of the goods or a licensed customs broker designated by the owner, purchaser or consignee.

the required documentation or information shall be filed or electronically transmitted either by the owner or purchaser of the merchandise or, when appropriately designated by the owner, purchaser, or consignee of the merchandise, a person holding a valid license under section 1641 of this title.

Source: 19 U.S.C. 1484(a)(2)(B), Entry of merchandise, U.S. Code, Government Publishing Office.

CBP reads "owner" and "purchaser" very broadly. Customs Directive 3530-002A of 27 June 2001 says the terms "include any party with a financial interest in a transaction". A Thai seller that still owns the goods at the border has such an interest. The directive excludes the nominal consignee.

The terms “owner” or “purchaser” would not include a “nominal consignee” who effectively possesses no other right, title, or interest in the goods except as he possessed under a bill of lading, air waybill, or other shipping document.

Source: Customs Directive 3530-002A, Right to Make Entry, U.S. Customs and Border Protection.

The directive names "express consignment operators (ECO)" among the nominal consignees that cannot file. A broker that files for one "must appear as importer of record".

The importer of record is responsible for the duties. The duty "constitutes a personal debt due from the importer to the United States" under 19 CFR 141.1. Payment to a broker "does not relieve the importer of liability if the duties are not paid by the broker".

CBP also says it can only refund IEEPA duties to the Importer of Record or the Notify Party (designated on CBP Form 4811). The role decides who gets money back. The guide to US import duties on goods from Thailand has the rates.

Who is the importer of record in common setups from Thailand?

The importer of record is determined by ownership and filing, not the delivery address. For US buyers importing their own orders the buyer is the importer of record. For Thai sellers sending duty paid they can be listed as the importer of record as a non-resident importer. A courier or forwarder named only as consignee cannot file and needs a licensed broker.

Sources: 19 U.S.C. 1484; 19 CFR 141.17 and 141.18, eCFR; Customs Directive 3530-002A, CBP; Delivering imports to Amazon, Amazon Seller Central.

Amazon, including our fulfillment centers, will not act as an IOR for any shipment of FBA inventory.

Source: Delivering imports to Amazon, Amazon Seller Central.

For a seller that wants the role, Amazon says "To become a nonresident IOR, contact your customs broker or carrier for details." The guide to sending inventory to Amazon FBA from Thailand covers the carton rules.

How does a Thai seller get an importer of record number?

Thai sellers file CBP Form 5106, themselves or through a customs broker. The number is the seller's IRS Employer Identification Number if one exists. If a foreign business has no IRS or Social Security number, CBP assigns a number. Having a US Tax ID is not a requirement.

The form's instructions say a CBP-assigned number "will be issued to foreign businesses or individuals, provided no IRS employer identification number or SSN exists for the requester". An existing employer identification number "will automatically become your importer identification number". 19 CFR 24.5 requires the form with the first formal entry. The guide to the customs declaration and commercial invoice shows the invoice fields that go with it.

CBP now checks the data.

if CBP determines that an IOR or customs broker acting on behalf of an IOR has failed to provide complete and accurate information, CBP will void the IOR number, rendering it invalid for any purpose, including entering imported merchandise into the United States.

Source: Accuracy of Importer of Record Data Submitted to CBP, 91 FR 53627, U.S. Customs and Border Protection, Federal Register, 19 August 2026.

Do you need a customs bond to import from Thailand?

There is no bond required for informal entry (US$2,500 or less). CBP may ask for a bond even though it is not required. For formal entry there is a requirement for a single entry or continuous bond.

19 CFR 142.4(a) bars the release of formal-entry goods "unless a single entry or continuous bond on Customs Form 301" has been filed. The informal limit sits in 19 CFR 143.21(a): "Shipments of merchandise not exceeding $2,500 in value".

The same paragraph excepts articles above US$250 classified in Chapter 99, Subchapters III and IV, which is where the Thailand tariff heading 9903.05.77 sits. CBP suspended that exception "until further notice" on 2 September 2025 and now proposes to delete it. A broker confirms the entry route for a Thai shipment above US$250.

CBP may require a basic importation and entry bond (19 CFR 113.62) for informal entries valued at $2,500 or less. The proposal of 8 October 2026 would require one on every entry type 11 and 13, the informal entry types. Comments close on 7 December 2026.

Sources: A Guide for the Public: How CBP Sets Bond Amounts, CBP, February 2024; 19 CFR 113.13(a), eCFR; Low-Value Shipments, CBP, Federal Register, 8 October 2026.

On CBP's averages a $15,000 bond costs $73.76 (15 x 4.917), a $5,000 bond costs $54.17 (minimum), nine minimum single bonds cost $487.50 (above the $441.52 average for a continuous bond), a repeat importer is better off with a continuous bond from about the ninth entry in a year. Real quotes vary by broker and surety.

A Thai seller filing as its own importer needs "a resident corporate surety" on the bond. A corporation also needs "a resident agent in the State where the port of entry is located who is authorized to accept service of process against that corporation". The guide to wholesale clothing from Thailand to the USA shows the 2,500 dollar line on a real order. The guide to product samples from Thailand to US buyers covers samples.

