Import Compliance & Training Programs

Copyright 2025 Bloomberg Industry Group, Inc. (800-372-1033) Reproduced with permission. Import Compliance & Training Programs

Editor’s Note: Creating a strong import compliance plan and training program for employees is one of the best investments an importer can make. Compliance plans and training help avoid customs violations before they occur and can also act as a mitigating factor in the case of a future violation.

In the U.S., individuals and businesses generally don’t need a permit, license, or pre-approval to begin importing products into the country. Many mistake the ease of importing to mean there is no liability or obligation on the part of the importer, when in fact the opposite is true.

U.S. Customs and Border Protection expects importers to exercise “reasonable care” when entering goods into the United States. That means every importer, regardless of size, is legally responsible for ensuring the accuracy of their import declarations, from product classification to valuation, country of origin, and proper recordkeeping.

A formal import compliance plan provides the foundation and structure a company needs to meet the reasonable care standard, reduce risk, and respond effectively if an issue arises.

Without a compliance plan, importers often face common pitfalls, including:

  • Misclassification of goods
  • Undervaluation
  • Inadequate recordkeeping
  • Overreliance on customs brokers

CBP has made clear that exercising reasonable care requires importers to take […]

By |2025-12-24T10:35:00-05:00December 24, 2025|Bloomberg, Bloomberg Import|Comments Off on Import Compliance & Training Programs

Importer End-of-Year Checklist: How to Strengthen Compliance and Prepare for the Year Ahead

For U.S. importers, the end of the year is a critical moment to evaluate compliance, correct issues, and prepare for the year ahead. With tariff changes, supply chain uncertainty, and an increased focus on enforcement, importers who take a proactive approach now will start the new year strong. Here’s a practical checklist for your year-end review.

1. Review Import Data for Accuracy

Begin with a thorough audit of your import data. Confirm that HTS classifications are correct and current, declared values accurately reflect your transactions, and country-of-origin determinations are well documented. Small mistakes can lead to large penalties.

2. Reassess Tariffs and Duty Exposure

Year-end is the ideal time to evaluate whether you are paying unnecessary duties and explore your options for tariff mitigation strategies. Consider what exclusions have changed, whether tariff engineering may reduce costs, or whether sourcing strategies should be updated. Many importers discover duty-saving opportunities simply by reassessing their tariff positions annually.

3. Strengthen Forced Labor Compliance

With UFLPA enforcement intensifying, importers must confirm that supplier information, ownership structures, and supply chain documentation are up to date. Now is the time to verify traceability records, refresh internal training, and assess whether high-risk suppliers require additional review.

4. Update Written Compliance Procedures

If your compliance manual or SOPs haven’t been updated this year, they’re likely outdated. Written processes should reflect current regulations, product updates, tariff changes, and internal workflow adjustments. CBP expects importers to document their […]

By |2025-12-22T09:04:16-05:00December 22, 2025|Best Practices, Import, International Trade, Pre-compliance, U.S. Customs and Border Protection (CBP)|Comments Off on Importer End-of-Year Checklist: How to Strengthen Compliance and Prepare for the Year Ahead

Breaking Trade News: New 301 Nicaraguan Tariffs, HTS Update, Administration Threatens New Tariffs on Mexico & Canada

Here is a recap of the latest customs and international trade news:    

Administration

  • Via a Truth Social Post, President Trump threatened to impose additional tariffs on Mexico for allegedly violating the U.S.-Mexico Water Treaty. Trump gave a deadline of December 31 for Mexico to release 200,000 acre-feet of water. Mexican President Claudia Sheinbaum subsequently said that they will be unable to meet that deadline.
  • At a roundtable at the White House on December 8, President Trump promised to impose “severe” tariffs on fertilizer imports from Canada to bolster U.S. fertilization production.

Customs and Border Protection (CBP)

  • CBP announced in the ACE Development and Deployment Schedule that the agency is developing a functionality in ACE that will improve CBP’s ability to collect penalty payments for failure to meet in-bond shipment requirements.
  • CBP officers in Louisville seized three shipments of counterfeit jewelry from Hong Kong and Taiwan. Had all these goods been genuine, the shipments would have had a combined MSRP of over $18M.
  • CBP released Harmonized System Update 2542, which contained 40 Automated Broker Interface records and 13 Harmonized Tariff Schedule records. 

