The importer of record (IOR) is the entity named on CBP Form 7501 — the customs entry summary. This is the single most important eligibility criterion for IEEPA tariff refunds because only the IOR can claim a refund from CBP. Not the supplier. Not the freight forwarder. Not the customs broker. The IOR.
The February 2026 Supreme Court ruling in Learning Resources v. Trump (6-3 decision) struck down $166 billion in IEEPA tariffs as unconstitutional. The resulting refunds flow exclusively to the importer of record on each affected entry. Our eligibility checker evaluates IOR status as the first of four screening criteria precisely because it is the most fundamental qualification requirement.
How to check your IOR status
There are three ways to confirm:
1. Check any CF-7501 form. Pull a customs entry summary from the covered period (February 2025 through February 2026). Your company name and IOR number should appear in the designated field near the top of the form. This is definitive proof.
2. Ask your customs broker. One question: “Am I listed as the importer of record on my entries?” They can confirm instantly by checking their filing records.
3. Check your ACE portal. If you have access to CBP’s ACE Secure Data Portal, your IOR number is associated with your account. All entries filed under that number belong to you as the IOR. You can verify by running the ES-003 Entry Summary report, which lists the importer of record on every entry line.
Why IOR status is the first screening criterion
CBP’s refund mechanism — whether through post-summary correction, formal protest under 19 U.S.C. section 1514, or claims processed through the CAPE portal — requires the claimant to be the importer of record. This is not a policy choice; it is how customs law operates. Duties are assessed against the IOR, and refunds are paid to the IOR.
The four-criteria screening in our eligibility checker evaluates IOR status before examining country of origin, HTS code classification (9903.01 or 9903.02), or import volume. If you are not the IOR, the remaining criteria are moot for the purpose of a direct claim.
Common scenarios
You use a customs broker. In the vast majority of cases, you are still the IOR. The customs broker files entries on your behalf using your IOR number. They are the filer, not the importer of record. This is the most common arrangement for U.S. importers and does not affect your eligibility.
You use a freight forwarder. Check who is listed as IOR on the customs entry. Some freight forwarders import under their own IOR number, especially for consolidation shipments or LCL (less-than-container-load) arrangements. If they are the IOR, the refund belongs to them, not to you.
You buy from a domestic supplier who imports. If your supplier imports the goods and sells them to you domestically, they are the IOR — not you. You cannot claim the refund on their entries, even if the tariff cost was passed through to you in pricing.
You sell on Amazon FBA. If you import the goods yourself (your company is on the customs entry), you are the IOR. If Amazon imports them under their own IOR number, they are the IOR. See Amazon sellers and IEEPA eligibility for detailed guidance on FBA, FBM, and third-party import arrangements.
You are a sole proprietor. Sole proprietors who import under their own name or a DBA are importers of record. The eligibility criteria apply the same way regardless of business structure. Whether you are a sole proprietor importing $20,000 annually or a corporation importing $20 million, the IOR requirement is identical. See small importers qualify too for volume considerations.
What if you are not the IOR?
If another entity is the importer of record on your goods, you cannot claim the IEEPA tariff refund directly from CBP. However, you have several options:
Negotiate with the actual IOR. If the tariff cost was passed through to you in pricing, you may be able to negotiate a share of the refund with the entity that is the IOR. This is a commercial negotiation, not a customs matter.
Request the IOR to file on your behalf. The IOR is the only party that can file a protest or correction with CBP, but nothing prevents them from sharing the recovery with you contractually.
Check whether you are the IOR on other entries. Some importers use multiple shipping arrangements. You may be the IOR on some entries and not others. A thorough review of your CF-7501 forms or ES-003 report reveals the full picture.
The IOR number explained
Your IOR number is typically your EIN (Employer Identification Number) or, for individuals, your Social Security Number. It is the tax identification number associated with your customs bond. CBP uses this number to link all entry filings to a single importer.
If you have multiple EINs (common for companies with subsidiary structures), each EIN may have its own entry history. A comprehensive assessment examines entries across all related IOR numbers. The Impact Assessment at tariffresolution.com handles this complexity as part of the standard analysis.
Time sensitivity for IOR verification
Confirming your IOR status is a prerequisite for every recovery path. The 180-day protest deadline applies to liquidated entries regardless of when you discover your eligibility. Entries liquidated in late 2025 may have protest windows closing in mid-2026.
Check your eligibility to confirm your IOR status as part of the four-criteria screening process. If you need assistance verifying IOR status across complex entry structures, customs brokers and trade attorneys in the partner network at tariffpartners.com can coordinate directly with your broker of record.