The importer of record for jewellery entering the USA is the party legally responsible for the entry: it declares the goods, pays duty and answers to US Customs and Border Protection (CBP). It is normally you, the buyer, or a licensed customs broker acting for you. It is not the Indian factory unless you agree that in writing and the factory is set up to do it.
De minimis is the rule that once let low-value shipments enter with little or no duty and a light-touch entry. It has been changed several times in recent years, so treat any claim that your jewellery parcels are de minimis with caution.
Who is the importer of record for jewellery?
The importer of record is the owner, purchaser or a licensed broker designated by one of them. In practice it is the business that buys the goods and brings them into the US market. That business needs an importer number and, for most commercial shipments, a continuous or single-entry customs bond.
The Indian supplier is the exporter. Their job is to ship the goods and supply accurate documents. They are not liable for US duty, classification or admissibility unless they are the importer of record.
If you sell on a marketplace or through your own website, you are usually the importer even when your customer receives the parcel directly. Check that your broker's power of attorney names the correct company.
What de minimis means for imitation jewellery
De minimis lets a shipment below a set value enter under simplified rules. For years the US used a threshold that many small online sellers relied on. Since 2025 the US has changed how and where that treatment applies, and the law and executive orders involved have moved more than once.
We do not give a threshold here because it may be out of date by the time you read this. Check the current position with CBP's own guidance or your customs broker before you quote a delivered price that assumes no duty.
Even where a low-value exemption applies, it does not remove other rules. Jewellery for children, lead and cadmium limits, plating and origin marking all still apply. Consumer product safety law does not care how small the parcel is.
Why you should not build your model on it
A business that only works while de minimis exists is exposed. A rule change can add duty, brokerage and delays to every parcel overnight. Run your landed cost twice: once with the simplified treatment and once with full duty and a formal entry.
For bulk orders the question mostly goes away. A pallet or a container of imitation jewellery is a formal entry, with a commercial invoice, a classification under the imitation jewellery heading and a duty calculation. The cost drivers are covered in import duty on Indian imitation jewellery into the US, UK and EU.
Your choice of delivery term decides who handles the entry. With FOB or CIF you clear the goods yourself, and with DAP the supplier or forwarder brings them to your door but you still clear them. FOB, CIF or DAP explains what each term leaves with you.
Next step
Before your first US order, confirm with a licensed customs broker who will be importer of record, what bond you need and what the current rule is for your shipment size. Ask for that answer in writing and keep it with your order file.
If you want a second pair of eyes on the document side as well as the factory, book a free sourcing review and we will go through your shipment plan with you.