U.S. Department of Commerce

  • The Commerce Department published […]
By |2025-12-12T11:24:31-05:00December 12, 2025|news, Snapshot|Comments Off on Breaking Trade News: New 301 Nicaraguan Tariffs, HTS Update, Administration Threatens New Tariffs on Mexico & Canada

ICYMI: Electronics Company Pays $11.8M to Resolve Duty Evasion Allegations

The Department of Justice announced that Harman International Industries, Inc., an audio electronics company, agreed to pay $11.8M to settle allegations of evading duties on goods made of aluminum from China.

What Happened

For a period of over ten years, from June 2011 to March 2023, Harman knowingly imported heat sinks that contained extruded aluminum from China without paying the required antidumping and countervailing duties (AD/CVD).

The settlement also reveals that when Harman discovered its failure to pay AD/CVD, the company concealed this fact and decided not to disclose it to the U.S. government. 

This case arose from a whistleblower lawsuit filed under the False Claims Act, which permits private parties to file suit on behalf of the United States for false claims and share in a portion of the government’s recovery. The whistleblower in this case will receive over $2M of the settlement proceeds.

Enforcement is a Top Priority for the U.S. Government

High tariffs in the current trade environment have created a higher incentive to cheat. The U.S. government has made clear that enforcing customs laws is a top priority. 

For example, on May 12, 2025, Matthew Galeotti, the Head of the U.S. Department of Justice’s Criminal Division, sent a memo to all criminal division personnel highlighting the focus areas of the division for white-collar crime.

The memo included a […]

By |2025-12-12T09:10:11-05:00December 12, 2025|Enforcement, Import, International Trade, U.S. Customs and Border Protection (CBP), U.S. Department of Justice (DOJ)|Comments Off on ICYMI: Electronics Company Pays $11.8M to Resolve Duty Evasion Allegations

Breaking Trade News: Revised 7501 Instructions, $11M AD/CVD Fine, UK Pharmaceutical Deal

Here is a recap of the latest customs and international trade news:

Customs and Border Protection (CBP)

  • CBP has expanded its partnership with data technology company Kharon to enforce the Uyghur Forced Labor Prevention Act and other trade laws.
  • CBP is revising instructions for Form 7501, which is used to clarify what defines country of melt and pour for steel imports and what defines country of smelted and cast for aluminum imports. Comments on the revisions are due December 31. 
  • CBP officers in Cincinnati seized a shipment of 52 counterfeit watches from Colombia. Had these goods been genuine, the shipment would have had a combined Manufacturer’s Suggested Retail Price of $6.37 million.
  • Reminder: the annual user fee for customs brokers is due January 30, 2025. 

Department of Justice

  • Electronics importer agreed to pay more than $11 million to settle allegations it evaded AD/CV duties on aluminum extrusions from China. 

U.S. Department of Commerce

  • Commerce, in partnership with USTR, published a notice stating that reductions of reciprocal tariffs on South Korea, as well as of Section 232 tariffs on South Korean lumber, will take retroactive effect on Nov. 14 under the recently agreed trade […]
By |2025-12-05T09:12:31-05:00December 5, 2025|news, Snapshot|Comments Off on Breaking Trade News: Revised 7501 Instructions, $11M AD/CVD Fine, UK Pharmaceutical Deal

New WRO Issued Against Goods Made in Mauritius by Firemount Group

U.S. Customs and Border Protection (CBP) issued a  Withhold Release Order (WRO) against imports made in Mauritius by manufacturer Firemount Group Ltd. (Firemount) after an investigation indicated forced labor use. This WRO was the fourth issued in 2025. CBP now oversees and enforces 54 WROs and nine Findings.

What Happened

On November 18, 2025, CBP issued the WRO against garments, apparel, and textiles manufactured in Mauritius by Firemount. CBP will immediately detain imports subject to the Order. The WRO was issued based on information that reasonably indicates forced labor was used in violation of 19 U.S.C. §1307.

In making this determination, CBP conducted an investigation and analyzed supporting evidence, including interview questionnaires, audio recordings and transcripts, open-source reports from nongovernmental organizations, news media, and academic research.  

The evidence demonstrated that Firemount workers are subject to four International Labour Organization indicators of forced labor: abuse of vulnerability, debt bondage, deception, intimidation, and threats. 

WRO Background 

The strategic use of WROs by CBP has been especially effective at identifying certain nations, industries, and companies that employ forced labor. CBP issues WROs after receiving information that reasonably indicates the use of prison or forced labor at any point in an imported product’s supply chain. Before the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), the United States had only implemented 30 WROs in the previous five decades. […]

By |2025-12-01T10:04:13-05:00December 1, 2025|Enforcement, Forced Labor, Import, International Trade, U.S. Customs and Border Protection (CBP)|Comments Off on New WRO Issued Against Goods Made in Mauritius by Firemount Group
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