Importer of Record in USA
The United States enforces a layered pre-arrival compliance framework that blocks unprepared foreign shippers at multiple points. The ISF 10+2 filing must be submitted 24 hours before ocean cargo is loaded at the foreign port, with a USD 5,000 penalty per violation for late or missing filings. FDA Prior Notice must reach the agency hours before arrival for imported food, including dietary supplements and animal food. Every formal entry requires a customs bond and an Employer Identification Number (EIN) that only a U.S. entity or authorised IOR partner can provide. On top of these, duty-free Section 321 de minimis treatment has been suspended for goods from all countries since 29 August 2025, UFLPA enforcement has expanded to raw materials including lithium, copper, steel, and aluminium, and since December 2025 the FCC Covered List has included foreign-produced drones and drone critical components, which blocks new FCC authorisations for new models.
Carra Globe acts as your Importer of Record in USA, providing the EIN, securing the customs bond, filing ISF and FDA Prior Notice, managing FCC verification, handling Section 301 tariff analysis, conducting UFLPA supply chain screening, and clearing cargo through CBP so your shipment enters the USA on first submission. For companies that need to ship to the USA without a local entity, Carra Globe provides a complete third-party IOR solution covering customs clearance, bond provision, regulatory filing, and DDP delivery to any U.S. address.
What an Importer of Record Does in the USA
An Importer of Record in the USA is the legally responsible party for customs entry filing, duty payment, regulatory compliance, and post-entry obligations to U.S. Customs and Border Protection (CBP). Commercial imports require a U.S. entity or individual with an Employer Identification Number (EIN) or Social Security Number. Foreign companies without a U.S. presence must work through an IOR partner. The USA’s pre-arrival filing requirements, ISF 10+2 for ocean cargo and FDA Prior Notice for regulated products, must be completed before cargo arrives at the U.S. port of entry. Neither can be resolved after arrival.
Carra Globe provides the importer of record through its in-country importing structure: a U.S.-registered importer holding the EIN and continuous customs bond, which manages CBP, FDA and FCC requirements and stands as the accountable importer on every entry. Entity details are shared during onboarding. This means your company can ship DDP into the USA without establishing a local entity. Whether you need to import IT equipment to the USA, clear data centre hardware through CBP, or deploy telecom infrastructure at U.S. locations, the IOR and customs bond requirement applies to all commercial goods.
Can a foreign company import into USA without a local entity?
Usually, yes. Carra Globe acts as importer of record in USA through its in-country importing structure, so a foreign seller, integrator or end user does not need its own registered company there.
Whether a specific shipment can go ahead still depends on the product, its approvals and the parties involved. We check those before the goods leave origin and confirm the route in writing.
USA import at a glance
| Customs authority | U.S. Customs and Border Protection (CBP) |
|---|---|
| Importer registration | Importer of record identified by EIN; customs bond required for formal entries (single transaction bond at least entered value plus duties, taxes and fees; continuous bond minimum USD 50,000) |
| Wireless and telecom approval | FCC equipment authorisation: Certification through an FCC-recognised TCB, or Supplier’s Declaration of Conformity (47 CFR 2.901); FCC Covered List includes foreign-produced drones and drone critical components since 22 December 2025 (FCC) |
| Medical devices | FDA: establishment registration for foreign manufacturers and initial importers; 510(k) for non-exempt Class I and II devices, PMA for most Class III (FDA) |
| IT equipment duty | Section 301 duties on covered China-origin goods, mostly 7.5% or 25%, raised to 50% or 100% for some products by the 2024 review (USTR). Duty-free de minimis suspended for all countries since 29 August 2025 (White House EO). MPF 0.3464%, minimum USD 34.58, maximum USD 670.86 from 1 October 2026 (Federal Register) |
Checked against official sources on 29 September 2026. Rates and rules change, so confirm the treatment for your exact HS code before shipping.
