Importer Of Record Number vs EIN: When A CBP‑Assigned Number Is Needed

Importer of Record Number The identifying number used by CBP for the party responsible for a U.S. import entry, commonly an EIN or a CBP-assigned number. Whether to use an EIN or a CBP-assigned number depends on the importer's legal status, U.S. presence, and recurring activity.

Many logistics teams assume the importer number is always an EIN. While that's true for most U.S. entities, foreign firms and certain non-traditional importers must use a CBP-assigned number. Understanding when each applies helps avoid filing errors and misapplied liability.

When To Use A U.S. EIN

Use a U.S. EIN when the importer is a registered U.S. business entity. Examples include domestic distributors, retailers, manufacturers, and U.S.-based subsidiaries of foreign firms. The EIN is the primary identifier for taxes and customs and should be used for ongoing imports to maintain a consistent compliance history.

When A CBP‑Assigned Number Is Appropriate

CBP assigns importer numbers when an importer lacks a U.S. EIN. Typical scenarios include:

• Foreign Principals Importing Directly: A European manufacturer that occasionally imports samples or customer-destined goods and does not hold a U.S. EIN.
• Temporary Or One-Off Transactions: Short-term trade activity where applying for an EIN is impractical.
• Agents Filing On Behalf Of Foreign Parties: Customs brokers or agents may use a CBP-assigned number for the foreign principal during processing.

How To Request A CBP Number

A customs broker typically requests a CBP-assigned importer number in coordination with the foreign party. The process involves providing company information to CBP or creating a filer profile in ACE. Work with your broker to ensure the number is properly linked to the entity and used consistently for all ACE transactions.

Risks Of Using The Wrong Number

Using an EIN when the foreign company should be the importer of record (or vice versa) can misallocate duty liability and complicate audits. If a third party is named incorrectly, they may unexpectedly face duty bills and penalty notices. Always document who is acting as IOR and why a particular identifier is used.

Practical Examples

Example 1 — U.S. Subsidiary: A foreign manufacturer that owns a U.S. subsidiary should use the subsidiary's EIN when the subsidiary is the importer on commercial invoices and assumes responsibility for duties.

Example 2 — Foreign Seller With Occasional Imports: A UK supplier shipping promotional samples directly to U.S. buyers for limited runs may use a CBP-assigned importer number, arranged through a broker, rather than applying for an EIN.

Operational Considerations For 3PLs And Carriers

Third-party logistics providers must be careful when including their own numbers on paperwork. Use of a 3PL’s importer number implies acceptance of legal responsibility. If a 3PL only provides logistics services and does not intend to assume IOR obligations, clearly list the customer's EIN or CBP-assigned number on shipment documents and in system records.

Best Practices To Decide Which Number To Use

• Policy Rule: Default to the buyer or consignee's EIN when the buyer is contractually responsible for import duties.
• Document Authority: Keep written proof of who is the importer of record, such as contract clauses or power of attorney documents.
• Consult Your Broker: Ask the customs broker to confirm whether a CBP-assigned number is necessary and to request one if needed.

In short, the Importer of Record Number may be an EIN or a CBP-assigned number depending on the importer's status and frequency of U.S. activity. Choose the correct identifier, document authority, and coordinate with your broker to keep entries accurate and shipment delays to a minimum.