Reconciliation has become a highly utilized tool for many importers to maximize duty reduction benefits under certain FTA programs or to ensure compliance associated with valuation and 9802 claims. The Reconciliation filing process originally commenced as the ACS Reconciliation Prototype test in October 1998. Through the intervening years from 1998 to the present, there has not been any advancement to codify this program into the regulations as there are so many facets of trade compliance that are touched by the rules around the Reconciliation filing process. These rules can be found here: Reconciliation Interim Guidance. Having been involved with Trade Compliance for over 17 years and with an oversight role for the Tradewin Reconciliation service offering for the past number of years, the one thing consistent across that time span is the growing complexity of trade compliance that, in turn, is driving a constant need for continuing education and for developing experts in key areas of Trade Compliance. Reconciliation is no longer just a filing process. Rather, regulatory knowledge, application, and monitoring underpin the exercise.

The Tradewin Reconciliation team has been working diligently to be that expert to aid with the Reconciliation filing process. Many importers are looking for duty mitigation strategies that may include First Sale for Export, in-depth country of origin analysis, and tariff engineering reviews. All of these are services that for which Tradewin has experts on staff to assist with and are areas that may impact the final valuation of imported items declared on a Reconciliation entry.

As this is the time of year, just before the traditional peak filing season for Reconciliation entries, I gave some thought to what I would wish Reconciliation participants to make note of as they go through the cycle of their financial/accounting reviews and prepare for their filings. Here are some of those reminders that will help with a smooth filing season:

• For new participants, do you have a Reconciliation bond rider in place as an addendum to your Import Bond?
• Do you have a current Power of Attorney in place with your Reconciliation filer?
• Have you, as an importer, become familiar with your company’s internal valuation process or FTA qualification process so that you can share your expectations of the value adjustments or FTA claims with your Reconciliation filer?
• Schedule a pre-filing call with your Reconciliation filer – to make sure both parties understand any of the rules that may pertain to how value adjustments are applied to your entries.
• Have final valuation data ready for your service provider no less than 30 days prior to any statutory deadlines ~ sooner, if possible.
• Grant “read-only” ACE access to your Reconciliation filer
• Remember that CBP is now tying their audit reviews of Reconciliation data submissions back to the original data stored in ACE.
  • When using broker data or internal data as original starting point for your valuation adjustments, the original values should match what is in ACE.
• Let your Reconciliation service provider know if you have any unliquidated Prior Disclosures, Protests, or Post Summary Corrections, as this will impact recommendations for Reconciliation filing.
• Finally, think of how you plan to pay for any duty obligations that may arise if you have increases in value and communicate this to your filer. ACH processing is CBP’s preferred method of payment.

There is a lot that goes on behind the scenes with the growing complexity of the Reconciliation filing process, and Tradewin has fully trained staff on hand to assist you with a smooth filing season. See our Reconciliation Roadmap below to understand the path that you and your Reconciliation filer will travel along during the filing process. Tradewin has experts on staff who walk you through this Reconciliation filing process and answer any questions that you may have.

**Eligible FTA programs for Reconciliation include: USMCA, Chile FTA, CAFTA-DR, Colombia TPA, Korea FTA, Oman FTA, Panama TPA, and Peru TPA.