19 U.S.C. § 1484 requires importers to exercise “reasonable care” in classification, valuation, and other entry decisions. Standard is non-delegable – using a customs broker does not satisfy the importer’s reasonable care obligation. Failure to meet standard supports negligence finding under § 1592.

This guide covers Reasonable Care Standard. Customs compliance audit work covers CBP focused assessments, CBSA Trade Compliance Verifications, and ongoing compliance program work.

For SMB importers, the practical implementation depends on volume, sector, and operational structure.

What reasonable care requires

Active engagement with classification accuracy, valuation correctness, country-of-origin documentation, FTA qualification. Not delegable to broker.

Examples of compliance

Annual compliance review, classification verification, supplier vetting, USMCA Certificate management, internal training.

Examples of non-compliance

Blindly accepting broker classifications, ignoring CF28 information requests, no internal compliance review.

Audit defense

Documentation of reasonable-care activities supports negligence-level penalty (rather than gross negligence or fraud).

Frequently asked questions

When is this most relevant?

For SMB importers facing audit, refund opportunity, or compliance gap remediation.

What documentation matters?

CBP forms, supporting records, supplier certificates, and BOM analysis as applicable.

What is the timeline?

Simple matters 2-4 weeks; complex audits or refund filings 3-12 months.

What does this cost?

Project scope $5,000-$45,000 depending on complexity. Refund work often on contingency.

How do I begin?

Book a 15-minute scoping call. We confirm fit before any engagement.

Get started

Already received an audit notice? Contact us within 48 hours.

About the author

Kyle Peacock is the Principal of Peacock Tariff Consulting, an independent tariff and customs advisory firm serving SMB importers across the U.S., Canada, the U.K., and the E.U. He has been quoted in Forbes, CNN, The Washington Post, BBC, CBC, CTV, Financial Post, Nasdaq, Supply Chain Brain, and Harvard Business School publications. Connect on LinkedIn.