Import Compliance and Customs Entry Checklist: A Practical Checklist

Summary. This checklist runs an import program from product selection through post-entry review. It front-loads the classification and trade remedy analysis that must happen before a purchase order, then works valuation including the assists importers most often omit, origin and marking, partner-agency requirements, the setup items, the entry sequence with its deadlines, and the annual program tasks including drawback and self-assessment.

What this checklist is for. Running an import program correctly. For the framework, see Customs, Tariffs, and Import Compliance. For the operational sequence, see Importing Goods Into the United States.

Phase 1 — Before the purchase order

Classification:

Work GRI 1 first — heading text plus section and chapter notes. Most classifications end here.
Apply GRI 2, 3(a) most specific, 3(b) essential character, 3(c) last in numerical order, 4, 5, and 6 in order, only as needed.
Search Customs' published rulings for the same or similar merchandise; address any contrary ruling rather than ignoring it.
Write down the subheading and the reasoning, with ruling citations and the date.
Request a binding ruling under 19 C.F.R. Part 177 where the question is genuinely close and the volume justifies it.

What attaches to the code:

Base duty rate under the applicable column.
Section 301 list and rate for the source country — 19 U.S.C. § 2411; check for an open exclusion.
Section 232 — 19 U.S.C. § 1862 — including derivative products.
Antidumping or countervailing duty order covering the description from that country; request a scope ruling if close.
Free trade agreement eligibility and the applicable rule of origin.
Partner government agencies — FDA, USDA, EPA, CPSC, FCC, DOT — and their registration, testing, and filing requirements.
Quota or licensing requirements.
Forced labor exposure — 19 U.S.C. § 1307 and the UFLPA presumption; map the supply chain before shipping.

Landed cost model includes: unit price; freight and insurance; assists; royalties paid as a condition of sale; base duty; Section 301/232; AD/CVD deposits modeled at review risk, not at deposit rate; MPF and HMF; broker, ISF, and exam reserve; domestic freight; and partner-agency testing.

Phase 2 — Valuation

Confirm transaction value is available — no restrictions, no unquantifiable conditions or proceeds, and no related-party influence on price.
Add the statutory additions under 19 U.S.C. § 1401a:
- Packing costs incurred by the buyer
- Selling commissions (buying commissions are not dutiable)
- Assists — materials, components, tools, dies, molds, merchandise consumed in production, and engineering, development, design, artwork, plans, and sketches undertaken abroad
- Royalties and license fees required as a condition of sale
- Proceeds of resale accruing to the seller
Exclude, if separately identified: international freight and insurance; post-importation construction and assembly; duties and federal taxes; buying commissions.
Screen for assists through accounts payable and engineering, not logistics. This is the most commonly omitted addition.
Evaluate first sale eligibility in multi-tier transactions, and document it contemporaneously.
Coordinate any transfer pricing adjustment with customs value in advance.

Phase 3 — Origin and marking

Determine origin for duty and trade remedy purposes — substantial transformation: a new and different article with a different name, character, or use.
Confirm that assembly, packaging, testing, or labeling in a third country is not being treated as a transformation without analysis.
Determine origin for preference purposes under the agreement's tariff-shift and regional value content rules — see 19 C.F.R. Part 181 for the North American framework.
Obtain supplier declarations describing the actual manufacturing operations and component origins, with supporting production records.
Confirm marking: conspicuous, legible, permanent, in English, visible to the ultimate purchaser. Approve a pre-production sample. A removable sticker is not permanent marking.
Distinguish customs marking from an unqualified "Made in USA" claim, which is governed by the FTC's "all or virtually all" standard.

Phase 4 — Setup

Decide who is the importer of record and understand that the responsibility does not transfer.
Obtain an EIN or customs assigned number.
Obtain a customs bond sized against duty, tax, and fee liability — including AD/CVD exposure.
Select a broker; interview on product category, source country, classification process, and AD/CVD screening.
Provide a written instruction letter stating the classifications and requiring escalation of any deviation.
Execute the power of attorney.
Complete partner-agency registrations before the first shipment.
Establish recordkeeping per 19 C.F.R. Part 163 — five years, retrievable, with an owner.

Phase 5 — Supplier documentation

Accurate commercial invoices: complete description, quantity, unit and total price, currency, terms of sale, country of origin, manufacturer identity and address.
Component origin disclosure and a description of operations by country.
Annual origin declaration, refreshed on any process change.
FTA certification with an obligation to provide supporting records on request.
Forced labor representation with audit and traceability rights.
Advance notification of any change in manufacturing location, process, or component sourcing.
Marking to specification, with pre-production approval, at the supplier's cost.
Records retention for the periods United States law requires.
Indemnity for duties, penalties, and costs from inaccurate supplier information.
Incoterm chosen deliberately — DDP transfers the filing but removes visibility.

Phase 6 — The entry sequence

Classification confirmed with the broker in writing before shipment.
Marking verified on a production sample.
Commercial invoice reviewed before the goods ship.
ISF filed within the required window for ocean shipments.
Partner-agency filings ready.
Entry and entry summary filed under 19 U.S.C. § 1484 and 19 C.F.R. Part 141; duties deposited.
Review the entry summary against your own records — classification, value, quantity, origin. Nobody does this, and it is where errors are caught while still free to fix.
Post-summary correction if an error is found before liquidation.
Liquidation monitored.
Protest within 180 days of liquidation if wrong — 19 U.S.C. § 1514; review under § 1515, with judicial review in the Court of International Trade under 28 U.S.C. § 1581.

Phase 7 — Ongoing program

Monthly:

Sample entry summaries against the classification database and commercial invoices.
Confirm every new SKU was classified and analyzed before shipping.
Reconcile duties paid against the landed cost model.

Quarterly:

Review Section 301/232 lists, exclusions, AD/CVD orders, and entity lists for your codes and countries.
Review supplier declarations for currency.
Confirm bond sufficiency.

Annually:

Review classifications against new rulings and the amended tariff schedule.
Refresh supplier origin declarations and FTA certifications.
Run the drawback analysis — 19 U.S.C. § 1313. Claims reach back five years and are the most commonly unclaimed benefit.
Evaluate foreign trade zone and first sale opportunities.
Conduct a self-assessment of a sample of entries.
Train purchasing, engineering, accounts payable, finance, logistics, and quality on what creates a customs consequence.

Phase 8 — When something goes wrong

An error found in your own entries:

Quantify across the full affected period.
Stop the conduct immediately — continuing converts negligence into gross negligence or fraud.
Post-summary correction for unliquidated entries.
Consider prior disclosure under 19 U.S.C. § 1592 before Customs commences an investigation.
Check whether a classification correction moves the goods into a trade remedy before disclosing — the exposure may be a multiple of the base duty difference.

A Request for Information or Notice of Action: respond completely and on time.

A detention: identify the basis — classification, value, admissibility, partner agency, intellectual property, or forced labor — and note that a UFLPA detention requires traceability documentation to the raw material level.

A penalty notice: address the culpability characterization as much as the facts; assemble mitigation — compliance program, prior disclosure, cooperation, remediation, and absence of prior violations.

An audit: produce the compliance file — classification analyses, ruling citations, supplier declarations, assist documentation, written procedures, and training records. That file is what reasonable care looks like.