Every step of a US import, in the order it happens

What this is

Your Employer Identification Number (EIN) is what identifies you to U.S. Customs and Border Protection (CBP), and it doubles as your importer of record (IOR) number. Most small importers already have one from forming the company. If you don't, apply before anything else here — several later steps depend on it.

What you need

• Your formed business entity (LLC, corporation, or sole proprietorship)
• Internal Revenue Service (IRS) EIN application — irs.gov

If it's missed

You cannot be named as the importer of record, which means you cannot legally make entry.

What this is

CBP Form 5106 registers you in CBP's system as an importer. Filing it on someone else's behalf is customs business, so only a licensed customs broker can do it for you. Raise it with your broker early — it is a common cause of first-shipment delays.

What you need

• Your EIN and formation documents
• A customs broker engaged and ready to file

If it's missed

No entry can be filed in your name, so nothing clears.

What this is

Quotes and samples. Nothing is committed yet and nothing can be checked yet, but record the exact registered legal name each factory quotes under. It is frequently not the name that appears on the eventual invoice.

What you need

No documents needed yet at this step.

If it's missed

You end up screening a trading name and never learn which legal entity you were actually dealing with.

What this is

The forced-labor rules work on a rebuttable presumption with no minimum threshold: goods traceable to a listed entity are presumed to be made with forced labor and barred, and you carry the burden of proving otherwise. A sanctions match behaves differently again — it can freeze the payment rather than the cargo. Brokers price per entry and do not include this for small accounts.

What you need

• The supplier's full registered legal name
• Country, and city or province if you have it
• A description of what you are importing, or a Harmonized System (HS) code

If it's missed

Cargo is detained and then excluded or seized, with a 30-day window to produce a traceability package. A sanctions hit can also freeze related bank transfers.

What this is

The entity that quotes you, the entity that manufactures, and the entity that invoices are frequently three different registered names. A clean screening record for the wrong company does not answer the question you will be asked.

What you need

• Proforma invoice — the preliminary bill of sale a factory sends before shipping; compare the legal name on it, not the trading name
• The factory's business licence, if they will provide one

If it's missed

Your screening record names a company you never did business with, which is the same as not having screened at all.

Tools that help

What this is

A continuous bond is worth it above roughly four or five shipments a year; below that a single-transaction bond is usually cheaper. It is sized at 10% of your prior year's duties, taxes and fees, with a $50,000 minimum. Your broker arranges it through a surety.

What you need

• Your EIN and importer identity on file with CBP
• An estimate of annual duties — your broker can model this

If it's missed

Cargo is not released. Separately, if tariffs push your trailing-year duties past the 10% threshold, CBP can find the bond insufficient mid-year and stop releases until it is increased.

What this is

Standard paperwork, and your broker will send it. Worth understanding what it does: it authorises them to act as your agent in filing. The duty to exercise reasonable care over what is filed stays with you and cannot be delegated.

What you need

• The POA form your broker provides
• Signing authority for the company

If it's missed

Your broker cannot act for you, so no entry can be filed.

What this is

Delivered Duty Paid (DDP) looks convenient because the factory arranges everything, including customs. It also obscures who the importer of record is, and a factory-nominated shell importer produces an entry you never see and cannot defend.

What you need

• A sales contract that names the importer of record explicitly
• Written confirmation of which party files the entry

If it's missed

An entry is filed under an importer identity you do not control, on terms you never agreed, and you may not learn of it until something goes wrong.

What this is

Most small purchase agreements contain no forced-labor representation and no indemnity, so the importer absorbs the whole risk with no recourse against the factory that caused it. This step is drafting, not checking: nothing you screen or file creates a claim against the factory, only the contract does. That is why it sits with a lawyer rather than with a tool.

What you need

• Your draft purchase agreement
• Your own lawyer, to write the wording

If it's missed

A detention becomes entirely your loss, with no contractual claim against the supplier.

What this is

Everything above is cheap before this moment and expensive after it. Paying the deposit moves you into production, where your remaining leverage is commercial rather than contractual.

What you need

• Proforma invoice
• Payment record — keep it five years with the rest of the entry file

If it's missed

Nothing here fails on its own. It is the step that makes every earlier omission permanent.

What this is

Children's products must be tested by a lab the Consumer Product Safety Commission (CPSC) has accepted before any certificate is valid. The factory usually arranges the testing, but the certificate is issued by you as the importer, not by the factory — a factory's own certificate counts only if the factory is itself the importer. Ask which lab and ask for the report, not just the summary.

What you need

• The name of the CPSC-accepted lab used
• The test report, and the date testing was performed

If it's missed

Any certificate you file is invalid, because it rests on testing that either did not happen or cannot be evidenced.

What this is

Which rules apply is decided by what the product IS, not by who you buy it from, and more than one agency usually applies to the same item. Your broker will surface a flag at entry, but a flag is not the same as being told in advance what you have to produce. The pattern below is the common case by product type — a starting point for what to go and confirm, not a determination.

