Audit every US entry against the documents that already exist
Three parallel audits on every entry: the original submission, the IEEPA refund opportunity and the Section 232 / 301 exposure. One data set. One reconciled view. Every finding quantified to the entry line.
This document defines the scope of a Stream A engagement for US-origin customs entries. It explains what we audit, how we audit it, what documents we ingest and what we deliver. It does not constitute legal advice.
US importers now face four concurrent duty regimes
Every entry is potentially subject to four separate duty calculations. Most importers pay whatever the broker invoices. The question is whether the broker got all four right.
One workflow. Three audits. Every entry.
The three audits run in parallel against the same data set. They are interdependent. A finding in one layer almost always surfaces a recovery or exposure in another.
We reconcile every field on the CBP Form 7501 against the commercial invoice, bill of lading, certificate of origin and packing list. Where a value, classification, origin or quantity does not match the source document, we raise a finding.
This is not a sample audit. Every electronic entry in the engagement period passes through the same reconciliation. Findings are categorized as overpayment, underpayment, classification risk or data discrepancy.
IEEPA tariffs have been paused, reinstated, modified and partially reversed multiple times since April 2025. Every pause creates a potential refund. Every reinstatement creates a compliance exposure. The audit identifies which entries were charged at a rate that was not in force on the date of entry.
Recovery is via CBP Form 19 (Protest), filed by your licensed customs broker within 180 days of liquidation. We identify. Your broker acts. The 180-day window is non-extendable.
The April 2026 Section 232 proclamation reset the rate structure for steel, aluminum and copper. Six rate tiers now apply at 0%, 10%, 15%, 25%, 50% and 200%. Eighteen Chapter 99 headings under 9903.82.xx govern the application. Copper joined steel and aluminum in scope from April 2026 under Chapter 74.
Section 301 tariffs continue to apply to Chinese-origin goods under Lists 1 through 4A at rates between 25% and 100%. Where Section 232 and Section 301 fall on the same entry line, the duties stack and the effective rate frequently lands between 30% and 50% before base HTS duty is added.
The audit identifies entries where Section 232 or Section 301 duty was overpaid (misclassification, incorrect origin, exclusion not applied, sub-15% metal content threshold met) or underpaid (derivative article not declared, incorrect list assignment, melt-and-pour origin missed, smelt-and-cast origin missed). Overpayments route to PSC or Protest. Underpayments route to Prior Disclosure via customs counsel.
Document-first. Entry-level. Every line.
We do not start from the tariff schedule. We start from the shipping documents: the commercial invoice, the bill of lading, the certificate of origin, the packing list and the CBP Form 7501 filed by the broker.
FastNet™, our document-extraction engine, ingests and normalizes these documents into a structured data set. Every field on the 7501 is then reconciled against the source documents. Where a field does not match, a finding is raised.
This approach is deliberately conservative. We do not reclassify. We do not revalue. We reconcile what was declared against what the documents say. The result is a set of findings that are defensible because they are grounded in the importer's own paperwork.
Once the reconciliation is complete, the IEEPA and 232/301 layers run against the same data set. The output is a single dashboard with three views: original submission findings, IEEPA recovery and 232/301 exposure.
Five documents. Four data points per document.
This is the complete list of documents we ingest for a US customs audit. We do not request ERP data, accounting records or internal pricing files.
| Document | Source | Key Fields Extracted | Used In |
|---|---|---|---|
| CBP Form 7501 | Licensed customs broker / ACE | Entry number, HTS code, value, duty, origin, quantity, date | All three layers |
| Commercial Invoice | Seller / exporter | Unit price, total value, product description, Incoterms, currency | Layer 1 (value reconciliation) |
| Bill of Lading | Carrier / freight forwarder | Shipper, consignee, port of lading, port of discharge, weight, container | Layer 1 (origin & routing verification) |
| Certificate of Origin | Exporter / chamber of commerce | Country of origin, manufacturer, preferential treatment indicator | Layers 2 & 3 (IEEPA, 301) |
| Packing List | Seller / exporter | Quantity, weight per item, package count, product breakdown | Layer 1 (quantity & weight reconciliation) |
April 2026 reset the Section 232 rate structure
The 2026 proclamation moved Section 232 from a flat 25% on steel and aluminum to a tiered structure across six rates, expanded scope to copper and introduced new origin-tracing obligations. Every US importer with metal content in their supply chain is now subject to a six-source audit, not a single-source ACE check.
The six rate tiers
What changed in April 2026
- Eighteen Chapter 99 headings under 9903.82.xx now govern rate application across all six tiers
- Copper joined steel and aluminum in scope under Chapter 74
- Melt-and-pour origin (steel) and smelt-and-cast origin (aluminum and copper) certificates required for rate determination
- SIMA (Steel Import Monitoring Analysis), AIM (Aluminum Import Monitoring) and CIMA (Copper Import Monitoring Analysis) licence data must reconcile to the ACE entry
- Annex I-A, I-B and III reference lists define product-specific rate eligibility
- Sub-15% metal content exemption available where qualifying conditions are met under Note 16(c)
- Russia-origin metal subject to a 200% rate under a dedicated Chapter 99 heading
- FTZ privileged foreign status interacts with rate determination at withdrawal
- Section 232 drawback available on subsequent re-export of qualifying goods
Why a single-source ACE audit misses Section 232 exposure
An ACE-only audit sees the HTS code, the declared origin and the duty paid. It cannot see the underlying Bill of Materials, the supplier metal content declaration, the melt-and-pour or smelt-and-cast certificate or the SIMA / AIM / CIMA licence data. A complete Section 232 audit requires all six sources to be reconciled against each entry.
