Short answer: Amazon will not be the importer of record for your FBA inventory. Its own help page says Amazon “will not act as an IOR, consignee, or partner government agency (PGA) agent for any shipment, regardless of the size, value, origin, destination, or product” (Seller Central help, checked 2026-10-11). That role falls to you or an entity you appoint. If you book Amazon Global Logistics, Amazon requires that importer of record to hold a continuous CBP customs bond. CBP’s bond guide leaves some entry types out of the continuous bond calculation, including informal entries under $2,500 (section 6.4.1.2). Under CBP’s February 2024 bond guide, the minimum continuous import bond is $50,000 or 10% of the duties, taxes and fees you paid in the previous 12 months, whichever is greater (checked 2026-10-11).
This guide covers three things the rest of our import series only touches: who the Amazon FBA importer of record has to be, how a single-transaction bond differs from a continuous bond, and the arithmetic CBP uses to size a continuous bond. Duty rates and landed cost live in the import tariffs framework; the ocean workflow lives in shipping from China to Amazon FBA.
Why Amazon will not be your importer of record
Amazon’s position is written down on a Seller Central help page that renders without a login: Amazon Global Logistics importer setup and customs compliance (checked 2026-10-11). Three sentences on that page settle most of the confusion:
- “You or an entity appointed by you must act as the importer of record (IOR) for inventory entering the US.”
- “Amazon will not act as an IOR, consignee, or partner government agency (PGA) agent for any shipment, regardless of the size, value, origin, destination, or product.”
- “However, Amazon is the ultimate consignee for FBA shipments with a ship-to destination in the US.”
The page sits under Amazon Global Logistics, but the second sentence is not limited to AGL bookings — it says “any shipment”. So whether you book Amazon’s own ocean service or hire a freight forwarder, the fulfillment center address on the paperwork does not make Amazon the importer. Amazon is the party that receives the goods at the end; the importer of record is the party CBP holds responsible for them.
For AGL bookings, the same page says the IOR “is also the consignee for your shipment”, with documents addressed as your name “in care of FBA” at the fulfillment center address. That is a routing convention, not a transfer of liability. Our Amazon Global Logistics guide covers how AGL charges are billed once this setup is done.
What the importer of record actually owes
Amazon’s help page lists three IOR responsibilities: making sure imported goods comply with local laws, filing the customs entry summary and associated documents, and “paying the assessed import duties and other taxes on those goods” (checked 2026-10-11).
CBP’s bond guide cites 19 U.S.C. 1484, under which “the importer of record is responsible for using reasonable care to enter, classify and determine the value of imported merchandise.” Failing that duty “could delay release of the merchandise and, in some cases, could result in the imposition of penalties” (checked 2026-10-11).
So the HTS code is your problem even when a broker files it (how to find one), and duty stays your debt even on a DDP quote — the tariffs guide covers that point. In the UK and EU the importer’s customs identity is an EORI number instead (EORI guide).
Getting an importer number: EIN, SSN or a CBP-assigned number
CBP’s bond guide says a bond principal is “identified by the 11-digit identification number (9-digit Internal Revenue Service employer identification number plus 2-digit suffix), social security number, or CBP assigned number, allowed on the CBP Form 5106, Create/Update Importer Identity Form” (checked 2026-10-11).
- A US company normally uses its EIN, with a two-digit suffix if it needs to separate branches.
- A non-resident company with no EIN gets a CBP-assigned number through Form 5106. Amazon’s page says “All non-resident IORs must complete a CBP form 5106”, and for AGL sellers who have never imported, Amazon will “complete a CBP form 5106 and register your business with US Customs on your behalf” (checked 2026-10-11).
Do this before anyone orders a bond. The CBP guide says “any party that is required to have a bond must have an active ACE account prior to submission of any bond,” and that an ACE account “may be established through submission of a CBP Form 5106” (checked 2026-10-11).
