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CBP Form 3347: Declaration of Owner and Duty Liability

Published: October 5, 2026  ·  11 min read
CBP Form 3347: Declaration of Owner and Duty Liability
Photo: Kampus Production / Pexels

Key Points

On this page

  1. What CBP Form 3347 is
  2. At a glance
  3. Where CBP Form 3347 comes from in law and regulation
  4. Who signs CBP Form 3347 and CBP Form 3347A?
  5. When is CBP Form 3347 filed in the entry lifecycle?
  6. How is CBP Form 3347 prepared and submitted?
  7. Common CBP Form 3347 problems and what they cost
  8. How CBP Form 3347 relates to other CBP forms
  9. Frequently asked questions
  10. What importers and brokers should do
  11. Key references

The links in this article go to the primary documents: the statute, the regulations, and the official CBP pages themselves. Read the source before you rely on a summary, including this one.

CBP Form 3347 is the Declaration of Owner for Merchandise Obtained Otherwise Than in Pursuance of a Purchase, the declaration an actual owner of imported merchandise signs so that responsibility for duties on an entry rests with that owner rather than with the nominal consignee who made entry. It is used by importers, consignees, and the customs brokers who file on their behalf, and it sits after entry has been made but before the duty liability question is settled. Its companion, CBP Form 3347A, Declaration of Consignee When Entry Is Made by an Agent, documents the consignee's confirmation when an agent filed the entry.

At a glance

Where CBP Form 3347 comes from in law and regulation

CBP Form 3347 exists because 19 U.S.C. 1485(d) allows a person who makes entry as a consignee, but who is not the owner, to shift liability for duties to the actual owner by filing a declaration of the owner together with the owner's bond. The regulation that implements that statutory mechanism is 19 CFR 141.20, which sets the conditions, including the 90-day filing window. The related provision at 19 CFR 141.19 governs the declaration side of entry made by an agent, which is where the 3347A companion form fits. As of October 2026, those three citations are the ones to read first, and any port-specific practice layered on top of them should be confirmed directly with CBP.

The phrase in the title of CBP Form 3347, "obtained otherwise than in pursuance of a purchase," signals the situation it addresses: goods that reached the importer through consignment, gift, lease, sample shipment, or some other arrangement that is not a straightforward sale, where the party named on the entry is handling the merchandise for someone else who truly owns it.

Who signs CBP Form 3347 and CBP Form 3347A?

CBP Form 3347 is signed by the actual owner of the merchandise, the party declaring that it owns the goods and accepting the duty liability that the declaration moves to it. The nominal consignee, the party that appears on the entry and made entry, is the one who benefits from the filing because a properly filed declaration supported by the owner's bond is what relieves that consignee of liability for increased or additional duties. CBP Form 3347A is signed by the consignee when the entry was made by an agent, confirming the relationship between the consignee and the filing agent.

In practice the customs broker does the legwork: identifying that the transaction is not a purchase, collecting signatures, verifying that the owner has a bond, and tracking the deadline. The broker's own authority to act comes from a power of attorney, for which CBP Form 5291, Power of Attorney, is the optional CBP format for the written authority an importer gives a licensed customs broker to transact customs business in its name. CBP Form 5291 and CBP Form 3347 do different jobs: the first grants authority to act, the second moves duty liability. See our reference on CBP Form 5291 for the authority side.

When is CBP Form 3347 filed in the entry lifecycle?

CBP Form 3347 is filed after entry has been made, within the 90-day window prescribed by 19 CFR 141.20, and it works alongside the entry summary rather than replacing it. The entry summary itself, CBP Form 7501, Entry Summary, is the declaration of classification, value, origin, duties, taxes and fees for an entry, filed in ACE within 10 working days of release or with the entry, and it remains the document every bill, refund and audit traces back to. CBP Form 3347 does not change what is declared on CBP Form 7501; it changes who answers for the money.

Miss the 90 days and the shift does not happen. The nominal consignee stays on the hook for increased and additional duties, which means any later rate advance, value adjustment, or post-liquidation bill lands on the party that filed, not on the owner it was acting for.

How is CBP Form 3347 prepared and submitted?

