Global Importer of Record · ISO-Certified · Ministry-Authorized 🇬🇧 Global Operations Line: +44 330 533 0223
United States Importer of Record (IOR)

Importer of Record in the United States

The United States is a high-volume and well-structured import market, but technology shipments still fail when importer responsibility, product classification and agency scope are not aligned before shipment. FCC, FDA, and EPA requirements apply to technology shipments in ways that are not always obvious from the commercial invoice. TFTIOR reviews each shipment before it ships, not after it arrives at the border.

CBP & Reasonable Care
FCC / FDA / EPA Review
Miami Warehousing
Discuss a USA import
Last Updated: May 9, 2026
USA customs framework

USA import regulations: CBP, HTS classification, FCC and agency review (2026)

U.S. Customs and Border Protection processes commercial imports under 19 U.S.C. § 1484 through the ACE (Automated Commercial Environment) platform. Technology shipments can also fall under FCC, FDA, or EPA jurisdiction depending on product type, condition, and intended use.

CBP entry and the reasonable care standard

Under 19 U.S.C. § 1484, the importer of record is legally responsible for making entry and providing the information CBP needs to assess admissibility, duties, and any applicable legal requirements. This includes the reasonable care obligation: the IOR must correctly classify the goods under the Harmonized Tariff Schedule of the United States (HTSUS), declare the correct value and country of origin, and identify any agency requirements that apply.

The commercial buyer, end customer, data center, or reseller is often not in a position to act as IOR. When that is the case and no responsible IOR structure is in place before shipment, the cargo can be held or refused at the border. See our Importer of Record and Paper IOR pages for the full picture of how IOR responsibility works.

FCC and RF device importation

FCC (Federal Communications Commission) regulates the importation of radio frequency devices under 47 CFR Part 2. A radio frequency device may only be imported into the United States if the importer, ultimate consignee, or customs broker determines that the device meets one of the permitted entry conditions under FCC rules. This covers Wi-Fi, Bluetooth, cellular, RFID, and satellite-enabled equipment, including refurbished or modified devices.

CE marks and FCC Supplier Declarations of Conformity issued outside the U.S. do not automatically satisfy CBP or FCC import requirements. Telecom-enabled devices with unresolved FCC status should not ship without prior review. TFTIOR checks FCC scope where the shipment includes wireless, radio-frequency, telecom-enabled or potentially RF-capable equipment.

FDA and EPA regulated products

FDA (U.S. Food and Drug Administration) regulates medical devices, diagnostic equipment, laboratory instruments, and certain other product categories at import. FDA-regulated products must meet applicable U.S. requirements when they arrive at the border; non-compliant goods can be refused entry and placed on detention. A formal FDA import entry is required for regulated goods.

EPA (Environmental Protection Agency) requirements can apply to batteries, certain chemicals, engines, vehicles, and electronic waste. Products in these categories should not be treated as standard commercial hardware without a separate review. TFTIOR flags EPA exposure where relevant during the pre-shipment check.

HTS classification, valuation and Section 301 tariffs

Most IT hardware falls under HTSUS Chapters 84 and 85, with standard duty rates of 0 to 3.5% for servers, switches, storage systems, and related equipment. However, Section 301 tariffs on China-origin goods can add 7.5 to 25% on top of the standard rate, depending on the product's HS code and whether any active exclusion applies. Country of origin documentation and correct HTS classification are therefore not optional checks for technology shipments.

The United States does not apply a federal VAT. State sales tax is not assessed at the point of importation. The primary cost variables at entry are import duty, any applicable Section 301 tariffs, and MPF (Merchandise Processing Fee).

USA import snapshot (2026)

IT hardware (HTSUS Ch. 84-85): 0-3.5% standard duty (typical range)
Section 301 (China-origin): +7.5-25% where applicable
Federal VAT: none
Customs system: CBP ACE (Automated Commercial Environment)
Agency checks: FCC, FDA, EPA depending on product
Typical range only. Final duty depends on HTSUS classification, country of origin, trade remedy measures and any active exclusion. Section 301 exclusions remain subject to USTR review.

