By Graham Anderson, Co-Founder of Importal
For the better part of the last decade, most importers barely thought about their customs broker. Tariff rates were relatively flat, entries were straightforward, and there was a comfortable trust built up between importers and the brokers filing on their behalf. Things were, as Graham Anderson puts it, “comfortably numb.”
That era is over.
Between the tariff volatility of 2025, the complexity of new duty categories, and now hundreds of billions of dollars in IEEPA refunds flowing back through the system — customs compliance has become one of the highest-stakes operational functions a brand can have. And most importers still aren’t paying attention to it.
This guide will walk you through why auditing your customs broker has become non-negotiable, what to look for, how to do it, and what happens if you don’t.
Why you need to audit your broker now
Your customs broker files entries on your behalf. But here’s the thing most importers don’t realize: the liability for those entries sits with you, not them.
Think of it like taxes. When you hand your documents to an accountant and they file incorrectly, the IRS comes after you. Customs works the same way. Your broker is consuming your information and declaring it — but you are the importer of record, and any errors, penalties, or recourse lands on your desk.
This has always been true. What’s changed is how much those errors cost, how likely you are to get caught, and how much money is now at stake.
The tariff complexity problem
The last two years introduced a level of compliance complexity that the industry had never seen. In-transit exclusions, 232 steel and aluminum content declarations, IEEPA tariff codes, shifting country-specific rates — entries that used to require one HTS code now require up to four. Brokers are human. Errors that were rare became common, and errors that used to cost a few hundred dollars now cost tens of thousands.
One example that illustrates the stakes: a customer’s broker declared one million Taiwanese dollars as one million US dollars. A simple currency error. But it resulted in a significant overpayment of tariffs that had to be clawed back through a correction process.
Another: brands importing products like insulated tumblers found themselves unable to provide the steel mill certificate and country of smelt required for 232 tariffs. If you couldn’t provide that documentation, customs defaulted your steel origin to Russia — and charged you a 200% embargo tariff. Importers who didn’t catch that error overpaid massively, when they could have recovered 150% of the tariff with the right documentation.
CBP is coming for revenue — and they have new tools
Customs and Border Protection is a tax collecting agency. And right now, they have 300 billion reasons to audit importers more aggressively.
With IEEPA refunds flowing back through the system, CBP has explicitly stated that refunds will be issued “unless compliance issues are found.” That means every entry tied to a refund request is going to receive some level of scrutiny — human or automated. If your entries have errors, requesting a refund may be what surfaces them.
Beyond refunds, CBP is adopting AI to flag shipments and identify which importers to audit. Historically, audit selection was driven largely by entry volume — Fortune 500 companies with thousands of monthly shipments got scrutinized more than small importers. That’s changing. With better technology and strong revenue incentives, the audit net is widening.
The five-year lookback window makes this especially sobering. CBP can audit any entry up to five years after import. That means entries filed during the most chaotic tariff period in recent memory — 2025 — are sitting in your liability column until 2030.
What the penalties actually look like
If CBP audits your entries and finds errors, the penalty structure is steep.
Penalties run 1.5x to 2.5x the duties owed. If you underpaid $50,000 in duties, you’re looking at a penalty of $75,000 to $125,000 on top of what you owe. There are also cases where import restrictions are imposed, and in serious situations, personal liability for LLC members.
CBP distinguishes between negligence (you didn’t know, but should have been paying attention) and gross negligence (you knew and didn’t address it). Both carry significant penalties. The distinction matters less than people think — the monetary consequences are serious either way.
And if you think your broker will share that liability — they won’t. It’s your name on the customs declaration.
The three things to check on every entry
When auditing an entry, there are three fields that matter most. All three tie directly to tariff calculations, and errors in any of them mean you’re either overpaying or underpaying duties.
1. Country of origin Is the declared country of origin correct? In the current tariff environment, the difference between China and Taiwan, or Mexico and a third country, can mean radically different duty rates. This is one of the most consequential fields on an entry and one of the most frequently wrong.
2. HTS classification Did your broker declare the correct 10-digit HTS code? Classification determines your tariff rate, and it’s an area where brokers make mistakes regularly — especially with new or complex products. Importantly, your broker classifying your goods doesn’t absolve you of responsibility. You need to own your classifications. Think of it like your own tax return: you can have someone prepare it, but the filing is yours.
3. Declared value Did the broker declare the correct invoice value in the correct currency? Currency errors are more common than you’d think, and the impact is proportional to shipment value.
