Quick answer. When you import products from China to sell on Amazon, your business (or a non-resident importer you set up through a broker) must be the importer of record, because Amazon says it will not act as importer of record for any FBA shipment. The importer of record files the entry, pays duties, taxes and fees, and may need a customs bond. Ocean freight needs an Importer Security Filing, with most data due 24 hours before the container is loaded in China. Each product needs an HTSUS classification, which sets the duty and shows whether Section 301 duties on products of China apply. Goods must carry a country of origin marking that matches your listing. Keep entry records for 5 years, because the same paperwork later proves your supply chain to Amazon.

Most sellers importing from China focus on the factory, the samples and the freight quote. The customs side arrives from a forwarder as a list of terms such as IOR, bond, ISF, HTS and 7501, and it is tempting to tick whatever box gets the container moving. That works until a shipment is held at the port or refused at the fulfillment center for collect charges, or until Amazon asks for invoices on an ASIN and the only paper you have is a pro forma from a factory sales rep.

The customs steps below follow what U.S. Customs and Border Protection (CBP), the Code of Federal Regulations, the U.S. Trade Representative (USTR) and Amazon’s Seller Central pages say. For the wider picture of China related selling, read our piece on Amazon and the Great Firewall of China. This is educational information, not legal or customs advice, and a licensed customs broker should confirm decisions for your goods.

Who is the importer of record when you ship from China to FBA

The importer of record (IOR) is the party responsible to CBP for an import. Amazon’s page on delivering imports to Amazon says an IOR is usually required when inventory enters the United States from another country, and that Amazon, including its fulfillment centers, will not act as IOR for any FBA shipment, of any size or value, regardless of origin and product. You may not leave the IOR field blank on the entry form, which Amazon says may get the shipment refused and returned.

What the importer of record is responsible for

Amazon lists three duties. The IOR makes sure the shipment complies with local laws and regulations, files an entry declaration with its documents, and pays import duties, taxes and fees. CBP’s tips for new importers add that even when you use a customs broker, you, the importer of record, are responsible for the correctness of the entry documents and for all duties, taxes and fees. Under 19 CFR 141.1, duty is a personal debt of the importer, and paying a broker does not relieve you if the broker does not pay. A broker moves the paperwork, not the responsibility.

CBP entry forms ask for an importer number, which is your IRS business registration number or a CBP assigned number requested on CBP Form 5106. CBP itself does not require an import license, though other agencies may for some goods.

Sellers based outside the United States

Amazon says shipments may be entered by a non-resident (foreign) IOR and tells sellers to ask their broker or carrier how to become one. Do not list Amazon. Amazon will not act as partner government agency (PGA) importer or consignee either, and says listing Amazon in those roles, or using an Amazon DUNS number, may lead to detention and seizure at the border and refusal or disposal of inventory at the fulfillment center.

Delivered Duty Paid, always

Amazon will not pay or collect duties, taxes or shipping costs for FBA inventory. All shipments must use Delivered Duty Paid (DDP) terms, and any shipment arriving with collect charges is refused without further concession. A cheaper collect quote from a forwarder saves nothing.

Customs bonds. What they secure and how CBP sizes them

A customs bond guarantees that the importer will pay what it owes and meet its obligations to CBP. Amazon says you may be required to obtain one as security for your shipments and suggests asking a broker whether you need it.

How the amount is set

Under 19 CFR 113.13, the minimum CBP bond is $100 unless a rule allows less. To judge sufficiency, CBP looks at your record of paying duties on time, complying with redelivery demands and honoring bond commitments, plus the value and nature of the goods, the supervision CBP will exercise, and your bond application. CBP’s Bonds page links its public guide on how it sets bond amounts.

CBP also reviews bonds periodically. If a bond is inadequate, CBP notifies the principal and surety in writing, and the principal has 15 days to remedy it. Until then, CBP may require extra security such as a cash deposit or a single transaction bond. If your volume or duty bill grows sharply, expect the bond question again.

The ISF connection

Under 19 CFR 149.5, the party responsible for an Importer Security Filing must hold one of the bond types listed there, such as a basic importation and entry bond. Ask your broker which structure covers both entries and ISF filings before your first ocean shipment.

See also The Risks of Selling Brands You Are Not Authorized to Sell on Amazon and Amazon Transparency Program.

If this is already affecting your Amazon account, our Amazon suspension team can review the notice and prepare the response with you.

Importer Security Filing (ISF 10+2) for ocean freight

CBP’s “10+2” rule took effect on January 26, 2009. CBP says it applies to cargo arriving by vessel, not other modes, and that failure to comply can mean monetary penalties, more inspections and delayed cargo.

