A focused assessment is CBP's audit of an importer's internal controls and compliance history. It is triggered by risk signals like classification errors, valuation anomalies, and prior penalties. The defense is documented procedures and a clean record, built before the letter arrives.
What a focused assessment is
A focused assessment is CBP's audit program for importers, run by its Regulatory Audit division. Unlike a single-entry review, it looks at the importer's systems: how classifications are decided, how values are declared, how records are kept, and whether the importer has written procedures that anyone actually follows. The audit can cover years of entries, and its findings can lead to penalties, reliquidations, and a compliance improvement plan.
The assessment starts with a letter, and the letter names the areas CBP wants to examine. The importer has a deadline to produce records, and the records have to be complete: entry summaries, invoices, classification work papers, broker communications, and the procedures manual. An importer who cannot produce the records is already in trouble, because recordkeeping is itself a legal requirement under 19 U.S.C. 1508.
Related reading on this site: TariffWatch HQ and Country of Origin Marking: The Four Tests Every Mark Has to Pass cover the neighbouring problems in more depth.
What triggers one
The most common trigger is a pattern in the data. Classification errors across many entries, a valuation that sits below the market for the same product, or a sudden change in the declared value after a tariff increase all flag the account. CBP's targeting systems watch for anomalies, and an anomaly repeated across fifty entries is not a typo. It is a risk signal.
Other triggers are external. A prior penalty, a protest that CBP denied, a referral from another agency, or a tip from a competitor can all start an assessment. So can a new tariff action: when a Section 232 rate rises, CBP watches for importers who reclassify products to escape it, and the reclassification itself becomes the trigger. The audit is rarely a surprise to anyone who reads their own data.
How to be ready before the letter
The preparation is unglamorous and it is the whole defense. Written classification procedures, with the reasoning for each HTS code on file. Valuation work papers that show how the transaction value was determined. A broker management file that records what the broker was told and what they filed. Records kept for five years, as the law requires, in a form that can be produced on a deadline.
The second part is a self-audit. Once a year, pull a sample of entries and check them the way CBP would: classification, value, country of origin, and the 9903 lines. Fix what is wrong before CBP finds it, and document the fix. An importer who finds and corrects their own errors is a compliant importer with a good story. An importer who waits for CBP to find them is a case file.
Frequently asked questions
What is a CBP focused assessment?
An audit of an importer's internal controls and compliance history, run by CBP's Regulatory Audit division. It examines how classifications and values are decided and whether written procedures are followed.
What triggers a customs audit?
Risk signals in the data, like repeated classification errors or valuation anomalies, plus prior penalties, denied protests, referrals, or reclassifications after a tariff increase.
How long must I keep import records?
Five years, under 19 U.S.C. 1508. Entry summaries, invoices, classification work papers, and broker communications must be producible on a deadline.
Can I audit myself before CBP does?
Yes, and you should. Pull a sample of entries once a year, check classification, value, origin, and 9903 lines, fix what is wrong, and document the fix.