What did the end of de minimis change for the importer of record?

Since 29 August 2025 every shipment from Thailand that does not travel by international mail needs a formal or informal entry with the duty paid, whatever its value. No exemption covers a parcel of US$800 or less, so a qualified party must file.

goods of all countries entering the United States will no longer be eligible for the administrative exemption from duty and certain tax at 19 U.S.C. § 1321(a)(2)(C) effective 12:01a.m. on August 29, 2025.

Source: CSMS # 66065494, Suspension of Duty-Free De Minimis Treatment for All Countries, U.S. Customs and Border Protection, 28 August 2025.

The suspension was extended via Executive Order 14388 of February 20, 2026 and made indefinite for goods not traveling on the international postal network by a CBP rule of June 24, 2026. This includes all modes other than international post. All goods valued at $800 or less must use formal or informal entry.

For international mail the compliance date is 20 January 2027. A package with a 12.5% tariff line needs a formal entry, so an importer of record and a bond.

What does DDP or duty inclusive mean for the importer of record?

DDP means the seller takes care of import clearance and pays the duty. Duty inclusive is a courier price that rolls all the same charges into one fee. Neither term names the importer of record, and neither changes who may file under US law.

DDP (Delivered Duty Paid) is unique: the seller is responsible for all duties, taxes and import formalities in the destination country.

Source: Guidance Note: Using the Incoterms 2020 Rules to Manage Tariff Risk in International Trade, International Chamber of Commerce, April 2025.

Source: International Chamber of Commerce, guidance note of April 2025.

Under DDP the seller is the importer of record. They file the entry themselves or authorize their broker to file for them. The seller must still be the party that fits one of the statute's two kinds of party. US law allows for a non-resident importer, as long as they follow the bond and agent rules.

Duty inclusive is the courier side of DDP. The sender pays duty, tax and fees inside the delivery price and the receiver pays nothing on arrival. The price does not say who is named on the entry, who holds the bond, up to what value the price applies, or who receives an IEEPA refund. Those four points go to the courier before booking. The DDP shipping page and the guide to DDP shipping explained cover the term from the sender's side.

What is changing for foreign importers of record in 2026?

Sources: Accuracy of Importer of Record Data Submitted to CBP, Federal Register, 19 August 2026; Strengthening Customs Enforcement (Executive Order 14411), Federal Register, 10 June 2026; CTPAT Alert for Broker Responsibilities Under Executive Order 14411, CBP, August 2026; Low-Value Shipments, Federal Register, 8 October 2026.

Executive Order 14411 of 3 June 2026 directs the Secretary of Homeland Security to promptly prohibit a foreign importer of record from filing informal entry. For formal entry a foreign importer may not rely on a continuous bond to meet the bond requirements for entry, except as permitted by CBP when the foreign IOR has demonstrated that the revenue would be fully protected.

Source: Strengthening Customs Enforcement, Executive Order 14411, section 2, The White House, Federal Register, 10 June 2026.

CBP's alert for brokers adds that "foreign IORs will be required to be validated in the CTPAT program; if they are not, they will be required to utilize a licensed CVCB to file entries with CBP". The 8 October proposal also asks a consignee that is not an owner or purchaser, such as a freight forwarder or a carrier, "to appoint a licensed customs broker who will act as the importer of record" for shipments of US$2,500 or less.

The order defines the US side by exclusion: a U.S. IOR entity is organized under US law, is located in the United States and has "at all times controlling beneficial owner(s) who are United States citizens or lawful permanent residents", or owns a significant amount of US real property. A Thai seller acting as its own importer of record is a foreign one. A US buyer may or may not be, depending on how it is organized and who controls it.

For a shipment today: decide who owns the goods at the border. Name the importer of record in the sales contract. Confirm the bond with the broker. Check the data on CBP Form 5106.

How Dragon Courier ships to the USA duty and tax inclusive

Dragon Courier is a Bangkok courier that delivers door to door, duty and tax inclusive. All duties, costs and tariffs included in the fee. Nothing to pay on arrival.

For USA we arrange our own service to the destination and handle customs clearance ourselves. We then pass the package to a US carrier for the final leg: UniUni on the e-commerce tier and UPS on the standard tier. Door to door takes around 5-8 days. We offer an Importer of Record (IOR) service next to airfreight and EOR services.

Prices are in the guide to the cost of shipping from Thailand to the USA. The route is on the USA destination page and the services page.

Before booking a shipment that needs a bond or a named importer of record, please message our team.

About Dragon Courier

Dragon Courier is a family owned Bangkok courier with more than 30 years in Thailand. We send more than 20,000 packages a month to over 200 destinations. We are the largest sender for eBay sellers located in Thailand.

Contacts and drop-off

We need the contents of the package and the receiver's name, address and contact number. Contact our team via office +66 2656 9019 or message Justin on LINE or WhatsApp +66 6-5937-0812. Our email is info@dragoncourier.com.

Our Bangkok office is at 217/3 Crystal Garden Building, 3rd floor, Sukhumvit Soi 4, Klongtoey, 10110. Drop off until 5pm Monday to Saturday. Pickup can be booked at a time and date that suits you.

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