Importer Onboarding, POA, and Bond Readiness Checklist
Importers & NVOCCs
Setting up an import operation correctly before the first shipment arrives is far less disruptive than correcting it while cargo is in transit or under CBP review. This checklist covers every step required: signing the right power of attorney, confirming your importer of record identity, placing the appropriate bond, and ensuring your first shipment documents are complete. NVOCCs managing new importer clients will find this useful for onboarding each customer account before their first filing.
Power of Attorney
- CBP-acceptable power of attorney completed and signed — CBP Form 5291 or a commercial POA that meets CBP requirements and is acceptable to your broker
- Signatory is authorized to bind the company — must be an officer, partner, or authorized employee per CBP requirements; not a forwarding agent or third party
- POA covers the correct scope — entry filing, ISF filing, or both — confirmed with your broker before the first shipment
- POA is on file with the customs broker before the first shipment departs origin — not during transit or after arrival
- If a continuous bond is in place, confirm the bond covers the same parties and scope as the power of attorney
Importer Identity and Business Information
- Full legal business name confirmed — must match IRS records exactly for CBP Importer of Record registration
- IRS/EIN confirmed and available — required for CBP Importer of Record number assignment
- Physical U.S. business address confirmed — P.O. box is not sufficient for IOR registration
- CBP Importer of Record number assigned or application in process with your customs broker before first shipment
- Ultimate consignee identified if different from the importer of record — both parties must be disclosed on the CBP entry
Customs Bond
- Bond type determined: continuous bond (recommended for 3 or more imports per year or annual duty exposure above $50,000) or single-entry bond
- Continuous bond amount sufficient for anticipated duty and fee liability — generally 10% of annual duties, taxes, and fees, with a $50,000 minimum
- Bond application submitted to a CBP-approved surety and bond placed with CBP before the first entry is filed
- Bond covers the correct parties — importer of record named as principal, customs broker named as attorney-in-fact
- Surety company confirmed on CBP's current approved surety list — not all surety companies are CBP-approved
First Shipment Document Readiness
- Commercial invoice: seller name and address, buyer name and address, full description of goods, quantity, unit price, country of origin, and Incoterms
- Packing list: carton count, gross and net weight, dimensions, and line-item quantities — must match the commercial invoice
- Bill of lading or airway bill identifying the shipper, consignee, and carrier with the correct legal party names
- HTS code provided or confirmed with your customs broker before entry filing — do not rely solely on supplier-provided HS codes without review
- Required partner agency documentation obtained before cargo departs origin — FDA prior notice, USDA permit, FCC declaration, or other applicable agency requirements
- Arrival notice received from the ocean carrier or NVOCC before cargo arrives at the U.S. port
Ongoing Compliance Setup
- Recordkeeping: CBP requires importers to retain entry documents, invoices, and supporting records for 5 years from entry date under 19 CFR 163.4
- ISF responsibility confirmed in writing: who files ISF, on whose behalf, and who is responsible if data is late or incomplete
- HTS classification responsibility established: who determines codes, who verifies them, and how often active codes are reviewed
- Duty payment process established: who handles duty disbursement and how that cost is tracked and invoiced back to the importer
- CBP binding ruling considered for high-value, high-volume, or classification-dispute-prone products — provides certainty and audit protection (CBP Form 177)