When the data is due

Under 19 CFR 149.2, the seller, buyer, importer of record number, consignee number, manufacturer (or supplier), ship to party, country of origin and HTSUS number are due no later than 24 hours before the cargo is laden aboard the vessel at the foreign port. The container stuffing location and consolidator are due as early as possible and no later than 24 hours before arrival in a U.S. port. The clock runs from loading in China, so if the factory loads the day after production ends, you have no time unless the data was gathered when you placed the order.

What each element means for an Amazon seller

Under 19 CFR 149.3, the manufacturer, origin and HTSUS number must be linked at the line item level. When the ISF, invoice and entry summary name the same factory, origin and code for each item, your file is consistent.

HTS classification. The number that sets your duty

The Harmonized Tariff Schedule of the United States (HTSUS), published by the U.S. International Trade Commission, sets out tariff rates and statistical categories for all merchandise imported into the United States. It is based on the international Harmonized System.

How to classify without guessing

CBP’s tips page says an import specialist needs four facts to help you. They are the country of origin and manufacturer, the composition, the intended use, and pricing and payment information. Your broker needs the same. “Kitchen item” is not a basis for classification. “Stackable polypropylene food storage set with lids, for household use” is a start. Choose the code that describes the product, not the one with the lowest rate, because a code picked for its rate is hard to defend later.

Binding rulings and CROSS

Importers can request a binding ruling from CBP on classification and duty rate under 19 CFR Part 177. Search the Customs Rulings Online Search System (CROSS) first, which CBP says may already hold rulings on similar products, including on origin marking. Keep the rulings you relied on in the product file.

Section 301 duties on products of China, as CBP and USTR state them

Section 301 duties follow USTR investigations. USTR lists them on its website, including the investigation into China’s technology transfer practices behind the additional duties most China importers know. CBP collects these duties at entry and lists its guidance on its Trade Remedies page.

What CBP says about who pays them

• Origin decides. CBP’s Section 301 FAQ says the duties are based on country of origin, not country of export. Routing goods through another country does not change origin.
• Products of China only. CBP says they apply to products of the People’s Republic of China. Goods legitimately produced in Hong Kong or Macau are not subject.
• Sets follow necessary character. If a retail set is classified under a covered subheading, CBP says the entire set is subject.
• Exclusions are USTR’s process. CBP says importers can seek advice from a CBP Center of Excellence and Expertise, or a binding ruling, on whether goods fit an exclusion.

Where to find the current rate

We do not print a rate, because lists, rates and exclusions keep changing. CBP’s Trade Remedies page lists Section 301 guidance messages from 2018 through September 2026, including four year review changes and repeated exclusion extensions, and the USITC’s HTS site carries a “China Tariffs” document with each revision. Check each HTSUS number on every shipment. The same CBP page covers other measures, including Section 232 duties and IEEPA duties, and says CBP launched the CAPE tool in ACE on April 20, 2026 for IEEPA duty refund claims. Ask your broker whether past entries are affected, and assume nothing either way.

Low value shipments

CBP’s Section 301 FAQ says goods properly entered under the Section 321 de minimis provision are not subject to Section 301 duties. That rule has shifted. CBP’s e-commerce page says it has published interim final rules suspending the de minimis exemption for international mail. Confirm any low value route with your broker against current CBP guidance before relying on it.

Related guide. Amazon Restricted Products.

Country of origin marking and your Amazon listing

Origin appears on the product, in your customs filings and on your listing, and all three must agree.

What the marking rule requires

Under 19 CFR 134.11, unless excepted by law, every article of foreign origin (or its container) must be marked in a conspicuous place, as legibly, indelibly and permanently as the article allows, with the English name of the country of origin, for the ultimate purchaser in the United States. Section 134.41 says the marking must survive normal distribution and store handling and be easy to find and read, and suggests marking worked in at manufacture, such as molding. A sticker that falls off inside a polybag does not meet that standard. Put the marking in your purchase order and check it at inspection.

What Amazon expects on the listing

Amazon defines origin as where the product was produced or, if several countries were involved, where it underwent its last substantial transformation, and notes that some product types follow more specific rules. Entering the correct origin for each listing is your responsibility, and if you are unsure, ask the supplier or manufacturer. Amazon’s FAQ adds four points. Each listing takes one origin, so a product made in two countries needs two listings. Origin is set per store. No certificate upload is needed. “EU” is not accepted.

To fix origin in bulk, Amazon describes requesting a Category Listings report from Inventory Reports, filling the country of origin column in the Compliance section of the Template tab, setting Edit (partial update) as the listing action, and uploading through Catalog, Add Products via upload. For one listing, use Edit listing from Manage All Inventory and look under Safety and compliance.

Repacking or relabeling elsewhere does not change origin. If origin genuinely changes, change it everywhere at once. If it has not changed, never declare that it did.