Ports and airports

Air (West): Los Angeles International (LAX)
Air (East): John F. Kennedy International (JFK)
Air (South): Miami International (MIA)
Air (Midwest): Chicago O'Hare International (ORD)
Sea (West): Los Angeles / Long Beach (San Pedro)
Sea (East): Port of New York and New Jersey
Sea (South): Port of Miami, Port of Houston

Clearance lead times

Routine air/sea clearance: same day to 3 working days
CBP exam or hold: 3-10 working days
Entry summary (CBP Form 7501): filed within 10 days of arrival
FDA import review: product-dependent; timing varies by product type, documentation and admissibility review
FCC pre-clearance: confirm before shipment; no fixed timeline

Standard import documents

Commercial invoice (HTS code, value, origin, condition)
Packing list
Bill of lading or air waybill
CBP entry (coordinated with licensed customs broker)
FCC documentation or SDoC (wireless/RF equipment)
FDA prior notice or import alert check (medical/lab devices)
EPA compliance confirmation (batteries, e-waste, chemicals)
Country of origin documentation

Why IOR structure matters

When the importer of record structure is the problem

Most U.S. import delays for technology shipments are not freight problems. They are IOR structure problems, identified too late.

The importer of record is not just a name on the customs entry form. Under 19 U.S.C. § 1484, the IOR is legally responsible for the accuracy of the entry, the HTS classification, the declared value, and any agency-specific disclosures. If the buyer, reseller, or data center operator is not in a position to take on that responsibility, and no alternative IOR structure is arranged before shipment, the cargo can arrive at a U.S. port with no one authorized to make entry.

The other common failure point is product scope. A shipment that looks like standard commercial hardware on the invoice can still carry FCC, FDA, or EPA requirements that the buyer did not expect and the freight forwarder did not check. These are not rare edge cases. Wireless-capable enterprise equipment, refurbished devices, lab instruments, and battery systems hit these requirements regularly. TFTIOR identifies them before the cargo moves.

No IOR structure

If the buyer, consignee, or data center cannot act as IOR and no responsible IOR is arranged before shipment, CBP cannot accept the entry. The cargo is held.

FCC scope missed

Wireless, cellular, or RF-enabled devices without FCC documentation face customs holds and potential seizure. This includes refurbished and modified equipment.

HTS and Section 301

Incorrect HTS classification or undisclosed China origin can result in duty underpayment, CBP audits, and post-entry penalties under the reasonable care standard.

Refurbished condition

Used or refurbished equipment must be declared correctly. Misstating condition on the commercial invoice creates customs and post-entry exposure.

FDA or EPA exposure

Medical, diagnostic, lab, battery, or environmental-sensitive products require agency-specific handling. Treating them as standard commercial hardware leads to refusals and detention at the border.

Valuation or origin gaps

Unsupported discounts, incorrect origin declarations, or missing commercial documents create audit exposure that surfaces months after clearance.

How TFTIOR supports USA imports

What we handle on your behalf

TFTIOR manages the importer of record structure, documentation alignment, and customs-facing coordination for eligible technology shipments into the United States.

Our role starts before the cargo moves. We review product descriptions, HTS assumptions, and declared origin and value before the shipment is confirmed. Refurbished goods and regulated categories get a closer look. If something does not work under a responsible IOR structure, we say so at the review stage, not at the U.S. border.

  • Product and shipment review: HTS code, country of origin, declared value, equipment condition, and intended use are checked before acceptance.
  • Agency scope screening: FCC, FDA, and EPA requirements are identified during the pre-shipment review, not discovered at entry.
  • Documentation alignment: Commercial invoice, packing list, origin documents, and condition statements are reviewed against CBP requirements.
  • IOR coordination: TFTIOR structures the importer of record arrangement and coordinates with the licensed customs broker through to entry release.
  • Post-clearance support: After customs release, goods move to the final destination or into Miami warehousing for staged delivery, consolidation, or project dispatch.
  • EOR support: TFTIOR also supports Exporter of Record coordination for U.S.-origin equipment moving outbound to other markets.

