Importers may be looking for ways to lower costs and take shortcuts in today’s environment of tariff hikes, increasing costs, and supply chain snarls, but doing so in the area of trade compliance could have a devastating impact.
U.S. Customs and Border Protection’s efforts to enforce trade laws and regulations have always included a focus on what the agency calls its priority trade initiatives. These include antidumping and countervailing duties, trade agreements, intellectual property rights, import safety, agriculture, textiles and apparel, and revenue, including the collection of tariffs being imposed under different statutory authorities. Today, CBP’s enforcement efforts also extend to the prohibition on imports of goods made with forced labor, sanctions against Russia and Belarus, and other measures.
These efforts are having a noticeable impact on importers, with enforcement numbers up consistently over the past five years but even more significantly in just the past year. Comparing statistics for fiscal years 2024 and 2025 (which CBP has published for the first 11 months of that FY), CBP collections have increased 63.8 percent from importer audits, 476.5 percent from recoveries due to entry summary reviews, and 44.5 percent from trade penalties and liquidated damages. Over the last five years CBP has also registered increases in the number of trade penalties issued (9.0 percent) and liquidated damages imposed (147.4 percent).
Importers should therefore be taking steps to (1) identify the types of risk they face, which can include everything from the type of product, to the country of origin and manufacturer, to the nature of the sales transaction, and (2) manage those risks by meeting CBP’s reasonable care standards, which can include consulting a customs expert, establishing effective internal controls, and conducting proactive compliance reviews.
Sandler, Travis & Rosenberg professionals are qualified customs experts skilled at helping importers identify and address compliance issues before they become problems. ST&R also offers a variety of import compliance reviews that will assess risk, analyze internal controls and procedures, identify compliance gaps, and conduct transaction compliance testing. These reviews are tailored to the importer’s circumstances and needs in a manner that measures against CBP standards and delivers a confidential report that will guide compliance teams toward industry-best practices and concrete cost-saving measures.
For more information, please contact messages@strtrade.com or your ST&R professional.
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