Why Companies Use Carra Globe as Their Importer of Record in USA
The USA’s compliance framework combines pre-arrival filing deadlines, agency-specific product approvals, and evolving trade policy that changes the cost basis of entire product categories overnight. ISF 10+2 must be filed before vessel loading, not before arrival. FDA Prior Notice must reach the agency 2 to 8 hours before cargo arrives depending on transport mode. A missing customs bond means the entry is rejected outright.
Beyond these pre-arrival requirements, the 2025 and 2026 trade policy changes have introduced new compliance layers that did not exist 12 months ago. Section 321 de minimis has been suspended for goods from all countries since 29 August 2025, so low-value shipments that previously cleared duty-free now need an informal or formal entry with duty assessed. UFLPA enforcement has expanded from finished goods to raw materials, requiring multi-tier supply chain documentation tracing lithium, copper, steel, aluminium, and caustic soda to origin.
The FCC Covered List blocks new equipment authorisations for communications equipment from listed entities and, since December 2025, for new models of foreign-produced drones and drone critical components. Carra Globe identifies and manages all of these before cargo moves. As a third-party Importer of Record in the USA, Carra Globe assumes the full legal responsibility for customs entry, duty payment, and regulatory compliance that foreign shippers cannot hold without a U.S. presence, making USA customs compliance manageable from any origin country.
When You Need IOR Services in USA
Working with an Importer of Record in the USA becomes necessary when no U.S. entity exists in your corporate structure, when your consignee cannot act as the importing party, when DDP obligations require one party accountable for all entry costs, when products require FDA registration or Prior Notice, when goods include telecom or RF equipment requiring FCC authorisation, when you need a customs bond but have no U.S. creditworthiness, when goods are subject to Section 301 tariffs and require tariff engineering, when UFLPA raw materials screening applies to your supply chain, when related-party transactions require transfer pricing documentation, or when CPSC, EPA, or DOT regulatory obligations apply or when needing end-to-end freight forwarding to the USA integrated with customs clearance, bond provision, and last-mile delivery.
Who does what in a USA import
| Role | What it means |
|---|---|
| Importer of record | Named on the import declaration and responsible for it, for duties and taxes, and for meeting import rules. Carra Globe's in-country importing structure takes this role. |
| Customs broker or declarant | Prepares and files the customs entry as authorised. Filing the entry does not make the broker the importer. |
| Consignee | The party named to receive the goods. Being the consignee does not by itself make a company the importer. |
| End user | Uses the equipment and supplies end-use details for screening. It may still need its own site or sector permissions. |
| DDP seller | Pays the agreed delivery costs under Delivered Duty Paid. DDP does not make a seller without local registration the legal importer. |
| Freight forwarder | Books and moves the goods. It does not take on the importer's legal duties. |
Common Hold Triggers in USA & How Carra Globe Prevents Them
The most frequent causes of holds at U.S. ports follow a consistent pattern: ISF not filed before vessel loading (USD 5,000 penalty plus hold), missing customs bond (entry rejected), Section 321 de minimis claimed after its suspension for all countries on 29 August 2025 (entry rejected), FDA Prior Notice not submitted (cargo refused or destroyed), FCC authorisation absent for RF devices (detention), FCC Covered List violation (refusal of entry), incorrect HTS classification triggering under-assessment, UFLPA-flagged raw materials without multi-tier supply chain documentation, inaccurate country of origin declaration, related-party transactions without transfer pricing documentation, missing CPC for children’s products, missing TSCA certification, and missing Lacey Act declarations.
Carra Globe prevents these by filing ISF at least 24 hours before loading, securing the customs bond before arrival, filing low-value shipments under the correct informal or formal entry type now that de minimis is suspended, submitting FDA Prior Notice within required timeframes, confirming FCC authorisation and screening against the Covered List, optimising HTS classification, conducting multi-tier UFLPA raw materials screening, reviewing related-party transfer pricing, and verifying all CPSC, TSCA, and Lacey Act requirements at SKU level before dispatch.
