Articles on this topic (6)
Prior Disclosure vs. a CBP Protest: Two Very Different Ways to Fix a Classification Mistake
Prior disclosure and a CBP protest both fix a classification error, but they're not interchangeable — one closes the moment CBP issues a CF-29, and most importers don't realize it until it's already too late.
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Everything You Need to Know About Post Summary Corrections
File a PSC within 300 days of entry or 15 days before scheduled liquidation, whichever is first. Eligibility, limits, 2026 ACH rules, and the audit risk.
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Classification Ruling vs. Country of Origin Ruling: Why They're Not the Same Request
A classification ruling settles the HTSUS subheading. It does not settle origin. Importers who treat one CBP ruling as answering both questions carry retroactive duty exposure.
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What a Focused Assessment Actually Audits, and Why Reasonable Care Is the Standard, Not Perfection
A CBP Focused Assessment doesn't punish every classification error — it punishes the absence of reasonable care. Here's how the audit actually works, and what separates a duty bill from a penalty.
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Section 301 Exclusions: Retroactivity, Expiration, and the Federal Register Trap
A USTR Section 301 exclusion only helps if it's actively claimed with the right Chapter 99 code, tracked through Federal Register notices, and caught before the protest window closes. Most importers miss at least one of the three.
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Why the Same Product Gets Two Different HTS Codes from Two Different Brokers
Two customs brokers can each follow the GRI in good faith and land on different HTS codes for the same product — not from carelessness, but because neither traversal was ever recorded.
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11 Terms
CBP Audit
A CBP audit reviews an importer's HTS classifications, duty payments, and compliance program. Classification errors can result in additional duties, penalties up to 4x unpaid duties, and interest going back five years.
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CBP Binding Ruling
A CBP binding ruling is an official advance determination of the correct HTS code for a described product. It binds CBP and provides the requesting importer with classification certainty and audit protection.
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CBP Protest
A CBP protest is a formal challenge to a CBP classification or duty assessment, filed on Form 19 within 180 days of liquidation. If denied, the importer may appeal to the U.S. Court of International Trade.
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CF-28 — Request for Information
CBP Form 28 is a formal written request from CBP for additional information about a shipment's classification, valuation, or origin. It is not a penalty — it is a request, typically with a 30-day response window.
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CF-29 — Notice of Action
CBP Form 29 is a formal Notice of Action from CBP indicating it intends to reclassify an entry or assess additional duties. Importers typically have 20 days to respond before the action becomes final.
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CROSS — Customs Rulings Online Search System
CROSS is CBP's public database of over 200,000 binding ruling letters on HTS classification, country of origin, and other customs matters. It is the primary source of U.S. classification precedent.
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Entry Summary — CBP Form 7501
The entry summary (CBP Form 7501) is the primary U.S. import document listing HTS codes, duty rates, and customs values. Classification errors on the 7501 are the legal basis for CBP audit assessments and penalty proceedings.
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Importer of Record (IOR)
The importer of record is the party legally responsible for a U.S. customs entry — including correct HTS classification, duty payment, and trade remedy compliance — regardless of who performed the classification.
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Licensed Customs Broker
A licensed customs broker files customs entries on behalf of importers and is responsible for correct HTS classification on entry documents. Importers share liability for broker classification errors.
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Prior Disclosure
A prior disclosure self-reports a customs violation to CBP before a formal investigation, limiting a negligence penalty under 1592 to interest on unpaid duties.
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U.S. Customs and Border Protection (CBP)
CBP is the federal agency that administers U.S. customs law, enforces HTS classification, collects duties, conducts audits, and issues binding rulings and penalties for classification errors.
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