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Can a foreign company export to the United States without an importer of record in the U.S.?
Yes, but they must have an agent in the state where the port of entry is located that serves as resident agent in the U.S. on behalf of the foreign corporation's behalf. For instance, a CBP Broker that has been named in a CBP power of attorney may make entry on behalf of the exporter or his/her representative.
Customs & Border Protection (CBP), Department of Homeland Security http://www.cbp.gov/
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