These three checks should happen on every entry, every time. There are other compliance checkpoints — supplier declarations, related party transactions — but country of origin, classification, and value are where most of the money is lost.
The audit timeline: what you need to know
10 business days. That’s how long you have after customs clearance to tell your broker to correct an entry before it’s finalized. Within those 10 days, corrections are straightforward — no penalties, no scrutiny, just a fix. Once you clear customs, the clock starts. When your broker sends you the customs release forms, put a reminder on your calendar.
314 days from the date of import to file a Post Summary Correction (PSC). A PSC is a self-declaration to CBP that an error was made and needs to be corrected. It’s the primary vehicle for recovering overpaid tariffs. Filing a PSC does put that entry on CBP’s radar to some degree — they track the ratio of entries to PSCs — but self-correcting is far better than waiting for CBP to find it.
180 days after that to file a protest, which is a more formal and labor-intensive correction process with greater scrutiny from customs.
The math matters here: the longer you wait to catch an error and file a PSC, the longer it takes to get a refund. Refunds typically take a few months to process. If you’re filing on day 300, you’re pushing your refund well into the following year.
How to start auditing your entries
If you’ve never done this before, don’t try to boil the ocean. Start with last month’s shipments and work backwards.
Step 1: Get your ACE data. Your Automated Commercial Environment (ACE) portal data is your single source of truth for every import declaration from the last five years. Pull it and look for anomalies. If you only import from China and you see entries declaring Germany or France as the country of origin, something is wrong. Unusual countries, unusual values, and unusual classification codes are your first flags.
Step 2: Find your biggest duty payments. Sort by the largest payments first. These are where overpayments hurt the most and where the refund opportunity is greatest. Start your detailed review there.
Step 3: Check origin, classification, and value on each entry against your commercial invoice and shipping documents. This is manual work — you’re going line by line — but it’s the only way to catch errors with confidence.
Step 4: Flag new SKUs immediately. Every time you launch a new product, audit the first few entries closely. It’s far easier to catch a classification error on shipment one than to discover it on shipment thirty and have to refile everything.
Step 5: Pay particular attention to high-scrutiny origins. China, Mexico, Canada, India, the EU — any country that has been subject to significant tariff action in the last two years deserves extra attention on every entry.
Who should own this internally
At a Fortune 500 company, there’s usually a dedicated trade compliance team. For everyone else, this belongs to supply chain and logistics operations — not finance.
The reason is timing. Supply chain has visibility to when shipments clear customs. They can start the audit clock immediately and catch errors within the 10-day window. If audit responsibility drifts to finance, you’ve almost certainly missed your window for easy corrections and are now relying on PSCs and protests.
If you don’t have internal trade compliance expertise, that’s a gap worth addressing — either through hiring, training your ops team, or working with a technology-enabled broker who builds audits into their process.
What to do if you keep finding errors
There’s a saying in the industry: you date your freight forwarder and you marry your customs broker. Like any marriage, it runs on trust. And if that trust is being eroded on every shipment, it’s time to consider a change.
Before you fire your broker, work with them. Customs compliance is genuinely harder than it’s ever been, and your broker’s errors may be a process problem that can be fixed rather than a competence problem that can’t. Give them the chance to improve.
At the same time, run trial shipments with a tech-enabled broker in parallel. Test a few entries, check their accuracy, evaluate their communication and response time. Compare the results directly. The biggest mistake importers make when switching brokers is going all-or-nothing — firing one broker immediately and onboarding another without overlap. That transition period is when errors spike. Trial shipments give you a real apples-to-apples comparison before you commit.
Treat audit like insurance
You might get through the next five years without a CBP audit. Plenty of importers do. But an audit isn’t just about avoiding penalties — it’s also about recovering money you’ve already overpaid. Most importers running a serious audit process find 10–15% of duties coming back through corrections. Across a meaningful import program, that’s real money.
Think of it as an insurance policy. You have insurance on your car and your home not because you expect disaster, but because the downside is too large to ignore. Your import operation is no different. With a five-year lookback, AI-driven CBP enforcement, and hundreds of billions of dollars in refunds under scrutiny, the risk profile has never been higher.
The good news: hundreds of thousands of importers across the US are all navigating this at the same time. You’re not alone in it. But the ones who come out ahead will be the ones who stopped trusting blindly and started checking their work.
Graham Anderson is the Co-Founder of Importal, an AI-native licensed customs brokerage that automates compliance from origin to destination. This post was developed in partnership with Izba.
