Reconciliation entries allow importers to file initial entries with estimated duty and reconcile to actual duty later. Flagged entries get reconciled within 21 months of import. Useful for: unfinalized pricing (related-party transactions), USMCA preference uncertainty, AD/CVD scope unsettled, FTA qualification pending verification.
This guide covers Reconciliation Entries. Refund and recovery work spans multiple statutes and mechanisms – drawback, CAPE refunds, PSCs, protests, reliquidation under § 1520.
For SMB importers, the practical implementation depends on volume, sector, and operational structure.
When to use reconciliation
Unfinalized pricing, FTA qualification pending verification, AD/CVD scope unsettled, related-party transfer pricing.
How flagging works
Flag entries at filing. CBP allows up to 21 months for reconciliation. Final true-up filed when actual values known.
True-up process
File reconciliation entry with actual values. CBP processes refund (if overpaid) or assesses additional duty (if underpaid).
IEEPA refund interaction
Reconciliation entries with IEEPA component spread across multiple periods create CAPE filing complexity. Phase 2 expected to handle these.
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
Run a refund opportunity audit on your import history. Free preliminary estimate.