Since 1993, Reconciliation entries have been a pivotal tool for US importers to simply and expediently make changes to certain elements of an import entry. While some very, very limited classification and 9802 changes can be made using reconciliation filings, the vast majority of adjustments are for value changes after importation or retroactively claiming a free trade agreement like USMCA and 9802. 

Reconciliations serve as the most compliant and expedient tool for changing values, 9802, and FTA claims. Reconciliation allows the importer to change multiple entries at once rather than submitting multiple PSCs or 520(d) claims.

Although reconciliation as a tool is not codified in the regulations, it is important to note that a reconciliation entry (entry type 09) falls under the same regulations that govern the underlying entries and, therefore, should be afforded the same reasonable care and preparation for regulatory review by Customs and Border Protection (CBP). When CBP has questions, they will contact the reconciliation provider informally or via a CF-28 requesting additional detail on the reason for the changes, as well as supporting documents.

Tradewin is one of the largest reconciliation providers in the United States. Across our filing activity, we are seeing an uptick in reviews of reconciliation entries by CBP in the form of email inquiries and requests for information through the CF-28 process. These reviews often require that the importer provide additional information and/or data evidence that the reconciled information is accurate and follows the subject regulations and record-keeping requirements.

As we move into the 2024 reconciliation filing year, please remember to periodically review written processes and procedures, conduct audits for compliance, and remember to keep records for the statute of limitations in a format that is easy to retrieve and supports the reported reconciled information.