Single-transaction vs continuous customs bond
CBP’s definitions are short. A single transaction bond is “a bond that secures a single transaction or activity.” A continuous bond “secures one or more transactions or activities over a one-year period, is renewed automatically on the anniversary of the effective date of the bond, and remains in effect until terminated” (CBP bond guide, checked 2026-10-11). For ordinary imports both are Activity Code 1, “Basic Importation and Entry”.
| Single-transaction bond (Activity Code 1) | Continuous bond (Activity Code 1) | |
|---|---|---|
| What it covers | One entry | Every entry by the principal for a one-year period |
| Renewal | None; it ends with the transaction | Renews automatically each year until terminated |
| Typical amount | Generally not less than total entered value plus all duties, taxes and fees | $50,000 or 10% of previous 12 months’ duties, taxes and fees, whichever is greater |
| Duty-free goods | May be 10% of total entered value (unconditionally duty-free goods only) | Same section 6.4.1.1 formula: “$50,000 or 10% of the total estimated duties, taxes, and fees in the previous 12-month period, whichever is greater” |
| Accepted for AGL | No — Amazon requires a continuous bond | Yes |
Source: CBP, “A Guide for the Public: How CBP Sets Bond Amounts”, February 2024, sections 4.6, 4.7, 6.4.1 and 6.4.2; Amazon Seller Central help ASFW4BD897LNTNN. Checked 2026-10-11.
The amount row surprises people. Because a single-transaction bond is generally sized at the full entered value plus duties, a $40,000 container needs a single-transaction bond of more than $40,000. A continuous bond at the $50,000 floor covers that container and every other entry that year.
Amazon puts the choice plainly: “A single-entry customs bond is for importers who ship occasionally. A continuous customs bond is for importers who ship regularly.” For AGL there is no choice: “To import goods into the US with Amazon Global Logistics, you must have or obtain a continuous US customs bond” (checked 2026-10-11).
Ocean shipments also need bond cover for the Importer Security Filing; see our ISF filing guide.
How CBP sets the minimum continuous bond amount
CBP calls the base calculation the “Reviewer formula”. Section 6.4.1.1 of the bond guide states: “The minimum Activity Code 1 continuous bond amount is $50,000 or 10% of the total estimated duties, taxes, and fees in the previous 12-month period, whichever is greater.” It continues: “All continuous bonds are set in increments of $10,000 up to $100,000 and then in increments of $100,000 for larger bonds” (checked 2026-10-11).
Four rules from the same section shape the result:
- “Duties, taxes and fees” is the whole bill, not just the tariff line. Additional duties stacked on your HTS code count, and so do fees such as MPF. When your duty rate goes up, your bond requirement goes up with it.
- Some entry types are excluded from the calculation, including type 11 informal entries under $2,500 and type 86 Section 321 entries.
- No import history means an estimate. If you made no imports in the preceding year, the amount is based on what you estimate you will owe over the next 12 months, and “in no event can the bond amount be less than $50,000.”
- Unpaid bills are added on top. CBP’s “Analytical formula” adds 10% of delinquent bills that are unpaid for under 210 days or under protest, and 100% of bills over 210 days, bills tied to a denied protest, and unpaid debit vouchers. The total is then rounded up again by the same increments.
Worked examples, assuming these 12-month totals of duties, taxes and fees:
| Previous 12 months’ duties, taxes and fees | 10% | Rounded continuous bond |
|---|---|---|
| $180,000 | $18,000 | $50,000 (floor applies) |
| $620,000 | $62,000 | $70,000 |
| $620,000 plus $40,000 in unpaid bills under 210 days | $62,000 + $4,000 | $70,000 + $4,000 = $74,000 → $80,000 |
| $1,230,000 | $123,000 | $200,000 |
Arithmetic follows CBP’s Appendix B formulas (bond guide, February 2024, checked 2026-10-11). The inputs are assumptions for illustration.
The bond amount is not what you pay. A surety issues the bond and charges you a premium; for AGL, Amazon publishes its own fee schedule, covered below.
When CBP says your bond is insufficient
The bond amount is not set once and forgotten. CBP’s guide says the Office of Finance – Revenue Division “performs a periodic review of bond sufficiency,” looking at recent activity volume, liquidated damages history, payment of duties, unpaid bills, and “the kind and character of the merchandise being imported” (checked 2026-10-11).
If the review finds your continuous bond too small, the notice comes from the Revenue Division director, and you have to terminate the old bond and file a larger one by the deadline in that notice. Paying overdue bills before that deadline, and telling the Revenue Division, triggers a recalculation.
Port or Center Directors can also demand a single-transaction bond on top of a continuous one when an entry puts “the revenue in jeopardy”. The guide names antidumping and countervailing duty cases as one situation where CBP may do this.
