Reasonable care for each entry
Importers are expected to use reasonable care in declaring the classification, value, and origin of imported goods, along with other information on the entry. Using a customs broker does not shift that duty, though the broker's advice can be relevant. Classification under the tariff schedule is often the hardest part, and binding rulings from CBP can provide certainty for a product before it is imported. Valuation questions come up with related-party pricing, assists provided to a manufacturer, and royalties or commissions. Country-of-origin rules matter for duties, marking requirements, and additional tariffs that apply to goods from particular countries.
Inquiries, detentions, and penalties
CBP often begins with a request for information and may follow with a notice of proposed action. Shipments can be detained or excluded, including under rules targeting goods made with forced labor, where importers may need to trace their supply chains in detail. Penalties for false statements or omissions depend largely on the level of culpability, from negligence to fraud. A prior disclosure made before you learn that CBP has opened a formal investigation can significantly reduce penalties, but timing and completeness are critical. Records generally must be kept for a set period after entry and produced on request.
Responding and fixing processes
Respond to CBP requests on time and with accurate information, and talk to counsel before answering questions that suggest a broader issue. Gather the entries in question, commercial invoices, purchase orders, payment records, and any classification or valuation analyses. Errors found before liquidation can often be corrected through a post-summary correction, while later issues may call for a protest or a disclosure. In a first meeting we review the inquiry, assess whether the issue extends to other entries, and discuss how to strengthen your classification and valuation process.
