QUESTION: I have 2020 entries flagged for Value Reconciliation for a business unit (IOR) that stopped importing in 2020 and is in process of being shut down.  Due to the way our transfer pricing & limited risk distributor agreements are structured and the expenses associated with shutting down the business unit, our reconciled Customs value […]

  • Liquidation and Recon filing

    OT Fact Sheet: Origin Certification Requirements QUESTION: This just came in: The Court of International Trade will stop liquidation of unliquidated entries subject to the List 3 or 4A Section 301 China tariffs imported by the thousands of plaintiffs in the Section 301 litigation, a majority of judges on the three-judge CIT panel said in […]


    OT Fact Sheet: Origin Certification Requirements QUESTION: This question relates to a Value Reconciliation where a downward pricing adjustment is insignificant. The Reconciliation External Guidance doc states that the full data must be transmitted even if there is no revenue impact. What if the change is insignificant, so .2% or .4%? Is there a de […]


    QUESTION: Our executive team posed the following questions regarding value reconciliation and hoping to get some guidance. Does the importer always have to submit a change if the value is not exact – in other words, is there a duty amount (under or over threshold) that could be considered a “No Change”? For example, if […]

  • Value Reconciliation Auditing

    QUESTION: Wondering if anyone else in the industry does value reconciliation?  If so, do you do an audit on your reconciliation?  What are some of the important points you would recommend to cover in a reconciliation audit? ============= Answers: Just like any other entry we audit that the data reported was accurate and defensible through sufficient […]


    QUESTION: After doing a deep dive, I have discovered that a past years’ recons were filed as no-change, when they should have had the value adjusted up (meaning more duty owed, mpf, hmf, etc..) 8 months worth. Is filing a PD the best way to correct this with CBP? (including submitting payment for the additional […]

  • PSCs and Reconciliation

    QUESTION: We have many PSCs and protests pending, mostly for 301 refunds, and we will be submitting our value reconciliation this summer.  I am concerned about trying to reconcile an entry while a PSC / protest is occurring simultaneously.  What are your thoughts? %%%%%%%%%%% ANSWERS: On you open PSC’s and Protest, It is my understanding […]


    QUESTION: Have  a question about CBP’s Reconciliation Program (Recon).  The Recon is available to any importer (IOR).  Is the Recon program available to a Non-Resident Importer (NRI) who imports using a Customs assigned number? Also, does Canada and Mexico have a similar Recon Program? What about other countries having a Recon program? ************** Answers: Yes, […]

  • Value added Recon/301 Tariffs

    QUESTION: My Company filed Value recon in Aug 2019 for year ending 2018 which included commodities that had the additional 301 China tariff duty added (25%). Now our products fall under the Product exclusions.  Does anyone know if there is a way to file an adjustment against the assist value added on the recon entry?  […]

  • Application for reconciliation

    QUESTION: Can you advise how long it takes to apply for and receive approval to participate in reconciliation? Are there any best practices or things that we need to keep in mind related to the program? %%%%%%%%%% ANSWERS: There is no more formal application to participate in entry reconciliation. You need to obtain a reconciliation […]


    QUESTION: We have several entries for which we would like to make changes to the HTS classification used. The HTS changes would result in my company receiving money back from CBP. These entries have already liquidated and have had value reconciliation filed on them. The reconciliation entries have also liquidated. Do we have any options […]

  • RECON filing for First Sale?

    QUESTION: Our company had been flagging entries for RECON when 301 kicked in last September with the intention of (obviously) updating the value. 301 occurred while in the process of assessing both first sale viability and a pricing restructure. We have determined the pricing restructure is not eligible for RECON as there was no agreement […]