Amazon passes the monitoring to you: “You or the IOR are responsible for ensuring that the bond coverage amount is current” (checked 2026-10-11). We’d recalculate the 10% figure every quarter in a year when your duty rate changes.
Buying, renewing and terminating a continuous bond for Amazon FBA
A customs bond is a contract between you (the principal) and a surety, with CBP as the beneficiary. It reaches CBP from the surety, a surety agent, a broker or the principal, either electronically through ACE eBond or by email to the Revenue Division. A continuous bond “may be filed up to 60 days prior to the effective date requested” (19 CFR 113.26(a), checked 2026-10-11).
Through Amazon Global Logistics. Amazon will help you obtain a bond if you don’t have one. Its page states: “A fee for your continuous US customs bond will be applied to your first booking. You will be charged annually thereafter to renew.” The published schedule, based on your duties, taxes and fees over the past 12 months (or the next 12 months if you have no history), is (checked 2026-10-11):
| Duties, taxes and fees | Amazon’s annual continuous bond fee |
|---|---|
| $500,000 or less | $350 |
| Greater than $500,000 | Quoted by Amazon with your first shipment |
Through your own broker. Ask which surety issues the bond and what face amount they calculated.
Changing or ending a bond. CBP authorizes only one continuous bond per activity for each principal (19 CFR 113.12(b), cited in the bond guide), so switching sureties means terminating one bond and filing another. Under 19 CFR 113.27(a), a principal’s termination request takes effect on the requested date if it is at least 10 business days after CBP receives it. Under 113.27(b), a surety must give reasonable notice, and “thirty days will constitute reasonable notice” unless CBP accepts a shorter time. Under 113.27(c), after termination, “a new bond in an appropriate amount on CBP Form 301” must be filed “before further customs activity may be transacted” (checked 2026-10-11). Schedule the switch so no container lands in the gap.
Amazon’s page adds one practical trap: if your IOR address has changed since the bond was issued, ask the broker who issued it for an update, because the bond address “must match the address used in your primary POA and supporting documentation”.
Common mistakes
- Assuming the FBA address makes Amazon the importer. Amazon is the ultimate consignee, not the IOR.
- Buying single-transaction bonds container by container. Each is generally sized at the full entered value plus duties, while one continuous bond covers every entry for the year.
- Sizing the bond on last year’s duty rate. The 10% base moves with your total duties, taxes and fees. A higher tariff on your HTS code can push you past the next $10,000 increment.
- Ordering a bond before the ACE account exists. File Form 5106 first.
- Letting overdue CBP bills sit. Unpaid bills are added to the bond calculation, partly or in full.
- Changing your company address without a bond rider. Amazon’s IOR setup checks that addresses match.
- Confusing domestic freight with import clearance. Amazon Freight moves goods inside the US and plays no role in customs entry.
Frequently Asked Questions
Does Amazon act as importer of record for FBA shipments?
No. Amazon’s Seller Central help page says it “will not act as an IOR, consignee, or partner government agency (PGA) agent for any shipment,” whatever the size, value or origin (checked 2026-10-11). You or an entity you appoint must be the importer of record.
Do I need a continuous bond to use Amazon Global Logistics?
Yes. Amazon states that to import with AGL “you must have or obtain a continuous US customs bond.” It can arrange one, with a $350 annual fee if your duties, taxes and fees are $500,000 or less (checked 2026-10-11).
What is the minimum continuous customs bond amount?
$50,000, or 10% of your duties, taxes and fees over the previous 12 months if that is greater, rounded up in $10,000 steps to $100,000 and $100,000 steps above that (CBP bond guide, February 2024, checked 2026-10-11).
Can a foreign company be the importer of record for FBA?
Yes. Amazon’s page says an IOR can be a non-resident entity, and all non-resident IORs must complete CBP Form 5106 to get an importer number (checked 2026-10-11).
Conclusion
Settle the Amazon FBA importer of record before you book freight: pick the entity, get its importer number through Form 5106, then buy a continuous bond sized to the greater of $50,000 or 10% of your annual duties, taxes and fees. Recheck that figure whenever your duty rate changes, and pay CBP bills before they push the bond up. Every rule and figure here was checked on 2026-10-11 against CBP’s February 2024 bond guide, 19 CFR Part 113 and Amazon’s Seller Central help page.