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 any regulated product. 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, Section 321 de minimis treatment is effectively suspended for China-origin and Section 301-covered goods as of mid-2025, UFLPA enforcement has expanded to raw materials including lithium, copper, steel, and aluminum, and the FCC Covered List now prohibits new equipment authorisations for drones and critical communications equipment from covered entities.
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.
Importer of Record in 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 holds the U.S. EIN, maintains continuous customs bonds, manages all CBP, FDA, and FCC regulatory relationships, and stands as the accountable importer on every entry so your company can ship DDP into the USA without establishing a local entity.
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 is suspended for China-origin goods, meaning low-value shipments that previously cleared duty-free now require formal entries with full duty assessment. UFLPA enforcement has expanded from finished goods to raw materials, requiring multi-tier supply chain documentation tracing lithium battery, copper, steel, aluminum, and caustic soda to origin. The FCC Covered List prohibits new equipment authorisations for drones and communications equipment from covered foreign entities. Carra Globe identifies and manages all of these before cargo moves.
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.
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 claimed for China-origin or Section 301 goods (entry rejected since mid-2025), 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, verifying Section 321 eligibility before claiming de minimis treatment, 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 (2025–2026 Compliance Framework)
U.S.A 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). Section 321 de minimis (USD 800) is effectively suspended for China-origin and Section 301-covered products as of mid-2025. These shipments now require formal or informal entries regardless of value. Traditional Section 321 treatment (Type 86 duty-free entry) remains available only for non-China, non-Section 301 shipments under USD 800.
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 (typically 10% of 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 within 10 calendar days of cargo arrival with estimated duties paid within that timeframe. CBP assigns entries to Green (released), Yellow (document review), or Red (physical exam) channels. 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 facility registration is required for food manufacturers and must be renewed every two years in odd-numbered years. Prior Notice must be submitted 2 hours before arrival by road, 4 hours by air, and 8 hours by ocean or rail 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. Class II and III require 510(k) premarket notification or PMA before import. FDA establishment registration and device listing are mandatory for device manufacturers and importers. 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. Three procedures apply: Certification for intentional radiators (cellular, WiFi, Bluetooth, transmitters), granted by FCC-recognised TCBs. Declaration of Conformity (DoC) for unintentional radiators and low-power devices. Verification for specific device categories where the supplier tests and verifies 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.
2026 FCC Covered List: Foreign-made drones and critical communications components from covered entities are prohibited from receiving new FCC equipment authorisations. 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.
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 of 7.5% to 25% on top of normal HTS rates. 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 to formal entries and Section 321 shipments alike.
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. As of 2026, CBP enforcement has expanded to foundational raw materials: lithium, copper, steel, aluminum, and caustic soda. 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.
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 33.58, maximum USD 651.50 per entry (effective October 1, 2025). Section 321 entries carry no MPF but Section 321 is suspended for China-origin goods. 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.
Special Entry Programs & 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
- Standard formal entry (Green channel): same day to 1 business day
- Yellow channel (document review): 1 to 3 business days
- Red channel (physical exam): 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
- Post–entry duty payment deadline: 10 calendar days from arrival
- Section 321 clearance (non–China, non–Section 301): same day
Lead times depend on CBP channel assignment, ISF timeliness, bond status, regulatory agency holds, and whether cargo is subject to intensive examination.
Carra Globe already holds every licence, certification, and approval listed above so your cargo moves without any delay.
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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 (air, ocean, road), warehousing, distribution, and white glove delivery and installation across all U.S. ports including Los Angeles, New York JFK, Chicago O’Hare, and Miami.
Frequently Asked Questions — USA IOR & DDP Shipping
Can I ship to the USA on DDP terms without a local entity?
Yes. Carra Globe provides the U.S. 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. As of mid-2025, this is suspended for China-origin and Section 301 goods, which now require formal entries regardless of value. Traditional Section 321 remains available only for non-China, non-Section 301 shipments under USD 800. 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 (typically 10% of duties). 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, dietary supplements, animal food, and cosmetics. Submit 2 hours before arrival by road, 4 hours by air, 8 hours by ocean or rail 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 of 7.5% to 25% 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 to formal entries and Section 321 shipments alike
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, aluminum, 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 suspended for China-origin goods. MPF increased October 1, 2025 (minimum USD 33.58, maximum USD 651.50). UFLPA expanded to raw materials with multi-tier tracing required. FCC Covered List prohibits new authorisations for drones and critical communications equipment from covered entities.
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.