Which rules apply

Housewares and kitchenware

U.S. Consumer Product Safety Commission (CPSC), plus the Food and Drug Administration for anything that touches food

Small electronics

Federal Communications Commission (Part 15), Department of Energy efficiency rules, and CPSC

Textiles and soft goods

CPSC on flammability and children's products, and the Federal Trade Commission on fiber content, RN number and care labels

Anything with a battery

CPSC, and the Department of Transportation as hazardous material

Packaged non-food goods

An Environmental Protection Agency import certification under the Toxic Substances Control Act

Anything with wood or plant content

A US Department of Agriculture Lacey Act declaration, filed electronically since January 2026

Every import, whatever it is

U.S. Customs and Border Protection (CBP) origin marking, permanently on the article

What you need

• Your product's Harmonized System (HS) code, or a description precise enough to find it
• What it is made of, what powers it, and who it is for

If it's missed

You discover the requirement when the shipment is already held, which is the most expensive moment to learn it.

What this is

The hard part of electronic filing is not the format, it is that you do not hold the data: manufacture date, manufacture place, test date and testing laboratory all sit with the factory, and a plain-English email asking for them frequently gets silence or an untranslated PDF. One piece you do not have to ask anyone for — the free check on the previous step names the CFR rules that apply to your code, so you can put them in the request rather than asking the factory which rules it tested against. Start this early and in writing, because it gates everything downstream.

What you need

• Product name and model, and the CFR safety rules it is certified against
• Manufacture date, and the manufacturer's name and address
• Last test date, and the testing laboratory's name and CPSC lab ID
• A named contact, with an address, who keeps the underlying test records

If it's missed

You cannot file at entry, and the shipment is held while you chase a factory across a time zone and a language barrier.

Tools that help

What this is

Registering a product once lets whoever files your entries reference short Registry identifiers — the Product ID and Version ID — instead of retransmitting every data element each time. Because the version only changes on retest or material change, this is roughly a once-per-product task rather than a recurring one. It is worth doing if you import the same product repeatedly.

What you need

• The four things from the previous step — they cover five of the filing's seven sections
• Your product's HS code, and your own company details as the certifying party — the two sections nobody else can give you
• An account on the CPSC Product Registry

If it's missed

Nothing fails, but every future shipment carries the full data-entry burden again, and each repetition is another chance to transpose something.

What this is

Goods must be marked with their country of origin so the final purchaser can see it, and the marking must survive normal handling. Depending on the product, other labels stack on top: fiber content and care labels for textiles, Federal Communications Commission (FCC) identifiers for electronics, energy labels for appliances. The factory applies these, but the exposure is yours.

What you need

• Written confirmation of how and where origin marking is applied
• Label artwork approved before the production run, not after
• Any product-specific labels for your category

If it's missed

A marking failure attracts an additional 10% duty and can trigger a demand to redeliver goods you have already received and possibly sold.

What this is

This is the most commonly misunderstood deadline in the whole process. The security filing is due at least 24 hours before the container is loaded onto the vessel overseas — before departure, not before arrival in the US. Your broker or forwarder transmits it, but the responsibility to see it filed accurately stays with you.

What you need

• Your broker or forwarder engaged, and the filing confirmed in writing
• The sailing date, so you can check the filing preceded loading
• Supplier and shipment details as requested by whoever files it

If it's missed

Liquidated damages of up to $5,000 per violation, and if the vessel has already sailed the filing is late by definition and cannot be rescued.

What this is

Cargo insurance is a separate purchase from freight, and a total loss in transit is otherwise yours. If you are having the goods inspected, the inspection has to happen while you still hold the final payment — that is the only leverage you have.

What you need

• A cargo insurance policy or a rider on an existing one
• An inspection booked before the balance falls due, if you are using one

If it's missed

A total loss is uninsured, or you pay in full for goods whose defects you discover only after they arrive.

What this is

Your broker files for release ahead of the ship's arrival so the container can move as soon as it lands. This is the routine part of entry and usually passes without incident, provided the earlier data is right.

What you need

• Commercial invoice and packing list
• Bill of lading
• Your bond and importer identity already in place

If it's missed

The container sits at the terminal accruing storage charges until the filing is corrected.

What this is

Where any agency regulates your product — the Consumer Product Safety Commission (CPSC) most often, for consumer goods — its data is submitted into the entry system alongside the customs entry. Your broker submits it; they do not originate it, and they will not tell you in advance what it has to contain. Everything submitted here came from the certificate data gathered during production, which is why that step lands so much earlier than it feels like it should.

What you need

• The certificate data, or your Registry identifiers — the free check names the CPSC rules for your code, and the filing tool turns the answers into those identifiers
• Confirmation from your broker of which agency sets apply to your codes

If it's missed

The shipment is held at the port until the data is supplied, and the hold is recorded against your filing history.