USA Rules & Regulations (2026 Compliance Framework)
- USA Customs: cbp.gov (Customs and Border Protection)
- Export control: bis.doc.gov (Bureau of Industry and Security)
U.S. Customs and Border Protection (CBP) & Entry Requirements
All commercial shipments valued over USD 2,500 require a formal customs entry (CBP Form 7501) filed through the Automated Commercial Environment (ACE). Duty-free Section 321 de minimis treatment (USD 800) has been suspended for goods from all countries since 29 August 2025. Low-value commercial shipments now need an informal or formal entry with duties paid, whatever their origin.
An Employer Identification Number (EIN) is mandatory for the importer of record. A customs bond is required for all formal entries, either a single-entry bond (generally at least the entered value plus all duties, taxes, and fees) or a continuous bond (minimum USD 50,000, USD 100,000 or more for high-risk categories).
ISF (Importer Security Filing), also called 10+2, must be filed 24 hours before ocean cargo is loaded at the foreign port. Non-compliance results in a USD 5,000 penalty per violation. ISF data elements include seller, buyer, importer of record number, consignee, manufacturer, ship-to party, country of origin, HTS classification, container stuffing location, and consolidator. The entry summary (CBP Form 7501) must be filed, with estimated duties deposited, within 10 working days after entry. CBP uses risk-based targeting to select shipments for document review, non-intrusive (X-ray) inspection or physical examination. All import records must be retained for 5 years.
FDA: Food and Drug Administration
The FDA regulates food, dietary supplements, cosmetics, medical devices, drugs, biologics, radiation-emitting devices, and tobacco products. FDA registration is required for food facilities that manufacture, process, pack or hold food for U.S. consumption and must be renewed between 1 October and 31 December of each even-numbered year. Prior Notice for imported food must be submitted 2 hours before arrival by road, 4 hours by air or rail, and 8 hours by water via FDA’s Prior Notice System Interface (PNSI). Failure to submit results in cargo refusal or destruction.
Medical devices are classified as Class I, II, or III. Non-exempt Class I and II devices require 510(k) premarket notification and most Class III devices require PMA before marketing in the USA. Foreign manufacturers and initial importers must register their establishments with FDA; manufacturers must also list their devices, while initial importers identify their manufacturers instead. UDI labelling is required per 21 CFR 801 Subpart B. Radiation-emitting products require accession numbers under 21 CFR 1000–1050. DSCSA serialisation and traceability requirements apply to prescription drug importers as of November 2023. FDA may issue import alerts for products from non-compliant facilities.
FCC Equipment Authorisation: Telecom & RF Devices
The FCC regulates all RF devices under 47 CFR. Equipment authorisation is required before import, marketing, or sale of any RF device. Two procedures apply: Certification, mainly for intentional radiators (cellular, WiFi, Bluetooth, transmitters), granted by FCC-recognised TCBs, and the Supplier’s Declaration of Conformity (SDoC), used for many unintentional radiators such as IT equipment, where the supplier tests and declares compliance. The FCC ID must be displayed on certified devices. A Responsible Party (U.S.-based) must be identified for all FCC-regulated products. Test reports must be from FCC-recognised or ISO 17025 accredited labs.
FCC Covered List: communications equipment from listed entities cannot receive new FCC equipment authorisations, and since December 2025 this also applies to new models of foreign-produced drones and drone critical components, unless a specific exemption applies. Existing authorisations for legacy equipment remain valid but new models or variants cannot be approved. Importers must verify the manufacturer is not on the Covered List before importing. The WiFi 6E (6 GHz band) requires updated certification. The voluntary U.S. Cyber Trust Mark programme is available for IoT devices meeting NIST cybersecurity criteria.
Schedule a Free Consultation With Our Experts
Send us the hardware list. We will come back with the compliance route, the landed cost, and a realistic timeline.
