Importer of Record UK: Requirements for Ecommerce Sellers

Updated October 2026

An Importer of Record (IoR) in the UK is the legal entity HMRC holds responsible for goods entering the country. The IoR files customs declarations, pays import VAT and duties, holds a UK EORI number, and ensures every shipment complies with UK product safety, labelling, and trade regulations. If you are a US or EU brand selling into the UK through TikTok Shop, Amazon, or your own DTC site, you either need to act as IoR yourself (which requires a UK entity, UK VAT registration, and a UK EORI) or appoint a licensed third party to do it for you.

TL;DR

• The Importer of Record is the party HMRC treats as legally liable for every import declaration, duty payment, and compliance obligation at the UK border.

• Foreign sellers cannot act as IoR without a UK EORI number, which requires UK VAT registration first.

• An IoR is not the same as a customs broker. A customs broker files paperwork on your behalf; the IoR carries the legal liability.

• A Merchant of Record that includes IoR (like CRSSBRDR) collapses entity, VAT, EORI, and customs clearance into one relationship.

• Getting IoR wrong turns import VAT into a sunk cost: HMRC only allows the goods owner to reclaim import VAT, and only if the customs documentation names the correct party (HMRC VIT13300, 2020).

What is an Importer of Record in the UK?

An Importer of Record is the individual or legal entity that HMRC recognises as the importer of goods on a UK customs declaration. The IoR takes full responsibility for:

1. Filing accurate customs declarations via the Customs Declaration Service (CDS), which replaced CHIEF for all UK imports as of 2024 (GOV.UK, CDS migration).

2. Paying customs duties and import VAT. UK import VAT is charged at 20% on the customs value plus duty. Postponed VAT Accounting (PVA) allows the IoR to account for import VAT on their VAT return rather than paying it at the border.

3. Holding a valid GB EORI number. Every IoR must have an EORI beginning with GB. Without it, goods cannot clear customs.

4. Ensuring product compliance. The IoR must confirm goods meet UK safety, labelling, and regulatory requirements before release.

5. Maintaining records for six years. HMRC can audit import records going back six years from the date of the declaration.

The IoR is not a freight forwarder, not a courier, and not the warehouse receiving the goods. It is the party whose name appears in Box 8 (consignee/IoR) of the CDS declaration, and it is the party HMRC contacts when something is wrong.

CRSSBRDR™ is the only MoR built by a licensed accountant and a founding TikTok Shop Partner agency. We get US and EU brands live on TikTok Shop UK in 7 to 10 business days. £100M+ in ecommerce sales driven. Compliance built in, growth switched on.

Why do ecommerce sellers need an Importer of Record for the UK?

Every physical product entering the UK must have a named IoR on the customs declaration. There are no exceptions for ecommerce, marketplace sellers, or low-value goods.

Before Brexit, EU sellers shipped goods freely into the UK under the single market. That ended on 1 January 2021. Since then, every shipment from the EU to the UK requires a full customs declaration, an EORI number, and a named IoR, exactly the same as shipments from the US, China, or anywhere else.

For ecommerce sellers specifically, the IoR requirement matters for three reasons:

1. VAT recovery depends on it. HMRC's published policy (Revenue and Customs Brief 2/2019, clarified in Brief 15/2020) is that only the owner of the goods can reclaim import VAT. If your freight agent or a third party appears as IoR and claims the import VAT, HMRC can reject your reclaim and pursue the duplicate deduction. For high-volume sellers, this turns 20% import VAT into a direct cost.

2. Border delays kill conversion. A shipment without a valid EORI or with an incorrect IoR declaration gets held. Customs processing times for incomplete declarations average 3 to 5 additional working days according to the Border Operating Model. For TikTok Shop sellers using Fulfilled by TikTok (FBT), delays mean stock-outs and lost sales velocity.

3. Liability sits with the IoR. If goods are misdeclared, if duties are underpaid, or if prohibited items enter the UK, HMRC pursues the IoR. Penalties for inaccurate declarations range from 0% to 100% of the potential lost revenue, depending on whether HMRC considers the error careless or deliberate (Finance Act 2007, Schedule 24).

What are the requirements to act as Importer of Record in the UK?

To act as your own IoR, you need four things in place before your first shipment:

UK VAT registration. Non-resident sellers have no VAT threshold. HMRC classifies you as a Non-Established Taxable Person (NETP), and your registration obligation starts from your first UK supply. Processing time for overseas applicants: 4 to 8 weeks (GOV.UK, VAT registration).