The CBP entry documents, from release to entry summary

What CBP needs to release goods

Under 19 CFR 142.3, the entry documents are the entry on CBP Form 3461 or its electronic equivalent, evidence of the right to make entry, a commercial invoice, a packing list where appropriate, and any documents other agencies require. Under 19 CFR 142.12, the entry summary, CBP Form 7501, is filed at entry or within 10 working days after entry, with estimated duties.

Amazon says it may be listed as ultimate consignee on the entry only with “in care of FBA” placed before the Amazon entity’s name, and it publishes an identification number for Box 26 of the 7501 for that purpose alone. Misusing it may cause delays, detentions and seizures.

What the commercial invoice must show

Under 19 CFR 141.86, the invoice must show, among other things, the port of entry, who sold to whom and when, a detailed description of each item, quantities, the purchase price of each item, itemized charges where required, the country of origin, and any assists, such as molds or tooling you supplied that are not in the price. If you paid separately for a mold for a private label product, tell your broker.

Informal entries, other agencies and exams

Under 19 CFR 143.21, shipments up to $2,500 may generally use informal entry, except articles over $250 classified in Chapter 99, Subchapters III and IV of the HTSUS, where additional duty provisions sit. Amazon lists goods that commonly need extra permits, including food, supplements, medical devices, hazardous goods and pesticides, and says undeclared PGA shipments will be held or seized and returned at your expense, or destroyed. CBP’s tips page adds that CBP may examine any shipment and the importer bears costs such as an examination station’s bill.

How long to keep import records

Under 19 CFR 163.4, records relating to an entry are generally kept for 5 years from the date of entry, with exceptions such as drawback records and packing lists. Keep the whole shipment file together for at least 5 years. Amazon’s invoice page asks for invoices dated within 365 days before the notification, covering your sales and inventory of each cited ASIN over that period. Five years of customs files covers that window, provided you can find them by ASIN.

How import paperwork becomes supply chain evidence for Amazon

Amazon asks for invoices to verify that sellers source from legitimate suppliers, typically after a product authenticity or quality notification. A clean import file already holds most of what Amazon wants.

What Amazon says an acceptable invoice contains

• Supplier information. Name, phone, address and website.
• Transaction details. An issue date within 365 days before the notification, quantities covering sales and inventory of each cited ASIN, and sales records for each ASIN.
• Product information. Names, model numbers or identifiers such as UPC or EAN, variation details, and every bundle component.
• Format. PDF, .jpg, .png or .gif, up to 10MB, submitted through Seller Central.

The invoice must record a completed, fulfilled transaction and be authentic and unaltered. You may remove pricing, but everything else stays visible. Amazon may contact the supplier. The invoice does not have to be in English.

What Amazon says it will not accept

Amazon rejects invoices sent by email instead of through Seller Central, quotes and pro forma invoices, self issued invoices or ones where supplier and buyer appear to be the same entity, manipulated or editable files such as .xlsx or .docx, and illegible or inconsistent invoices. Several of these match China sourcing habits. Factories issue pro formas for deposits and never a final invoice unless asked, some sellers buy through their own offshore trading company, and some suppliers send spreadsheets. Fix all three in the purchase order by requiring a final PDF commercial invoice, from the factory or a genuinely independent trading company, naming your business as buyer.

The chain a reviewer can follow

An invoice inside a chain proves more than an invoice alone. Link the purchase order, final invoice, payment from your business account to the named supplier, bill of lading, ISF, entry summary, broker duty statement and FBA receiving record, with matching names, quantities and dates. The ISF ties factory, origin and code per line item, and the 7501 ties the entry to your importer number, so customs records independently confirm that the invoiced goods crossed the border in your name.

Amazon’s supplier due diligence page adds checks that strengthen the file. They include business registration and licenses, physical presence, a letter of authorization from the brand or the supplier’s own invoices for branded goods, and invoices showing supplier, buyer, dates, descriptions and quantities. For private label goods, the factory is your source.

Where to verify each part of your import setup

When a shipment or an Amazon review goes wrong

Import problems surface in three ways. CBP holds the shipment, the fulfillment center refuses it, or Amazon asks for invoices on an ASIN. Diagnose before you write anything.

Find the real root cause

Start with the specific failure. A dock refusal for collect charges is a shipping terms problem. A CBP hold for missing agency data is a classification and PGA problem. A rejected invoice is a documentation problem, and Amazon says its Performance Notifications explain why invoices were not accepted. A root cause names a broken process, such as “our purchase orders never required a final invoice, so the factory only issued pro formas.” “There was a paperwork issue” is not a root cause.

Corrective actions you can prove

Fix gaps with genuine records. If the factory never issued a final commercial invoice for a completed order, ask it to. That is a real document of a real transaction. Pull the ISF and 7501 from your broker to show the goods entered in your name. Correct a wrong origin through the Category Listings report. Date every correction.

