Recent Trade & Tariff Perspectives

August 4, 2021 | Alyson Brinkman Senior Compliance Manager

To Reconcile or Not to Reconcile Your Data?

U.S. Customs and Border Protection (CBP) requires importers to exercise reasonable care when they are declaring elements like valuation, classification, and free trade agreement eligibility. Every customs entry must include specific data for the cargo to be released. But what if certain information isn’t available at the time of entry into the country or you’re unsure that the products being imported meet specific eligibility criteria (e.g. for a free trade agreement)?

Reconciliation is a great option for importers who may not be able to provide the most complete information at time of cargo release. Issues related to valuation, classification, and certain free trade agreements may be flagged for reconciliation, allowing you time to obtain the relevant information and supporting documentation to perfect the entry later.

Which issues may be flagged for reconciliation?

Reconciliation flags may be filed for four specific issues or combined as needed:

How do importers participate in reconciliation?

Any importer may participate in reconciliation. Interested importers should review the helpful reconciliation resources on the CBP website and then reach out to their customs broker to get started.

Importers will need to:

• Have a continuous bond and a valid reconciliation bond rider to participate.
• Determine which transactions may be eligible for reconciliation and for which reconciliation issues.
• Advise their customs broker to start flagging their applicable entries with the reconciliation issue flags. Customs brokers may flag all the importer’s transactions or flag specific entries individually, but the importer needs to provide guidance on which entries should be flagged and for which issue.
• Establish an internal compliance process to monitor and manage the changes, adjustments, or corrections that would need to be made at the time of the reconciliation filing. 
• Get an Automated Commercial Environment (ACE) Portal account to effectively monitor flagged entries and deadlines and obtain customs entry data for flagged entries.
• Work with the customs broker to file the reconciliation entries to close out the flagged issues before the deadline.
• Pay any additional duties and taxes owed, which can be processed through either the customer’s or customs broker’s Automated Clearinghouse (ACH) account. Reconciliation resulting in refunds will be paid to the importer, with interest, via check or ACH Refund. A Periodic Monthly Statement (PMS) is not an option for reconciliation.

C.H. Robinson has a dedicated team of Trusted Adviser® experts to assist clients with their reconciliation filing needs. Reach out today for more information.