GB EORI number. You can only apply for a GB EORI once your UK VAT registration is active. HMRC typically issues EORI numbers within 5 to 7 working days of the application. The EORI format is GB followed by your 9-digit VAT number plus 000 (GOV.UK, Get an EORI number).

UK entity or branch. While HMRC can issue a VAT number to a non-established overseas entity, TikTok Shop UK requires a UK-registered company (Ltd) to open a seller account. For brands selling on TikTok Shop, the entity requirement is non-negotiable.

Customs software or broker access. All UK import declarations must be filed through CDS. Most ecommerce sellers use a licensed customs broker to file declarations on their behalf, but the legal liability remains with the IoR regardless of who submits the declaration.

The sequential dependency is what catches most brands. You cannot get EORI without VAT. You cannot get VAT without understanding your entity position. Each step queues behind the last.

What is the difference between an Importer of Record and a customs broker?

A customs broker files import declarations on your behalf. An Importer of Record carries the legal liability for those declarations.

Many ecommerce sellers confuse the two. They appoint a freight forwarder or courier as their "importer" without realising the freight forwarder is acting as customs broker, not as IoR. When HMRC has questions six months later, the seller discovers they were the IoR all along, with no records, no EORI, and no VAT recovery trail.

What is the difference between an Importer of Record and a Merchant of Record?

This is the question most cross-border ecommerce sellers should be asking but rarely do.

An IoR gets your products past the border. An MoR gets your products past the border, sells them to UK consumers as the legal seller, handles VAT collection and remittance, processes payments, and manages chargebacks.

For brands selling on TikTok Shop UK, you need both. A standalone IoR gets your stock into the country, but you still need a UK entity, UK VAT registration, and a UK bank account to open the seller account.

CRSSBRDR acts as both MoR and licensed IoR. One contract covers the entity, VAT, EORI, customs clearance, and seller account. That is why brands go live in 7 to 10 business days instead of 8 to 12 weeks.

How much does an Importer of Record cost in the UK?

IoR costs vary significantly based on the provider model:

Standalone IoR service: £500 to £2,500 per month, plus a per-shipment fee of £50 to £150. This covers customs declarations and IoR liability but not VAT registration, entity setup, or seller account management.

Customs broker with IoR add-on: £100 to £300 per declaration. Some brokers offer to act as IoR for an additional fee, but check their liability coverage carefully. If the broker's insurance does not cover your product category, you carry residual risk.

MoR with included IoR (CRSSBRDR model): 2.5% to 5% of GMV. IoR is included alongside entity, VAT, EORI, compliance, and seller account management. No separate customs fees.

The hidden cost most brands miss is VAT recovery failure. If your IoR arrangement is structured incorrectly, you cannot reclaim 20% import VAT. On £100,000 of imported stock, that is £20,000 in unrecoverable VAT, a cost that dwarfs any IoR service fee.

What happens if you import without a proper IoR?

Three scenarios, all expensive:

Scenario 1: Goods held at the border. Without a valid EORI on the declaration, HMRC's CDS system rejects the submission. Your goods sit in a bonded warehouse, accruing storage fees of £15 to £50 per day per pallet.

Scenario 2: Freight forwarder acts as IoR without authority. The goods enter the UK, but the freight forwarder's EORI is on the declaration. Import VAT is charged to their account. You cannot reclaim it because HMRC's policy requires the goods owner to be named as IoR for valid VAT recovery. The freight forwarder has no obligation to pass the C79 certificate to you.

Scenario 3: Retrospective HMRC audit. HMRC discovers your import declarations were inaccurate or that duties were miscalculated. They can issue a C18 post-clearance demand for underpaid duty and VAT going back three years (or longer in cases of fraud). Penalties under Schedule 24 of the Finance Act 2007 can reach 100% of the duty shortfall.

Over 320,000 UK businesses imported goods in 2024, a 3% increase on the prior year (HMRC Customs Importer and Exporter Population, 2024). HMRC's shift to the CDS platform has given them significantly better data visibility, and enforcement is increasing.

How does Postponed VAT Accounting work for the IoR?

Postponed VAT Accounting (PVA) is one of the few advantages the post-Brexit import regime offers ecommerce sellers.

