Record Keeping Requirements for Importers


Importers of Record (IOR) are required by CBP and the Mod Act to have proper records on file for all import shipments into the territory of the United States. These records pertain to any of the following activities, filing a drawback claim, any importation, declaration or entry, transportation or storage of merchandise carried or held under bond into or from the customs territory of the United States, the collection and payment of fees and taxes to CBP and any other activity required to be undertaken pursuant to laws or regulations administered by CBP. All importers are required to follow the requirements that are outlined in the Informed Compliance publication issued but CBP (ICP – Recordkeeping ( or the 19 CFR 163 (eCFR :: 19 CFR Part 163 — Recordkeeping).

This publication will explain what every importer needs to ensure is put into place to be complaint with all of their import shipments should CBP request at any time documentation of any shipment within the required time outlined.

If this is not already implemented within your company and enforced this could lead to penalties that can be issued to you as the IOR that can be hefty penalties. CBP can assess an administrative penalty for each release of merchandise not to exceed $100,000 or an amount equal to 75% of the appraised value of merchandise for failure to maintain, store or retrieve a demanded record. If you fail to produce records to CBP at time of request due to negligence of maintaining, storing or retrieve a demand record, CBP can assess a penalty for each release of merchandise, not to exceed $10,000 or an amount equal to 40% of the appraised value of merchandise, whichever is less.

It is recommended that you read through this Informed Compliance publication that is presented by CBP to help you understand the following.

  • What are records
  • What is required for recordkeeping
  • Who is subject to record keeping requirements
  • What original records need to be kept
  • What are the requirements for alternative methods of storage
  • How long are you required to keep certain documents
  • Recordkeeping compliance program

Following the guidance provided in this Informed Compliance publication will help to ensure you are being compliant with CBP in the event of a customs audit or if customs sends you a request for information that must be provided to them.

As a Customs broker we are also required to follow these same guidelines and if you should have additional questions regarding this or need help with implementing this within your company Juno Customs Solutions can assist you with this. If you would like to know more about this please feel free to reach out to us for a consultation by emailing us at

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