Section 301 Chinese Import Audits Are Coming!

We have learned that, in the very near future, Customs and Border Protection (CBP) will begin carefully auditing imports of goods subject to Section 301 duties.  As a result, importers may see an increase in the number of Requests for Information (CF 28s); these requests will be based on inconsistencies related to reclassification, changed countries of origins, and valuation decreases. Electronics classified in chapters 84 and 85 of the HTS will likely face the brunt of this early scrutiny, due to the history of these products being predominately duty-free, and concerns surrounding intellectual property rights.

Inaccuracies or inconsistencies in the audited data could result in additional duties, fees, and penalties. It is important that importers proactively exercise reasonable care by retaining any legal documentation necessary to substantiate claims declared to the government. It is also important to note that any external audit questions or actions should be immediately directed to your licensed Customs broker and/or legal representative.

Shapiro will keep you informed of any more announcements regarding the impending Section 301 audits. If you have any questions about your import documentation, please reach out to our compliance team at

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