Section 301 Tariffs & UFLPA
Section 301 tariffs on Chinese-origin goods remain in effect, covering approximately USD 370 billion in annual trade value. Four tranches apply additional duties, mostly 7.5% or 25%, on top of normal HTS rates, and the 2024 four-year review raised rates for some products to 50% (such as semiconductors and solar cells) or 100% (electric vehicles). Products “substantially transformed” in a third country may avoid Section 301 if they meet CBP’s substantial transformation test, but simple assembly or repackaging does not qualify. Section 301 tariffs apply whatever the entry type, and low-value shipments no longer qualify for de minimis.
The Uyghur Forced Labor Prevention Act (UFLPA) creates a rebuttable presumption that goods mined, produced, or manufactured in Xinjiang are made with forced labour and prohibited from entry. The August 2025 UFLPA Strategy update added caustic soda, copper, lithium, red dates and steel as high-priority enforcement sectors, alongside existing sectors such as aluminium. Products manufactured in third countries (Mexico, Vietnam, etc.) using Xinjiang-sourced materials remain subject to detention. CBP requires multi-tier supply chain documentation tracing raw materials to origin. This directly impacts IT hardware, electronics, automotive, and industrial equipment. These evolving trade restrictions make US import regulations in 2026 significantly more complex than even 12 months ago, particularly for companies sourcing from China or using China-origin raw materials in third-country manufacturing.
USMCA: Preferential Duty Treatment
USMCA provides duty-free treatment for qualifying goods originating in the USA, Mexico, or Canada. Goods must be wholly obtained, produced entirely, or meet product-specific rules of origin (regional value content, tariff shift). A USMCA Certification is required for shipments over USD 2,500 with 9 minimum data elements. Automotive rules require 75% regional value content plus labour value content requirements. Textiles qualify under the “yarn forward” rule. Claims are subject to CBP origin verification with 5-year documentation retention. Invalid claims result in duty assessment plus interest and penalties.
CPSC, EPA, DOT & Other Agency Requirements
CPSC regulates consumer product safety. A Children’s Product Certificate (CPC) is required for products designed for children 12 and under, based on third-party testing by a CPSC-accepted lab. A General Certificate of Conformity (GCC) is required for adult products subject to CPSC rules. EPA regulates chemical substances under TSCA, importers must file a TSCA Certificate of Compliance or declare exemption at entry. DOT regulates vehicle safety (FMVSS), hazardous materials (PHMSA), and emissions. The Lacey Act requires import declarations for wood products, seafood, and wildlife. Textile and apparel labelling must meet FTC requirements for origin, fibre content, care instructions, and manufacturer identification.
Import Duties, Taxes & Fees
Customs duty is assessed by HTS classification, ranging from 0% to 37.5%. Most Favoured Nation (MFN) rates apply to WTO members. Section 301 tariffs (7.5% to 25%) apply on top of HTS duty for covered Chinese-origin goods. Merchandise Processing Fee (MPF): formal entries at 0.3464% of entered value, minimum USD 34.58, maximum USD 670.86 per entry (from 1 October 2026; FY2026 limits were USD 33.58 and USD 651.50). Informal entries pay a flat MPF instead, and Section 321 de minimis is suspended for all countries.
Harbor Maintenance Fee (HMF): 0.125% of cargo value for ocean shipments only. Federal Excise Tax applies to alcohol, tobacco, fuel, tyres, and firearms. State sales and use tax is not collected by CBP at import. Anti-Dumping (AD) and Countervailing Duties (CVD) apply as cash deposits at entry for products sold below fair value or benefiting from foreign subsidies. US import duties in 2026 range from 0% for ITA-covered IT goods to 37.5% at the HTS ceiling, with Section 301 tariffs adding 7.5% to 100% for covered China-origin products on top of standard rates.
Special Entry Programmes & Bonded Facilities
Foreign Trade Zones (FTZ) allow imported goods to be stored, processed, or manufactured without formal entry, with duties deferred until goods leave for U.S. consumption. Temporary Importation Under Bond (TIB) permits duty-free temporary import for trade shows, testing, or repair with re-export within 1 year. ATA Carnet covers temporary admission of professional equipment and commercial samples. Bonded warehouses store goods without duty payment until withdrawal for consumption. In-bond movements transport goods from port of arrival to another U.S. location without formal entry, with duty paid at final destination.
