A shipment of Thai food supplements left Laem Chabang on time, arrived in Los Angeles on time, and then sat. The paperwork named a buyer, the consignee named a warehouse, and nobody in the file was the importer of record for that entry. The cargo was not late; the entry was incomplete.
This is the rule worth understanding before you compare rates on a Southeast Asia–US lane: a US entry needs an importer of record — a party in the United States, with a tax number, that accepts legal responsibility for the entry — and that importer must be covered by a customs bond sized to the duty and fees on the goods.
The rule, in one paragraph
The importer of record (IOR) is the party CBP holds responsible for the accuracy of the entry, the duty, and compliance with the rules that apply to the goods. The bond is the financial guarantee behind that responsibility: a continuous bond that renews annually, or a single-entry bond for one shipment. Neither the forwarder nor the carrier can be the IOR by default; someone has to actually take that position, and it has to be a party entitled to do so.
Three ways sellers handle it
- The buyer is the IOR: normal under FOB, CIF and DDU. Cleanest liability, and the buyer needs its own bond and broker.
- The seller has a US entity: under DDP this is the arrangement that actually matches the paperwork. The US entity holds the bond and signs the entry.
- A third-party IOR service is used: workable for parcels and testing a market, but the service signs for customs purposes only. Product compliance, AD/CVD exposure and recalls stay with the seller — and a third-party IOR that cannot see your supply chain will refuse the file the moment a case becomes complicated.
A DDP price does not move the liability. It only decides who writes the cheque. If your DDP quote is built on somebody else’s bond and somebody else’s importer number, ask what happens the day CBP questions the value or the origin — because that question is addressed to the IOR, not to you.
How the bond is sized
A continuous bond is set around your annual duty and fees; the common working figure is roughly 10% of the previous year’s total, with a floor that most brokers will quote at around USD 50,000. A single-entry bond is priced per shipment against value plus duty and fees. A first shipment from Thailand or Vietnam often goes out on a single-entry bond, then moves to a continuous bond once the volume is predictable — the annual one is cheaper per entry and stops the recurring paperwork.
Ask your broker for the figure rather than the formula: the amount is set by the surety and the broker, and it changes with the commodity mix, not only with turnover.
Case one: Thai supplements, and the FDA file
Food and supplements add a second requirement on top of the entry: prior notice and, where applicable, an FDA registration tied to the facility. What we see go wrong is a mismatch — the entry filed under one company, the FDA registration under another, and a hold that neither side can lift alone. If the seller’s DDP arrangement uses a third-party IOR, that IOR must also be able to answer an FDA question about the product, or the file stalls at the port.
Case two: Vietnamese furniture, and AD/CVD
Furniture from Vietnam is the classic example of a case where the IOR matters more than the freight rate. When an AD/CVD order covers the product, the importer of record posts the cash deposit and carries the retroactive risk if the scope or the origin is later disputed. That is why third-party IOR services decline these files and why a seller running DDP without a US entity struggles to place them: the bond follows the risk, and the risk is not the forwarder’s to take.
Does the lane change any of this?
Not the requirement. Direct services from Laem Chabang or Cai Mep to the US west coast, transhipment through Port Klang or Singapore, or an air lane into Chicago all end at the same place: an entry, an IOR and a bond. What changes is the documentation in between — a transhipment adds a second set of handling records and makes the origin story something you have to be able to prove, not just state. If the product has a tariff or origin question attached to it, a direct lane removes one moving part.
The other direction, briefly
US machinery and equipment moving to Thailand or Vietnam runs the same question in mirror: the US exporter files the Electronic Export Information where the value or the licensing rules require it (goods above USD 2,500 in value, or controlled items, are the usual trigger), and the import side is handled by the consignee’s own importer position and bond in that country. DDP on the US side does not make the US seller the Thai importer.
Four questions before you book
- Who is named as importer of record on this entry, and whose bond covers it?
- If it is a third party, what will it do when CBP questions value, origin or scope?
- Does the commodity carry an FDA, AD/CVD or other requirement that lands on the IOR?
- Is a single-entry bond enough for this shipment, or is the annual volume already past that point?
None of this is exotic; it is simply the part of a DDP quote that is invisible until something goes wrong. Send us the commodity and the lane and we will tell you which of the three arrangements fits, and what the bond will look like before the first container is booked.