For businesses that import goods into the United States, understanding how and why U.S. Customs and Border Protection (CBP) conducts audits is essential. CBP audits are not random “gotcha” events. They are a part of routine compliance oversight designed to ensure that importers follow U.S. customs laws and accurately declare goods, values, and duties.
Below is what every importer should know to prepare, respond, and minimize risk.
What Is a CBP Audit?
A CBP audit is a formal review of an importer’s records and practices to confirm compliance with U.S. customs laws and regulations. These audits can vary in scope:
- Trade Regulatory Audits (TRA): Targeted reviews addressing specific compliance risks identified by CBP.
- Focused Assessments (FA): Comprehensive audits that include assessment of internal compliance controls and operational procedures.
CBP audits may examine how goods were classified, valued, documented, and whether duties and fees were assessed correctly. They also may include an evaluation of internal controls.
Official CBP audit overview: https://www.cbp.gov/trade/programs-administration/audits
Why CBP Conducts Audits
Audits are part of CBP’s compliance and enforcement framework. They help ensure:
- Proper collection of duties, taxes, and fees
Correct application of tariff classification and valuation rules - Accurate determination of country of origin and eligibility for trade programs
- Adequate documentation and recordkeeping systems
CBP uses audits to identify compliance weak spots and enforce policies consistently nationwide.
What CBP Looks at in an Audit
CBP auditors commonly examine:
1. Tariff Classification
Ensuring Harmonized Tariff Schedule (HTS) codes are correct and justified. Misclassification can lead to duty shortfalls and potential penalties.
2. Valuation
CBP reviews declared values to verify they are accurate and consistent with customs valuation principles.
3. Country of Origin
CBP checks that origin determinations are supported with documentation and align with rules governing preference programs.
4. Recordkeeping
Importers must maintain records such as entry summaries, invoices, bills of lading, and compliance documentation for at least five years. CBP can examine any relevant documents during an audit or inquiry.
CBP Recordkeeping guidelines: https://www.cbp.gov/sites/default/files/2025-07/Recordkeeping.pdf
What Triggers a CBP Audit
There is no single trigger for audits, but common risk factors include:
- Repeated classification or valuation errors
- Inconsistencies in import documentation
- Sudden changes in import patterns
- Prior CBP violations or discrepancies
- Complex related-party transactions
CBP’s audit units analyze risk data and referral information to prioritize audits.
Legal Framework and Procedures
CBP audits are governed by federal customs regulations. For example, 19 CFR § 163.11 outlines audit procedures, including:
- Advance written notice of audit scope and timeframe
- Opportunity for an entrance conference to clarify objectives
- Detailed closing and written report timelines
- Use of sampling methods when appropriate
This regulation helps ensure transparency and procedural consistency in audits.
19 CFR § 163.11 – Audit Procedures: https://www.law.cornell.edu/cfr/text/19/163.11
Reasonable Care and Import Compliance
Under U.S. law, the importer of record is legally responsible for accuracy in classification, valuation, and documentation. CBP’s Reasonable Care standard expects importers to conduct due diligence before entry.
CBP’s Informed Compliance Publications offer guidance on how importers can meet these obligations and reduce audit risk.
CBP Reasonable Care guidance: https://www.cbp.gov/document/publications/reasonable-care
How Importers Should Prepare
Preparation pays dividends, whether or not an audit is imminent. Best practices include:
Maintain Organized Records
Keep accurate entry summaries (e.g., CBP Form 7501), invoices, and supporting documentation. CBP may request these at any time.
Develop Internal Controls
Structured procedures for valuation, classification, and country of origin build compliance defensibility.
Regular Self-Assessments
Periodic reviews of past entries, documentation, and compliance processes help catch errors before CBP does.
Use Official CBP Guidance
CBP’s Informed Compliance Publications and Directives & Handbooks offer educational resources on customs procedures and expectations.
During and After an Audit
Once an audit starts:
- Respond promptly and thoroughly to CBP’s requests.
Communicate clearly and avoid speculative explanations. - Document corrective actions, if issues arise.
- Consider professional support, such as customs counsel or compliance specialists.
A cooperative approach may reduce penalties and help demonstrate good faith. Even after the audit closes, implement lessons learned to strengthen future compliance.
CBP audits are serious but manageable. With strong recordkeeping, internal controls, and proactive compliance practices, importers can navigate audits efficiently and reduce risk. Using CBP’s official guidance and preparing ahead of time makes the audit process more predictable and less disruptive.