Product Categories Requiring Special Attention in USA
Carra Globe’s IOR services are tailored to industries that rely on precision, speed, and reliability.
USA Customs Clearance Lead Times
USA customs clearance timelines vary by CBP channel assignment, regulatory agency involvement, and whether cargo is flagged for examination. With complete pre-arrival filing, most entries clear within hours.
- Entry released without examination: same day to 1 business day
- Yellow channel (document review): 1 to 3 business days
- Entry selected for X-ray or physical examination: 2 to 5 business days
- FDA Prior Notice review: typically released within hours if compliant
- FCC equipment authorisation (new certification): 4 to 8 weeks
- CPSC third-party testing and CPC issuance: 2 to 4 weeks
- FDA 510(k) clearance (medical devices): 1 to 2 months average
- Continuous customs bond issuance: 3 to 7 business days
- Entry summary and estimated duty deposit: within 10 working days after entry
- Low-value shipments: de minimis suspended for all countries since 29 August 2025, so an informal or formal entry applies
Lead times depend on CBP channel assignment, ISF timeliness, bond status, regulatory agency holds, and whether cargo is subject to intensive examination.
Carra Globe checks the product approvals, documents and importer route before cargo leaves origin, so problems are fixed at origin rather than at the border. Clearance time still depends on the product, its approvals and any customs inspection; typical ranges are in the lead times section.
What we check before we accept a USA shipment
- The exact product, model and what it does
- HS classification, origin and customs value for each line
- Which approvals are needed and who holds them
- The parties, the end user and the intended use
- Commercial terms, and who pays duty and tax
- The documents needed for filing
We decline shipments that are prohibited, sanctioned, counterfeit, misdeclared or deliberately undervalued. We hold a shipment until any missing approval or document is in place.
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Carra Globe services in USA
Carra Globe provides Importer of Record in USA (IOR), Exporter of Record (EOR), DDP shipping, ISF 10+2 filing, FDA Prior Notice submission, customs clearance, continuous customs bond provision, FCC verification and Covered List screening, Section 301 tariff engineering, USMCA origin certification support, UFLPA raw materials tracing, HTS classification, trade compliance consulting, freight forwarding, warehousing, distribution, and white glove delivery and installation across all U.S. ports including Los Angeles, New York JFK, Chicago O’Hare, and Miami.
The largest US trade corridors are covered by Carra Globe’s IOR network: Canada and Mexico under CUSMA, Israel under the US-Israel FTA, UK and Germany for transatlantic trade, and India as a growing trade corridor.
Our services include DDP shipping to the USA with full duty, MPF, and HMF settlement, USA freight forwarding by air, ocean, and road, and end-to-end customs clearance coordination across all major U.S. ports.
Frequently Asked Questions: USA IOR & DDP Shipping
Can I ship to the USA on DDP terms without a local entity?
Yes. Through its in-country importing structure, Carra Globe provides a U.S. importer with an EIN, secures the customs bond, files CBP entries, submits ISF and FDA Prior Notice, and settles duty, MPF, and HMF on your behalf.
What is the ISF 10+2 and when must it be filed?
The Importer Security Filing requires 10 data elements from the importer and 2 from the carrier. It must be filed at least 24 hours before ocean cargo is loaded. Late or missing filing results in a USD 5,000 penalty per violation. Air shipments are exempt.
What is Section 321 and when does it apply?
Section 321 traditionally allowed duty-free entry for shipments under USD 800. Since 29 August 2025, duty-free de minimis treatment is suspended for goods from all countries, so low-value shipments need an informal or formal entry with duties paid. Section 321 does not exempt goods from FDA, FCC, or CPSC requirements.
What is a customs bond and do I need one?
A customs bond guarantees duties, taxes, and penalties will be paid to CBP. All formal entries require one. Single-entry bonds cover one shipment (generally set at the entered value plus duties, taxes and fees). Continuous bonds cover all entries for 12 months (minimum USD 50,000). Continuous bonds are more cost-effective for regular importers.