Tools that help

What this is

Release gets your goods moving; the entry summary is the formal declaration of what they are and what is owed. It follows within ten working days, and the duties are paid with it. Read it before it is filed — it declares your classification, value and origin, and those are your representations, not your broker's.

What you need

• Your broker's draft entry summary, reviewed before filing
• Funds in place for duties, taxes and fees

If it's missed

Late filing draws liquidated damages, and unpaid duties accrue interest.

What this is

Examinations range from an X-ray of the sealed container to full unloading and inspection of the contents. You pay the costs either way, including unloading, haulage and storage, and a clean result does not reimburse you. Customs may also send written requests for information or notices of proposed duty changes, and both need answering.

What you need

• Prompt responses to any written request from U.S. Customs and Border Protection (CBP)
• Budget headroom — an intensive exam is the expensive one

If it's missed

Costs accumulate daily while the container waits, and an unanswered request can turn a question into a reassessment.

What this is

This is the detention the earlier screening step exists to avoid: goods traceable to a listed entity are presumed to be made with forced labor, you have thirty days to document the supply chain back to raw materials to a clear and convincing standard, and the burden is entirely yours. Assembling that package after the fact is far harder than screening was beforehand, and a screening record made before you contracted — naming what was searched, and when — is the strongest thing in it. Shipments are held for other reasons too — an examination, missing agency data, an antidumping scope question, all covered by the steps above — but this is the only hold that starts with a presumption against you.

What you need

• Purchase orders, invoices and payment records for every tier
• Transportation records tracing the goods and their inputs
• Production records from the factory, and its own suppliers
• Counsel experienced in forced-labor detentions

If it's missed

The goods are excluded or seized, and you carry the loss plus the freight and storage already spent.

Tools that help

What this is

A drayage trucker moves the container from the terminal to you, usually booked through your freight forwarder — but the booking is yours to make, and nobody does it on your behalf. Two clocks run at once and they are different charges: demurrage while the container sits at the terminal, and per-diem once you are holding it off-site. Two things are routinely underestimated — whether your address can physically take a container and its chassis, and who is going to unload it.

What you need

• A drayage trucker booked, usually through your forwarder
• An address that can take a container and a chassis, or a liftgate delivery booked instead
• Labor arranged for unloading, and somewhere to put the goods

If it's missed

Daily charges accumulate on a container nobody can unload, which is the most avoidable cost in the entire process.

What this is

You must keep records relating to the entry for five years and produce them on request. Your broker keeps their own copies, but that is their obligation and does not discharge yours. Keep your own set from the first shipment; reconstructing it years later is far harder.

What you need

• Entry documents, invoices, packing lists and payment records
• Screening records and any certificates you filed
• Correspondence evidencing what you asked suppliers and what they answered

If it's missed

A request arrives years later and you cannot answer it, which converts a routine question into an enforcement problem.

What this is

Most first-time importers assume the entry is closed once the container is unloaded. It is not — it stays open until it liquidates, typically several months later and up to a year by statute. While it is open you can correct it; once it closes, your options narrow to a formal protest within a fixed window.

What you need

• A note of your entry numbers and dates
• A review of anything you were unsure about at the time

If it's missed

A correctable error hardens into a final assessment, and the cheap fix is no longer available.

What this is

Telling customs about an error yourself, before they find it, substantially reduces the penalties that would otherwise apply. The option disappears the moment they open an inquiry. Enforcement in this area has grown sharply, and competitors can and do initiate cases about a rival's import practices.

What you need

• The facts of what went wrong, and which entries it affected
• Counsel — the timing and framing of a disclosure matter

If it's missed

The same error found by customs rather than disclosed by you carries materially higher penalties.

What this is

Clearing customs is a federal matter; selling the goods is governed where you sell them, and those rules vary by state. The pattern that catches importers out is brand ownership: several states treat whoever puts their own brand on a product as its manufacturer, with registration and recycling duties attached, even though the goods were made overseas. Sales tax registration is separate again and easy to overlook because it has nothing to do with importing.

What you need

• Sales tax registration in the states where you sell
• A check of your own state's rules for your product category
• For example, in New York, electronics sold under your own brand can trigger registration before you begin selling

If it's missed

You sell for months before discovering a registration you should have completed first, and the fix is retroactive.

What this is

Selling through a marketplace like Amazon is its own gate, separate from clearing customs. For a children's product the marketplace asks for the safety certificate, and often the test report behind it, and a listing is held or pulled when the certificate names a different product, an unaccredited lab, or the wrong certificate type. The paperwork that cleared the shipment is not automatically the paperwork the marketplace will accept.

What you need

• The Children's Product Certificate (CPC) and the test report behind it
• The listing details — model, brand and age grade — matching the certificate
• The commercial invoice for the goods being listed

If it's missed

The listing is blocked or taken down until the documents line up, after the goods have arrived and been paid for.