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Importer and exporter of record
Getting hardware into a country your company has no entity in, legally and without it sitting in bond. We are the importer of record into New Zealand, and we arrange and manage the same role in other markets under one contract.
The hardware is bought, the site is ready and the install crew is booked. Then the shipment stops at the border, because the company named on the commercial invoice does not exist in that country as far as its customs authority is concerned.
This is the part of a global rollout that nobody prices and everybody discovers. A freight forwarder will happily move your boxes, but a forwarder is not an importer: it will not sign the declaration, it will not carry the liability for what that declaration says, and it will not pay the duty. Someone with legal standing in the destination country has to do all three, and if that party has not been appointed before the goods ship, the equipment goes into a bonded warehouse and starts accruing storage while you find one.
The role is called importer of record, and its mirror image on the way out is exporter of record. Both are legal positions rather than logistics services, which is why they sit awkwardly in most procurement processes: they are not a line on a freight quote and they are not something a project manager can absorb.
What we hold, and what we arrange
The distinction matters legally, so we put it on the page rather than leaving you to discover it in the contract.
New Zealand: we are the importer of record
In our own name, with our own standing. This is the part we carry ourselves.
- Import declaration lodged and owned by us
- Duty and GST paid at clearance, then reconciled to you
- Tariff classification, including on encryption-capable network and security equipment
- AS/NZS compliance verified against the equipment actually shipped, not the catalogue entry
- MPI biosecurity requirements on timber packaging and crating
- Storage, staging and final-mile delivery to the site under the same contract
Other markets: we appoint and manage the provider
We do not hold customs standing outside New Zealand and will not tell you we do. What we do is own the arrangement.
- A provider with real standing in the destination country is appointed and contracted to us
- You sign one agreement with us rather than one per country
- Pre-compliance check before the purchase order, not after the goods ship
- One escalation path when a consignment is held, and one party answering for it
- The legal importer in that country is the appointed provider, and we will name them to you
- Documentation returned in one consistent pack regardless of who cleared it
Six ways a cross-border shipment goes wrong
None of these are exotic. Each one has a fix that costs almost nothing before the goods move and a great deal afterwards.
01
Goods ship before an importer is appointed
The consignment arrives, cannot be cleared to anyone, and goes into bond. Storage accrues daily while the appointment is sorted out, and the install crew you booked is standing on site with nothing to install.
02
The commercial invoice is wrong
Understated value, a vague description, or a transfer price that does not reflect the goods. It gets flagged, the consignment is inspected, and the shipper acquires a record that makes every later shipment slower.
03
Export control is missed on encryption
A lot of ordinary switching, wireless and storage hardware is encryption-capable, which puts it inside export control regimes people associate with weapons. Classified wrongly, it is held on the way out, before it has even reached the border that everyone was worried about.
04
Tax is paid by a party that cannot reclaim it
VAT or GST paid on import is recoverable by a registered entity and a dead cost to everyone else. Route a shipment through the wrong importer and a recoverable line becomes a permanent one, which is a budget problem discovered at year end.
05
Serial numbers do not match the paperwork
The declaration says one thing, the asset register says another, and the vendor will not register warranty against either. The equipment is installed and running, and unsupported.
06
The packaging fails inspection
Untreated timber crating without ISPM 15 marking holds the whole consignment, hardware included, over a pallet. It is the cheapest failure on this list to prevent and one of the slowest to resolve.
How it runs
Pre-compliance check
Before the purchase order. What is being shipped, from where to where, its classification, whether export control applies, and what the destination country requires. This is where the cost of getting it wrong is still zero.
Appointment
We take the importer of record role for New Zealand, or appoint and contract a provider who holds it in the destination country. You get one agreement either way, and we tell you which of the two applies.
Documentation
Commercial invoice, packing list, classification and country of origin prepared to what the destination actually requires, with serial numbers captured so the declaration and the asset register agree from the start.
Export
Export declaration lodged, export control cleared where it applies, and the consignment released with packaging that meets the destination's biosecurity rules.
Clearance
Import declaration lodged, duty and tax paid, inspection managed if one is called. Held consignments get chased by us rather than by you.
Storage and staging
Into a bonded or commercial facility near the site rather than straight to a building that is not ready for it. Equipment can be unboxed, asset-tagged, configured and staged while the site catches up.
Final-mile delivery
To the floor, the room or the rack position, timed to the install programme rather than to the shipping schedule.
Reconciliation and handover
Asset register reconciled against what actually arrived, duty and tax reconciled against what was paid, and one document pack covering the whole journey for your finance and audit teams.
When you do not need us
If you have a registered entity in the destination country and a customs broker who already works for you, you do not need an importer of record. You need freight, and you should buy freight.
If it is a laptop or a couple of access points, an integrator shipping delivered-duty-paid through a courier will be cheaper than anything we can structure, and there is no sensible argument otherwise.
This is worth paying for when the value is high enough that a held consignment hurts, when the equipment is encryption-capable, when the install crew is booked against a date, or when nobody in your organisation can name who the legal importer is. That last one comes up more often than the others combined.
Common questions
What is an importer of record?
The importer of record is the party legally responsible to the customs authority for a shipment: for the accuracy of the declaration, for paying duty and tax, and for meeting whatever compliance rules apply to the goods. It is a legal role, not a logistics one. A freight forwarder moves the boxes; the importer of record carries the liability for what is written on the paperwork.
Can I import hardware into a country where my company has no entity?
Usually not in your own name. Most customs authorities will only clear commercial goods to a party with standing in that country, which is why shipments addressed to a company with no local presence sit in bond. The normal solution is to appoint an importer of record in that country who takes the role on your behalf.
Is 369 Infrastructure the importer of record in every country?
No, and we would not claim it. We are the importer of record into New Zealand directly. Outside New Zealand we appoint and manage a provider who holds that standing in the destination country, and we contract with you for the whole arrangement so you have one agreement and one escalation path rather than several.
What is an exporter of record?
The mirror image: the party legally responsible for the export declaration and for meeting export control rules in the country the goods are leaving. It matters more than people expect on network and security hardware, because encryption capability puts a lot of ordinary switching and storage equipment inside export control regimes.
How long before the equipment ships do you need to be involved?
Before the purchase order, ideally, and certainly before anything leaves the supplier. The expensive failures are almost all caused by goods shipping first and the compliance question being asked afterwards, at which point the equipment is already in a bonded warehouse accruing storage.
Do you handle duty and tax, or do we?
Duty and tax are paid at clearance by the importer of record and then reconciled back to you with the documentation. What matters commercially is whether you can recover the tax portion, and that depends on whether you have a registered entity in that country. We will tell you which side of that line you are on before you commit, because it can be the difference between a recoverable cost and a permanent one.
Got hardware to land somewhere?
Tell us what is shipping, from where, and to which country. We will tell you what the compliance position is and whether you need us at all.
Talk to us about a shipment