Under PVA, the IoR does not pay 20% import VAT in cash at the border. Instead, they account for it on their next VAT return: declaring import VAT in Box 1 and simultaneously reclaiming it as input tax in Box 4 (subject to normal partial exemption rules).

The net cash impact is zero, provided the IoR is UK VAT-registered and using PVA correctly.

To use PVA:

1. The IoR must be UK VAT-registered.

2. The customs declaration must include the IoR's own EORI number.

3. The declaration must specify PVA as the method of payment for import VAT (Additional Procedure Code 1CPC on CDS).

4. The IoR must download their Monthly Postponed Import VAT Statement from the CDS portal and reconcile it with their VAT return.

Without PVA, the IoR pays 20% import VAT at the border and waits until the next VAT return to reclaim it. On a £200,000 shipment, that is £40,000 tied up in cash flow for up to three months.

How do you appoint an Importer of Record in the UK?

Three routes, depending on your commercial model:

Route 1: Act as your own IoR. Register a UK Ltd, get VAT-registered, obtain a GB EORI, appoint a customs broker to file declarations under your EORI. Timeline: 8 to 12 weeks. Cost: £15,000 to £40,000 in year one including entity setup, accounting, and compliance.

Route 2: Appoint a standalone IoR service. A third-party company acts as IoR on your declarations. They use their own EORI and account for import VAT. You retain ownership of the goods but the IoR carries the customs liability. Check that the arrangement allows you (as goods owner) to reclaim import VAT, as HMRC's rules on this are strict.

Route 3: Use an MoR that includes IoR. CRSSBRDR acts as both Merchant of Record and Importer of Record. The entity, VAT, EORI, customs clearance, and seller account are all handled through one licensed structure. Timeline: 7 to 10 business days to first sale.

For TikTok Shop sellers, Route 3 is the fastest path. Route 1 gives you full control but takes months. Route 2 solves customs but leaves the entity, VAT, and seller account problems unsolved.

IoR requirements checklist for UK ecommerce sellers

Use this checklist before your first UK import. Every item is mandatory.

The DIY route requires you to complete items 1 through 5 in sequence. Each step depends on the previous one. Total elapsed time: 8 to 12 weeks before your first import.

Frequently asked questions

Can a non-UK company act as Importer of Record in the UK? Yes, but it needs a UK VAT registration and a GB EORI number first. HMRC issues VAT numbers to overseas entities, though processing takes 4 to 8 weeks for non-resident applicants. Without a UK entity, TikTok Shop UK will not open a seller account, so the VAT and EORI solve customs but not marketplace access.

Is the Importer of Record the same as the consignee? Not necessarily. The consignee is the party receiving the goods. The IoR is the party legally responsible for the import declaration. They can be the same entity, but in many ecommerce arrangements (especially FBA and FBT), the consignee is the warehouse and the IoR is the seller or their appointed representative.

Do I need an IoR for goods under £135? For consignments valued at £135 or less sold to UK consumers, the online marketplace or the overseas seller collects and remits VAT at the point of sale under the UK's Low Value Consignment rules. Customs duty is not charged. However, a customs declaration is still required, and someone must act as IoR on that declaration.

Can my freight forwarder act as my IoR? Some freight forwarders offer IoR services, but many act only as customs brokers (filing declarations under your EORI). Confirm in writing whether the freight forwarder is accepting IoR liability or simply acting as your agent. If they are acting as agent, you remain the IoR.

How long does it take to set up an IoR in the UK? DIY: 8 to 12 weeks (entity, VAT, EORI, broker, sequentially). Standalone IoR service: 2 to 4 weeks. MoR with included IoR (CRSSBRDR): 7 to 10 business days.

What records must the IoR keep? Import declarations, invoices, packing lists, certificates of origin, product compliance certificates, duty and VAT payment records, and PVA monthly statements. HMRC can request these for up to six years from the date of importation.

What is the penalty for incorrect import declarations? Penalties under Schedule 24 of the Finance Act 2007 range from 0% (prompted, unprompted disclosure of a careless error) to 100% of the potential lost revenue (deliberate and concealed errors). HMRC can also issue C18 post-clearance demands for underpaid duty.

CRSSBRDR acts as licensed Importer of Record and Merchant of Record for US and EU brands selling on TikTok Shop UK. Get started in 7 to 10 business days.