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 […]


    QUESTION: We’ve identified a recurring issue with one of our suppliers and broker, where the invoice is listed in a not-USD currency and the broker has inconsistently done the currency conversion on the 7501. For any non-revenue entries, we’d just like to correct the value via value Reconciliation. Does anyone else use Recon to correct […]


    QUESTION: Our company is in Recon and we are filing appropriately within the time frames. The next set of filings will greatly increase value over that declared at import. Is there a value increase percentage (eg. over 25 %; over 40 %; etc) uplift which will raise a red flag ? =========== Answers: Difficult to […]

  • Reconciliation Program(s)

    QUESTION: As there is a CBP Recon Program for the USA, are there ones in Canada and Mexico?  If so what they called.  Also can an NRI, who imports into the USA  participate in the Recon Program, or is it just for USA based importers. ============ Answers: Reconciliation is a US program.  In Canada if […]