IOR costs depend on shipment value, product classification, number of line items, agency requirements involved, and warehousing needs. We do not publish standard rates because eligible shipments vary significantly. Contact us with the shipment details for a specific review.

Pre-shipment

HTS review, FCC/FDA/EPA scope check, refurbished condition assessment, and commercial invoice alignment before the cargo leaves origin.

At customs

CBP entry coordination under the approved IOR structure, customs broker management, and response to CBP queries or exam requests.

Post-clearance

Customs entry records, duty and fee documentation, and Miami warehousing or final-mile delivery coordination where required.

Equipment scope

Typical equipment we support in the United States

Each shipment is reviewed individually. The categories below represent the types of goods we support for eligible USA imports, subject to product-level feasibility review.

IT Infrastructure

Servers & Enterprise Hardware

Data center servers, storage systems, enterprise switches, and network equipment. HTS classification, origin documentation, and product descriptions are aligned before entry.

Servers Storage Data Center
Telecom & Wireless

FCC-Scope Devices

Routers, firewalls, wireless access points, RF-enabled equipment, and cellular hardware. FCC documentation and technical specifications are verified before shipment as part of the pre-import review.

FCC RF Equipment Telecom
Refurbished

Used & Refurbished IT

Selected refurbished servers, network devices, storage systems, and enterprise IT assets, subject to feasibility review. Condition, intended use, and agency scope are checked before acceptance. See our refurbished equipment IOR page for details.

Refurbished Used IT Pre-owned
Data Center

GPU & AI Hardware

GPU clusters, AI accelerator hardware, high-density compute equipment, and related power and cooling infrastructure. Importer structure, serial number control, and staged delivery planning are often more relevant than the freight itself.

GPU AI Hardware Compute
Spare Parts

Replacement & Spare Parts

Time-sensitive spare parts shipments for IT and telecom infrastructure. Documentation must still meet CBP requirements regardless of urgency. Clean product descriptions and a defined IOR structure are required before shipment.

Spare Parts Replacement Maintenance
Regulated

Medical & Lab Equipment

Diagnostic instruments, lab testing systems, and regulated medical devices. FDA import requirements are checked before the shipment is accepted. These are not treated as standard hardware shipments. See our medical device IOR page.

FDA Medical Lab
Post-clearance logistics

Miami warehousing and staged delivery support

For companies importing into the United States for project deployment, spare parts distribution, or regional logistics, TFTIOR can support Miami-based warehousing options after customs clearance.

Miami is useful when a shipment needs to be held, consolidated, staged, or released in phases before final delivery. Technology suppliers, refurbished equipment sellers, spare parts programs, and companies using the United States as a logistics point for domestic or Latin America-facing operations use this option regularly.

This is not a blanket storage offer. It is a controlled warehousing and staged delivery layer for eligible shipments after import clearance under a responsible IOR structure. Availability and terms depend on the shipment type, volume, and project timeline.

  • Temporary storage after customs clearance
  • Staged release for project rollouts
  • Consolidation of multiple shipments
  • Spare parts holding and inventory coordination
  • Delivery planning with downstream partners
  • LATAM-facing dispatch support
Who uses Miami warehousing?

Foreign technology vendors, IT hardware suppliers, spare parts providers, and companies deploying equipment across multiple U.S. locations or routing through Miami for Latin America distribution.

Post-clearance documentation

After customs release, TFTIOR provides the CBP entry records, duty and fee payment confirmation, and delivery coordination documentation for your project records.

End-to-end flow

How a USA IOR import works with TFTIOR

The review happens before the cargo moves. That is how problems stay out of the U.S. border and out of the post-entry audit queue.

  1. Shipment review: The client shares the product description, HTS code if available, country of origin, declared value, equipment condition, intended use, and consignee details. Refurbished and regulated goods are flagged at this stage.
  2. Feasibility check: TFTIOR reviews whether the shipment can be supported under a responsible USA IOR structure. FCC, FDA, and EPA scope is assessed. If the shipment cannot be supported, we identify why before the cargo is booked.
  3. Documentation alignment: Commercial invoice, packing list, origin documents, product descriptions, and condition statements are reviewed against CBP and agency requirements before shipment.
  4. Agency screening: FCC documentation, FDA import checks, and EPA requirements are addressed where applicable, before the cargo leaves origin.
  5. Customs entry: TFTIOR coordinates the importer of record structure and customs entry process with the licensed customs broker under 19 U.S.C. § 1484. CBP queries and examination requests are managed through to release.
  6. Post-clearance routing: After customs release, goods move to the final destination or into Miami warehousing for staged release, consolidation, or project delivery coordination.
Who uses this service?