What products require FDA Prior Notice?
All food, including dietary supplements and animal food; cosmetics do not need Prior Notice. Submit 2 hours before arrival by road, 4 hours by air or rail, 8 hours by water via PNSI. Failure results in cargo refusal or destruction.
Do I need FCC authorisation for my wireless device?
Yes. All devices emitting RF energy require FCC equipment authorisation before import. Most require Certification from an FCC-recognised TCB. The FCC ID must appear on the device. Devices without authorisation face seizure and refusal. Verify the manufacturer is not on the FCC Covered List.
What are Section 301 tariffs?
Additional duties, mostly 7.5% or 25% and up to 100% on some products after the 2024 review, on approximately USD 370 billion of Chinese-origin goods applied on top of normal HTS rates. Products assembled or repackaged in third countries may still be subject unless substantially transformed. Section 301 applies whatever the entry type.
What is UFLPA and how does it affect imports?
The UFLPA presumes goods from Xinjiang are made with forced labour and prohibits entry. Enforcement has expanded to raw materials: lithium, copper, steel, aluminium, and caustic soda. Third-country manufactured goods using Xinjiang-sourced materials remain subject to detention. Multi-tier supply chain documentation required. Directly impacts IT hardware, electronics, and industrial equipment.
What are the critical 2025–2026 changes?
Section 321 de minimis suspended for all countries from 29 August 2025. MPF limits rise again on 1 October 2026 (minimum USD 34.58, maximum USD 670.86). UFLPA expanded to raw materials with multi-tier tracing required. FCC Covered List blocks new authorisations for communications equipment from listed entities and, since December 2025, for new models of foreign-produced drones and drone components.
Can Carra Globe handle data centre and IT deployments in the USA?
Yes. Servers, networking, storage, and telecom hardware with ISF filing, customs bond, FCC verification, Covered List screening, Section 301 analysis, UFLPA raw materials tracing, CBP clearance, and white glove delivery at U.S. locations.
How much does it cost to import goods into the USA in 2026?
US import duties in 2026 range from 0% to 37.5% based on HTS classification, with Section 301 tariffs adding 7.5% to 100% for covered China-origin goods. Additional costs include MPF (0.3464%, minimum USD 34.58, maximum USD 670.86 from 1 October 2026), HMF (0.125% for ocean cargo), customs bond fees, and any applicable AD/CVD deposits. Carra Globe provides complete landed cost estimates before cargo ships.
Does Carra Globe provide freight forwarding to the USA?
Yes. Carra Globe provides USA freight forwarding by air, ocean, and road, fully integrated with IOR services, ISF filing, customs clearance, warehousing, and last-mile delivery across all major U.S. ports including Los Angeles, New York, Chicago, and Miami.
How long does customs clearance take in the USA?
USA customs clearance for entries released without examination typically takes same day to 1 business day. Document review takes 1 to 3 days, and an X-ray or physical examination takes 2 to 5 days. Pre-arrival ISF filing, bond provision, and complete documentation significantly reduce clearance time. Carra Globe’s pre-departure compliance checks aim to get entries filed correctly on first submission.
Official sources
- White House: Suspending duty-free de minimis treatment for all countries
- CBP: Monetary guidelines for setting bond amounts (Directive 3510-004)
- eCFR 19 CFR 142.12: entry summary time limit
- eCFR 21 CFR 1.279: FDA Prior Notice timeframes
- eCFR 47 CFR 2.901: FCC equipment authorisation procedures
- FCC: Covered List update adding foreign UAS (fact sheet)
- FDA: Who must register, list and pay the fee (medical devices)
- USTR: Section 301 four-year review tariff actions
Last reviewed: 29 September 2026
Update policy: reviewed every quarter and after major customs, tax or product-rule changes
Corrections: info@carraglobe.com
This page gives general operational information as at 29 September 2026. It is not legal or tax advice. Requirements depend on the exact product and transaction and may change. Customs and regulatory authorities make the final decisions.