Who Is an “Importer”?
The definition of “importer” reaches further than many companies expect. Here is who counts, and a quick checklist to see whether it includes you.
Before you can decide whether an import-related reporting obligation applies to you, it helps to know whether you count as an importer in the first place.
The Definition
An importer is anyone who imports chemical substances, mixtures, or articles into the 50 states, the District of Columbia, and Puerto Rico, including:
- The party liable for customs or import duties
- An authorized agent
- A consignee
- The importer of record
- The actual owner
- The transferee
You Might Be an Importer If…
For any given chemical substance, mixture, or article, you:
- Had to deal with customs, such as filling out forms, filing declarations, and paying duties
- Have hired a customs agent, or have been a customs agent yourself
- Are listed in the shipping documents as the recipient of the shipment
- Assumed possession, legal responsibility, or title once the shipment arrived
- Have submitted a declaration or provided a special bond to customs authorities
- Are working with or through a bonded warehouse
If any of these describe you, it is worth reviewing which import-related obligations may apply to your business, including PFAS reporting under US TSCA Section 8(a)(7). See compliance tools built for distributors if importing is part of a broader distribution role.