Foreign technology vendors, IT hardware suppliers, telecom equipment manufacturers, data center hardware providers, refurbished equipment sellers, and non-resident companies importing for U.S. projects without a domestic importer structure.

Documentation provided

After clearance: CBP entry summary (CBP Form 7501 equivalent), proof of duties and MPF paid, and delivery or warehousing confirmation for your internal records and audit trail.

FAQ

Common questions about importing to the United States

Clarifications on IOR structure, FCC scope, duty rates, and refurbished equipment.

Can a foreign company import into the United States without a U.S. entity?
In many cases, yes. Under 19 U.S.C. § 1484, the importer of record must be qualified to make entry, but a non-resident importer can act as IOR in certain structures. TFTIOR reviews each shipment to determine the correct importer arrangement, consignee setup, and customs broker configuration before the cargo moves. For a detailed breakdown, see our Importer of Record page.
What does "reasonable care" mean for the importer of record in the USA?
Under 19 U.S.C. § 1484(a)(1), the importer of record must use reasonable care in making entry: correct HTS classification, accurate declared value, country of origin documentation, and any required agency disclosures. It is a legal standard, not an administrative suggestion. Incorrect classification or missing agency declarations can result in CBP penalties and post-entry audits months after the shipment clears.
Do wireless or telecom devices need FCC review before importing into the USA?
Yes, in most cases. Under 47 CFR Part 2, a radio frequency device may only be imported into the United States if the importer or consignee can confirm that the device meets one of the permitted entry conditions under FCC rules. Wi-Fi, Bluetooth, cellular, RFID, and satellite-enabled equipment falls under this scope, including refurbished or modified devices. CE marks do not satisfy FCC import requirements. TFTIOR checks FCC scope before every IT and telecom hardware shipment is accepted.
What import duties apply to IT hardware imported into the United States?
Standard HTSUS duties on IT hardware (Chapters 84-85) are generally 0 to 3.5% for servers, switches, storage systems, and related equipment. Section 301 tariffs on China-origin goods can add 7.5 to 25% on top, depending on the HS code and whether any active exclusion applies. The United States does not apply a federal VAT; state sales tax is not assessed at the border. Always confirm HTS classification and origin before committing to a shipment structure. CBP basic import guidance.
Can TFTIOR support refurbished equipment imports into the United States?
TFTIOR can support selected refurbished and used technology equipment imports into the United States, subject to product-level review. Condition must be correctly declared on the commercial invoice. Wireless and FCC-regulated equipment requires additional pre-import checks regardless of whether it is new or refurbished. Medical devices, environmental-sensitive goods, and restricted products require separate review before acceptance.
Do you offer warehousing in the United States?
Yes. TFTIOR can support Miami-based warehousing options for temporary storage, staged release, consolidation, and project-based delivery coordination after customs clearance. This is available for eligible shipments and is designed for technology suppliers, spare parts programs, and companies using the U.S. as a logistics point for domestic or LATAM-facing operations.
Is customs clearance guaranteed?
No. Responsible IOR support is not guaranteed clearance. Import eligibility depends on product type, HTS classification, declared value and origin, equipment condition, and whether FCC, FDA, or EPA requirements are met. TFTIOR's approach is to identify problems at the review stage rather than at the U.S. border. We don't take on shipments we cannot clear responsibly.
What information does TFTIOR need to review a USA import?
At minimum: product description and technical datasheet if available, commercial invoice, packing list, country of origin, declared value, equipment condition (new, used, or refurbished), intended use, consignee details, and HTS code if known. For wireless or telecom-enabled equipment, FCC ID or technical specifications are also needed.