Customs Compliance Audit: A Short Guide
- Sal Orozco
- Jun 9
- 3 min read
"An ounce of prevention is worth an ounce of cure" - Benjamin Franklin
Think Customs is Just Paperwork?
Customs compliance isn't a back-office chore.
It's a battlefield where details are weapons, and your margin is what's at stake. If you're importing and not paying attention, you're already paying the price. One misstep in paperwork can cost thousands—fast.
Imagine declaring your high-end apparel shipment using the wrong HS code and suddenly being slapped with triple the duties.
Not fun.
So... What Trips the Audit Alarm?
No, it's not just bad luck. Here’s what customs is actually watching:
🎲 Random Selection: Sometimes you’re just the lucky winner.
🚨 Inconsistencies: Say your invoice says $2.50 per unit, but your declaration says $1.90. Hello red flag.
🔥 High-Risk Categories: Electronics, pharmaceuticals, fashion—sexy to consumers, spicy to customs.
🕵️ Past Issues: Once flagged, always on the radar. Your file has a memory.
👪 Related-Party Deals: Customs wants to know if you’re giving your cousin a “special” price that doesn’t reflect real market value.
🏷️ FTA Claims: Big savings mean big scrutiny. Don’t mess up.
Rookie Moves That Bleed Profits
Let’s talk about the mistakes that keep importers up at night:
❌ Wrong HTS Code: Using the code for cotton tees on your poly-blend hoodies? Get ready for a bill—and a possible penalty.
❌ Undervaluation: That “friendly” invoice might save you today and cost you tomorrow when customs checks market pricing.
❌ FTA Slip-Ups: Claiming duty-free under USMCA without origin certificates? That’s a repayment + penalty cocktail.
❌ Poor Recordkeeping: Customs walks in and asks for 2019’s invoices. You say, “We switched systems.” They say, “We don’t care.”
❌ Dual-Use Missteps: That high-tech drone you imported might qualify as military grade. Oops.
❌ Broker Confusion: If your broker isn’t briefed properly, they’ll guess. And when they guess wrong, you pay.
What To Do Before Customs Knocks
Treat compliance like a business function, not a fire drill. Here's your proactive checklist:
Designate a Customs Lead: One owner. One playbook. No confusion.
Audit Your Last 3 Years: Yes, three. Dig deep, spot the patterns, and clean it up.
Verify Classifications: One SKU, one code. Consistency is king.
Check Your Valuations: Did you include freight, assists, packaging? Customs will.
Confirm Country of Origin: If you’re claiming FTA benefits, prove it.
Documentation Game Tight: Certificates of origin, BOLs, commercial invoices—all neatly stored and accessible.
Spot-Check Your Own FTAs: Choose a few shipments and test your own compliance.
Scrutinize Related Pricing: Importing from your parent company? Prove it’s a fair market price.
Test Your Broker’s Work: Compare what you sent vs. what they filed. Spot the disconnects.
Build a Risk Map: Know where the cracks are before customs points them out.
What Real Preparation Looks Like
DO:
✅ Assign one person to own customs
✅ Keep communication clean, simple, and written
✅ Show them a clear, consistent process
✅ Prepare like they’re already watching
✅ Think like an auditor
DON’T:
❌ Assume your broker knows your business
❌ Let someone wing it in an audit
❌ Use "that’s how we’ve always done it" as a defense
❌ Share more than necessary
❌ Push blame around the table
After the Audit Smoke Clears
They came, they saw, they nitpicked. Now what?
Post-Mortem Time: Gather your team. Dissect what happened and what slipped.
Fix Fast: Get your gaps closed before the next one rolls through.
Schedule Internal Reviews: Treat it like brushing your teeth—regular, boring, essential.
Update SOPs: Make sure your playbook reflects reality, not fantasy.
Close the Feedback Loop: Train the team. Update the docs. Stay audit-ready.
Final Word
You don’t need perfection.
You need proof you’ve got a system—and that you’re in control.
Customs wants to see a company that takes compliance seriously, not one that scrambles when the audit letter shows up. This isn’t just risk management.
It’s how smart businesses protect their bottom line—and their reputation.