What is the difference between an importer of record and an exporter of record?
The importer of record is the party legally responsible for a US import entry: the declared value, the classification, the duties and the accuracy of the filing. The exporter of record carries the same responsibility for an export filing on the way out. Neither role is ownership. Because they are filing roles, a bonded third party such as Super Universal can hold them, which is how foreign buyers with no US entity, and owners who do not want their name on a public-facing entry record, complete a clean transaction.
Key takeaways
- Importer and exporter of record are filing roles, not ownership
- A foreign buyer with no US entity still needs an importer of record
- The role carries liability for valuation and classification accuracy
- Using a bonded third party keeps the transaction off the entry record
What each role owns
On the way in, the importer of record is the party CBP holds responsible for the entry. That covers the declared value, the classification applied to the airframe, the duties and fees assessed and the truthfulness of the supporting documents.
On the way out, the exporter of record does the equivalent for the export filing. In both cases the responsibility attaches to the filing, not to the title, which is what makes it possible for someone other than the owner to hold it.
When a third party should hold it
There are three situations where owners routinely put someone else on the entry, and none of them are unusual.
- A foreign buyer with no US entity and therefore no ability to be importer of record
- A transaction the parties do not want visible on the entry record before closing
- An owner or lessor with no customs filing capability and no appetite for the liability
- A repeat mover who wants every filing behind one bonded party rather than a new broker each time
Privacy, and what it does not mean
Entry records are one of the ways a deal becomes visible earlier than the parties intended. Acting as importer or exporter of record keeps the owner's name off that record, which for high-value private transactions is often the reason the call is made in the first place.
What it does not do is change who owns the aircraft, alter the title chain or move any tax obligation that follows ownership. It is a filing arrangement, and we are explicit about that with every party in the transaction.
How we take the role on
We review the transaction documents, agree the declared value and classification with you before anything is filed, confirm the arrival or departure port, and then file under our CBP bond. You get the entry record and the release, and the aircraft moves on the schedule you planned rather than the schedule the paperwork dictates.
Common questions
Last reviewed September 10, 2026 by the Super Universal operations desk.