Never create, edit or “tidy up” a document. Amazon requires authentic, unaltered documents and may call your supplier, and CBP holds the importer responsible for entry documents. If a genuine invoice cannot be obtained because a supplier closed, say so plainly, submit the genuine records you have, such as payment records, bill of lading and entry summary, and accept that the gap affects the outcome. A fabricated document turns a sourcing question into an integrity problem.

Preventive controls with an owner and a date

Name each control, its owner and its start date. Examples are a purchase order template requiring a final PDF invoice, owned by purchasing, an ISF checklist sent at order placement, owned by logistics, a review of every 7501 against the invoice, a quarterly bond and tariff review with your broker, and a per ASIN evidence folder covering 365 days. If a prep center was involved, see our guide to supply chain suspensions. Our Amazon inventory reconciliation service helps match what you imported, what Amazon received and what you sold.

Common mistakes sellers make importing from China

• Leaving the IOR blank or naming Amazon. Amazon says this risks refusal, detention or seizure.
• Shipping on collect terms. Amazon refuses shipments with collect charges.
• Collecting ISF data at the last minute. The clock runs from loading in China.
• Picking an HTSUS code for its rate. Classification follows what the product is.
• Assuming routing changes origin. Section 301 follows origin, not the export point.
• Keeping only pro formas and chat messages. Amazon does not accept them as sourcing proof.
• Paying suppliers from a personal account. Payment should connect the same buyer and supplier as the invoice.

For invoice quality, see our article on Amazon’s invoice requirements. For forced labor import rules, see Amazon supply chain standards.

A repeatable routine for every China shipment

At order placement. Confirm the factory’s legal name, the HTSUS number and current additional duties, the marking method, DDP terms and a final PDF invoice requirement, and request ISF data. Before loading. Give the broker complete ISF data in time and confirm agency requirements and the bond. At entry. Check the 7501 against the invoice line by line. After receiving. Reconcile units and file the full chain in the ASIN folder. Every quarter. Review tariffs, bond sufficiency, listing origin values and invoice coverage for the last 365 days.

Frequently Asked Questions

Can Amazon be the importer of record for my FBA shipment?

No. Amazon says it will not act as importer of record for any FBA shipment. Your business, or a non-resident importer set up through your broker, must be the IOR.

Do I need a customs bond to import from China?

Often, yes. Amazon says you may need one, and an ISF filer must hold a bond type listed in 19 CFR 149.5. Your broker confirms the type and amount.

When is the ISF due?

For ocean cargo, most elements are due no later than 24 hours before the cargo is loaded at the foreign port. ISF does not apply to air shipments.

Do Section 301 duties apply to everything from China?

They apply to products of China under covered HTSUS subheadings, based on origin, not export point. Check your code against CBP and USTR sources for each shipment.

Do I need to prove origin to Amazon?

Amazon says no certificate upload is needed, but each listing needs one exact country of origin that matches your marking and customs filings.

Can I send Amazon a pro forma invoice?

No. Amazon does not accept quotes or pro forma invoices. It wants the supplier’s final invoice for a completed transaction.

How long should I keep customs records?

Under 19 CFR 163.4, generally 5 years from the date of entry, which also covers Amazon’s 365 day invoice window.

Who is liable if my broker makes a mistake?

CBP says the importer of record remains responsible for entry documents and all duties, taxes and fees.

Get Help With Your Import Records and Amazon Supply Chain Evidence

If Amazon has asked for invoices on goods you import from China, or a shipment problem has become an account problem, our team can review your import file against what Amazon asks for and help you build a truthful, documented response. Submit your case or book a consultation.

This article is educational information about Amazon policies and U.S. import rules as published at the time of writing. It is not legal, customs or tax advice. Tariff measures, de minimis rules and Amazon policies change. Confirm current requirements with CBP, USTR, Amazon and a licensed customs broker before acting.

You can also see all our marketplace suspension services.

Sources

• Amazon: Delivering imports to Amazon
• Amazon: Invoice requirements for appealing a policy violation
• Amazon: Select reliable suppliers with due diligence
• Amazon: Shipping and routing requirements
• CBP: Tips for new importers
• CBP: Importer Security Filing 10+2
• CBP: Bonds
• CBP: Trade Remedies
• CBP: Section 301 FAQs
• CBP: E-Commerce
• USTR: Section 301 investigations
• USITC: Harmonized Tariff Schedule
• 19 CFR 149.2, 149.3, 149.5 (ISF)
• 19 CFR 113.13 (bond amount), 141.1 (duty liability)
• 19 CFR 141.86, 142.3, 142.12, 143.21 (entry and invoices)
• 19 CFR 134.11, 134.41 (marking), 163.4 (records)