A reconciliation entry is a filing that lets an importer correct estimated elements of an entry summary after the fact, under 19 U.S.C. 1484(b). The importer files the entry summary on the best available information, flags the estimated elements, and files the reconciliation later with the correct figures. Only four issues can be flagged: value, duty under 9802, classification when a ruling, protest, or court case is pending, and free trade agreement or 1520(d) claims. The deadline for value, classification, and 9802 is 21 months from the entry summary date of the oldest flagged entry. The FTA deadline is 12 months from importation. There are no extensions.
File on the best information, flag what is estimated
The reconciliation program exists because some entry elements cannot be known at the time of filing. The value of the goods may depend on a transfer price that is not yet final. The classification may depend on a ruling that has not been issued. The origin may depend on a free trade agreement claim that is still being documented. In those cases the importer files the entry summary on the best available information, flags the elements that are estimated, and files a reconciliation later with the correct figures.
The flag is the mechanism. The importer marks the entry summary to show which elements are estimated, and that flag is what makes the later correction possible. An unflagged entry cannot be reconciled. The correction has to be filed as a reconciliation entry, not as a post-summary correction, and the reconciliation has to cover all flagged entries in the period.
Related reading on this site: TariffWatch HQ and CBP Form 28 vs Form 29: The Question and the Decision cover the neighbouring problems in more depth.
Only four issues can be flagged
The program is narrow by design. Only four issues can be flagged for reconciliation: value, duty under HTS 9802 for goods assembled abroad, classification, but only when a binding ruling, a protest, or a court case is pending, and free trade agreement or 1520(d) claims. Everything else has to be correct at entry, or corrected through a post-summary correction inside the 300-day window.
The classification restriction is the one that surprises importers. A classification cannot be flagged for reconciliation just because the importer is unsure. It can only be flagged when a ruling, protest, or court case is already pending on the issue. An importer who wants to reconcile a classification needs to have the ruling request or the protest filed first, and the reconciliation waits for the outcome.
The deadlines have no extensions
The deadline for value, classification, and 9802 reconciliation is 21 months from the entry summary date of the oldest flagged entry. The deadline for a free trade agreement claim is 12 months from the date of importation. There are no extensions, and the deadlines are measured from the oldest flagged entry, not from the most recent one, so a reconciliation that covers a long period can have a deadline that arrives sooner than the importer expects.
Two practical requirements complete the picture. Only certain entry types are eligible for reconciliation: types 01, 02, and 06, which cover consumption, warehouse withdrawal, and foreign trade zone entries. And the importer needs a continuous bond plus a reconciliation bond rider, because the reconciliation can increase the duty owed and Customs needs security for the difference. A post-summary correction is the alternative for knowable errors inside the 300-day window, and it is the right tool when the correction is known at the time of filing.
Frequently asked questions
What is a reconciliation entry?
It is a filing that lets an importer correct estimated elements of an entry summary after the fact, under 19 U.S.C. 1484(b). The importer files on the best available information, flags the estimated elements, and files the reconciliation later with the correct figures.
What issues can be reconciled?
Only four: value, duty under HTS 9802, classification when a ruling, protest, or court case is pending, and free trade agreement or 1520(d) claims. Everything else has to be correct at entry or corrected through a post-summary correction.
What is the reconciliation deadline?
21 months from the entry summary date of the oldest flagged entry for value, classification, and 9802. The free trade agreement deadline is 12 months from importation. There are no extensions.
What entry types are eligible for reconciliation?
Types 01, 02, and 06, which cover consumption, warehouse withdrawal, and foreign trade zone entries. The importer also needs a continuous bond plus a reconciliation bond rider.