CBP Form 3347 is prepared from the underlying commercial documents that show the goods were not purchased, and submitted to CBP along with evidence that the owner's bond is on file. Because filing channels and port handling for declarations of this kind vary, confirm the current submission method, whether paper, document imaging, or another channel, with CBP or the port before the deadline runs. The form itself is published on CBP's forms pages at cbp.gov, and brokers should pull the current revision each time rather than reusing a stored PDF.

Bond coverage is the part teams forget

A signed CBP Form 3347 without the owner's bond on file does not do the job. The relief described in 19 U.S.C. 1485(d) is conditioned on the bond, so the practical sequence is: confirm the owner has a bond, confirm it covers this entry, then file the declaration.

Common CBP Form 3347 problems and what they cost

The most common CBP Form 3347 failures are procedural rather than substantive: filing after the 90-day window has closed, filing without the owner's bond in place, or signing the wrong form when an agent made the entry and CBP Form 3347A was the one needed. Each failure has the same practical result, which is that duty liability does not move and the nominal consignee carries it.

A second category is misuse. CBP Form 3347 is not a vehicle for a party that bought the goods to hand its duty bill to someone else, and it is not a correction mechanism for classification or value. If the numbers on the entry are wrong, that is a post summary correction, a response to a CBP Form 28 request for information, or a prior disclosure question, not a CBP Form 3347 question.

How CBP Form 3347 relates to other CBP forms

CBP Form 3347 belongs to the small group of CBP forms that allocate responsibility rather than describe cargo, and it is easy to confuse with forms that look adjacent but do something else entirely. CBP Form 3124, Application for Customs Broker License, is the application an individual, partnership, association or corporation files with CBP under 19 CFR part 111 to obtain a customs broker license; it concerns who may file, not who owes duties. CBP Form 400, ACH Debit Application, enrolls a payer in CBP's Automated Clearinghouse debit program to pay duties, taxes, fees and bills electronically, which determines how duties are paid once liability is settled by CBP Form 3347.

Other forms in the cluster touch merchandise under CBP custody or at the border: CBP Form 3499, Application and Approval to Manipulate, Examine, Sample or Transfer Goods, permits handling of goods still in CBP custody; CBP Form 3495, Application for Exportation of Articles Under Special Bond, notices the export of temporary importation bond goods; CBP Form 3173, Application for Extension of Bond for Temporary Importation, extends the TIB period in one-year increments up to three years total; CBP Form 300, Bonded Warehouse Proprietor's Submission, is a warehouse proprietor's annual inventory reconciliation; and CBP Form 7533, Inward Cargo Manifest for Vessel Under Five Tons, Ferry, Train, Car, Vehicle, etc. is the land border arrival manifest. Further afield, FinCEN Form 105, Report of International Transportation of Currency or Monetary Instruments (CMIR), is filed with CBP when currency or monetary instruments above the reporting threshold cross the border, and is not a customs entry form at all. None of these shift duty liability; only CBP Form 3347 and its 3347A companion do.

Frequently asked questions

Does CBP Form 3347 apply to purchased goods?

No. CBP Form 3347 is the Declaration of Owner for Merchandise Obtained Otherwise Than in Pursuance of a Purchase, so by its own terms it addresses merchandise that came to the importer through something other than a purchase. If the goods were bought, the duty liability analysis runs through the ordinary importer of record rules instead.

What is the deadline for CBP Form 3347?

The owner's declaration under CBP Form 3347 must be filed within 90 days, per 19 CFR 141.20. Confirm how the window is counted for your specific entry with CBP or the port before relying on an internal calendar.

Is CBP Form 3347 the same as the importer identity form?

No. CBP Form 3347 is a declaration of ownership and duty liability. It is not an identity or importer number application, and filing it does not create, update, or substitute for an importer identification record.

What does CBP Form 3347A add?

CBP Form 3347A, Declaration of Consignee When Entry Is Made by an Agent, is the consignee's declaration for the situation covered by 19 CFR 141.19, where an agent made the entry. It documents the consignee's side of the arrangement that CBP Form 3347 addresses from the owner's side.

What importers and brokers should do

Key references


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About the Author

Franz Brotzen, CustomsGenius CEO & Founder. Franz is a published researcher on U.S. trade policy. He has worked at think tanks in Washington DC and Tokyo, where his academic publications focussed on tariffs and legal compliance. Franz received his JD from Harvard Law School.

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