US Import Readiness Audit.

A licensed broker’s job, under 19 CFR Part 111, is to file entries competently and represent you before CBP. Most brokers file the classification and valuation you or a prior compliance function gave them — their license doesn’t obligate them to independently re-derive it from your bill of materials, and it doesn’t obligate them to audit your historical filings for accuracy.

That split matters because CBP’s civil penalty structure under 19 USC 1592 attaches to the importer, not the filer. A negligent violation carries a penalty of up to two times the unpaid duties, or 20% of dutiable value if no duty was underpaid. Gross negligence goes to four times unpaid duties, or 40% of dutiable value. Fraud goes to the full domestic value of the merchandise. On a $25M import book, the range between “we filed correctly” and “CBP found a pattern going back three years” is not a rounding error.

The audit exists to sit in that gap: an independent, cited review of what’s actually being filed, before CBP — not your broker — is the one who finds the problem.

Four areas, each with cited findings.

An analysis of your active SKU list at the 10-digit HTS level. For each classification, the report cites the CBP ruling, chapter note, or GRI application that supports the assignment. Where existing classifications are wrong, the report documents the correction with authority and estimates the retroactive duty exposure or refund opportunity.

Review of your commercial invoice treatment, transfer pricing methodology, and disclosure of statutorily required additions to value: assists, royalties, commissions, packaging, and proceeds of subsequent resale. Where valuation is understated, the report identifies the gap. Where valuation is defensible but at risk of challenge, the report recommends supporting documentation.

Country-of-origin substantiation for products claiming preferential treatment under KORUS, USMCA, USJTA, or other applicable agreements. The report reviews your bill-of-materials, the applicable rules of origin, and the substantiation you would need to withstand a CBP verification request. Where qualification is defensible, the report structures the documentation. Where qualification is at risk, the report explains why and recommends corrective action.

Analysis of your import volume against pending and enacted duty regimes: Section 232, Section 301, IEEPA, Chapter 99. The report identifies where existing classifications sit in higher-duty scope, where reclassification might reduce exposure, and where scenario planning is needed for pending regulatory changes.

A written report, delivered as PDF, typically thirty to sixty pages. Each finding cites authority — a CBP ruling number, a chapter note, a regulatory reference. The report is structured so your broker can use it directly: classification decisions with reasoning, valuation methodology with substantiation, FTA qualification with substantiation checklists.

If we don’t have high-confidence guidance on a specific question, we say so explicitly and recommend a broker filing for a binding ruling.

Week 1. Scoping call, data collection, initial SKU review.

Week 2. Analysis, ruling research, drafting.

Week 3. Draft report delivery, walkthrough call, revisions.

Week 4. Final report, implementation guidance, broker handoff if applicable.

Total elapsed time is three to four weeks depending on your team’s responsiveness and the complexity of the SKU list.

Starting at $19,500 for engagements under 100 SKUs and under $25M in annual import value. Larger engagements custom-quoted; see Pricing → for the full tier structure.

Fixed-fee, not hourly. Written quote provided within three business days of scoping call. Quoted exclusive of any applicable sales, use, or value-added tax — see Pricing for how that’s handled.

Foreign manufacturers with $50M–$500M in annual revenue, importing 50–500 SKUs into the US. Companies in the middle of the following situations often benefit most:

• Recent expansion into US direct sales with existing brokers inherited from prior arrangements
• Uncertainty about FTA qualification for products crossing under KORUS or USMCA
• Recent Section 301 or IEEPA action affecting import scope
• Preparation for a CBP audit or Focused Assessment
• Change in ownership requiring compliance function review

Not sure where you fall? Ask Tarsis-Haven a specific question about your product, FTA claim, or a recent Section 301 action — free, no scoping call required — before you decide whether the full audit is worth it.

Companies with existing full-time compliance functions and Big 4 advisory relationships. Companies importing under 20 SKUs where the exposure math doesn’t justify the audit fee. Companies importing high-volume consumer ecommerce SKUs — that’s Zonos, Passport, or Avalara territory.

If Tarsis isn’t the right fit, we say so on the scoping call. Referrals to Big 4 or category specialists on request.