Import Compliance Checklist — 10 Steps Before Your Shipment Arrives
Most customs delays, holds, and penalties result from preventable documentation and classification errors. This 10-step checklist covers everything professional importers verify before cargo arrives.
Classify your goods with the correct HS / HTS code
- Identify the 6-digit HS code (universal) and the 10-digit HTS code for the destination country
- Verify classification for each item line — bundles may need separate classification
- Check for any applicable ECCN (Export Control Classification Number) for dual-use goods
- Document your classification rationale — CBP audits frequently challenge misclassification
Misclassification is the #1 cause of CBP penalties. The correct HS code determines duty rate, AD/CVD applicability, and import licensing requirements.
Verify country of origin marking
- Goods must be marked with country of origin (e.g., 'Made in China') — legibly and permanently
- For US imports: 19 USC 1304 requires marking on the article itself, not just outer packaging
- Check for substantial transformation rules if goods are processed in a third country
- Transshipment origin fraud (claiming Vietnam origin for Chinese goods) carries criminal penalties
Prepare a compliant commercial invoice
- Seller and buyer name, address, and contact
- Detailed description of goods (not just 'spare parts' or 'merchandise')
- Quantity, unit of measure, unit price, and total value
- Country of origin, currency of invoice, and Incoterms
- HTS code (US) or HS code (EU/global) — strongly recommended
- Payment terms and port of destination
The CBP 16-field commercial invoice requirement (19 CFR 141.86) — missing fields are the most common cause of shipment exam holds.
Check for required import licenses and permits
- Food, drugs, cosmetics: FDA prior notice required
- Textiles and apparel: quota category and visa requirements
- Agricultural goods: USDA APHIS permits
- Wildlife products: CITES permits (USFWS)
- Firearms and munitions: ATF import license
- Vehicles and engines: EPA/DOT compliance certification
Calculate and confirm customs value
- Use CIF value for EU/most-of-world; FOB value for US/UK/Canada
- Add assists (molds, tooling, designs provided free to seller)
- Include royalties and license fees related to production
- Confirm related-party pricing meets WTO acceptability tests
- Document value basis in writing for your records
Check anti-dumping and countervailing duty orders
- Search access.trade.gov (US) or EU Trade Defence database by HTS code + origin country
- If AD/CVD applies, identify your specific supplier's rate (not just the 'all others' rate)
- Request supplier's CBP-assigned exporter code if applicable
- Factor AD/CVD into your landed cost — these are easy to overlook and hard to recover
Prepare the packing list
- Match item descriptions, quantities, and weights to the commercial invoice
- Include gross and net weight, dimensions, and number of packages
- Separately identify any hazardous materials (IMDG classification)
- Marks and numbers on packages must match the bill of lading
Arrange customs bond and broker
- Single-entry bond required for US imports over $2,500 (or $200 for some categories)
- Continuous import bond (CBP Form 301) recommended for frequent importers
- Choose a licensed US customs broker (CBP License) or EU customs representative
- Provide power of attorney documentation to your broker
File entry before cargo arrives (advance filing)
- US ocean imports: CBP requires ISF (Importer Security Filing) 24 hours before vessel loading
- US air imports: advance cargo information required 4 hours before arrival
- EU imports: Entry Summary Declaration (ENS) required before departure from origin
- Failure to file ISF on time: $5,000 per violation, possible shipment holds
Retain all documentation for 5 years
- US: CBP requires importers to retain entry records for 5 years from date of entry
- EU: 3 years minimum, up to 10 years for VAT records in some member states
- Records needed: invoice, packing list, bill of lading, entry summary, any permits
- FTA preference claims require origin certificates retained for audit
Frequently Asked Questions
What is import compliance?
Import compliance refers to the set of legal requirements that importers must meet when bringing goods across international borders. This includes proper HS code classification, customs valuation, country of origin marking, import licensing for regulated goods, filing of required government agency entries (FDA, USDA, EPA), and payment of all applicable duties and taxes. Non-compliance can result in shipment holds, penalties, seizure of goods, and loss of import privileges.
What documents are required for customs clearance in the US?
For US customs clearance you typically need: (1) Commercial Invoice with all 16 CBP-required fields, (2) Packing List, (3) Bill of Lading or Air Waybill, (4) CBP Entry Summary (Form 7501), (5) Customs Bond, and (6) any agency-specific permits (FDA, USDA, EPA, etc.). For formal entries (shipments over $2,500), a licensed customs broker must file using ACE (Automated Commercial Environment).
How much does customs non-compliance cost?
Penalties for customs violations in the US are governed by 19 USC 1592. For negligent violations: up to 20% of the dutiable value per entry. For gross negligence: up to 40%. For fraud: up to 4x the unpaid duties. ISF late filing: $5,000 per violation. Country of origin marking violations: 10% of dutiable value. EU customs penalties vary by member state but typically equal the unpaid duties plus 10–100% penalty. These penalties are per shipment, not aggregate.
What is an ISF (Importer Security Filing)?
ISF (Importer Security Filing), also called '10+2', is a US CBP requirement for ocean imports. The importer must file 10 data elements (seller, buyer, ship-to party, manufacturer, country of origin, HTS code, container stuffing location, consolidator, etc.) at least 24 hours before the vessel loads at the foreign port. Failure to file, late filing, or filing inaccurate information results in $5,000 per violation and may result in the shipment being held or returned.
Do I need a licensed customs broker?
In the US, CBP regulations require that formal entries (shipments valued over $2,500, or over $200 for some categories) be filed by a licensed customs broker — unless the importer is filing as a non-resident individual. Licensed customs brokers (CBP-licensed, 19 USC 1641) are responsible for the accuracy of the entry and can be held liable for violations. In the EU, indirect customs representation requires the representative to be established in the EU.
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