The six-source audit methodology
- ACE ES reports filed by the broker
- SIMA, AIM and CIMA licence data from the importer or broker
- Importer Bill of Materials with metal percentage by line
- Commercial invoices showing unit value and product description
- Melt-and-pour certificates (steel) and smelt-and-cast certificates (aluminum and copper)
- Broker entry worksheets supporting the 7501 filing
Other platforms show you ACE data. MyCustomsInfo® audits the data behind the data.
Open recovery opportunity · Subheading 9903.82.01 at 0%
CSMS #68554727 / 91 FR 23056 created subheading 9903.82.01 with a 0% ad valorem rate for HTS codes subject to Note 16(c) where the goods contain no aluminum, steel or copper. This rate applies retroactively to 12:01 AM ET, 06/04/2026.
That means approximately six weeks of entries filed between 06/04/2026 and mid-May 2026 carry potential Section 232 duty exposure on goods that now qualify at 0%. If your entries include HTS codes under Note 16(c) and the goods do not contain aluminum, steel or copper, your licensed customs broker has a Post-Summary Correction route to recover the overpaid duty.
PSC window: 300 days from the date of entry, non-extendable. The closer you are to the window closing, the smaller the recoverable population.
How the Section 232 audit fits within the three-layer model
Section 232 findings surface inside Layer 3 of the standard Stream A engagement. The same data set that drives the Original Submission audit (Layer 1) and the IEEPA Refund Recovery audit (Layer 2) is the data set Section 232 runs against. One ingestion, three reconciliations.
| Audit finding | Likely recovery or exposure route | Filed by |
|---|---|---|
| 9903.82.01 0% rate not applied to qualifying entry | Post-Summary Correction within 300 days of entry | Licensed customs broker |
| Section 232 derivative article not declared on a qualifying entry | Prior Disclosure under 19 USC 1592 | Customs attorney |
| Sub-15% metal content exemption available but not claimed | Post-Summary Correction within 300 days, or Protest within 180 days of liquidation | Licensed customs broker |
| Russia-origin 200% rate applied where origin trace shows otherwise | Protest within 180 days of liquidation | Licensed customs broker |
| Section 232 paid on qualifying re-export | Section 232 drawback claim within 5 years of importation | Licensed customs broker or drawback specialist |
Compliance boundary. MyCustomsInfo® maintains a live Section 232 rate engine that ingests CBP Federal Register notices, CSMS messages, and Annex updates as they are published. The rate in force on the date of entry is applied to every declaration audited, not the rate at engagement start. MCI surfaces the finding. Your licensed customs broker determines the corrective action and files the relevant document with CBP. This separation is the model validated in CBP HQ H272798 (2017) and HQ H350722 (2026).
What MCI does. What MCI never does.
MyCustomsInfo® operates as an independent compliance auditor under the framework validated by CBP in HQ H272798 (2017) and HQ H350722 (2026). We do not hold a customs broker license and do not perform broker-reserved activities under 19 USC §1641.
What MCI Does
- ✓ Ingest and structure shipping documents
- ✓ Reconcile declared values against source documents
- ✓ Identify discrepancies, overpayments and underpayments
- ✓ Quantify IEEPA refund eligibility per entry
- ✓ Quantify Section 232 and 301 exposure per entry
- ✓ Deliver findings in a structured dashboard and PDF report
- ✓ Provide the data pack required for broker-filed corrections
What MCI Never Does
- ✗ File, prepare or submit any document to CBP
- ✗ Determine or confirm an HTS classification
- ✗ File a Protest, PSC or Prior Disclosure
- ✗ Prepare or file a drawback claim
- ✗ Act as, or hold itself out as, a customs broker
- ✗ Provide legal advice
- ✗ Guarantee any classification, valuation or outcome
Every corrective action sits with the licensed broker. MCI identifies the finding. The importer's licensed customs broker determines the appropriate corrective action and files the relevant document with CBP. This separation is by design, not by limitation. It is the model validated by CBP.
What you receive at the end of each audit cycle
Reconciliation Dashboard
Live, filterable view of every entry, every finding and every discrepancy. Drill from summary to entry line.
PDF Audit Report
Formal findings report suitable for board presentation, external audit and broker instruction.
Recovery Schedule
Entry-by-entry quantification of overpaid duty with the applicable recovery mechanism (PSC, Protest, Drawback).
Exposure Register
Entry-by-entry list of underpayments and compliance risks requiring corrective action by the broker.
Broker Data Pack
Structured data extract formatted for your broker to file PSCs, Protests or Prior Disclosures without re-keying.
IEEPA Rate Timeline
Visual timeline of every IEEPA rate change mapped against your entry dates. Shows which entries fall in a refund window.
Five paths from finding to recovery
MCI identifies the finding and quantifies the amount. The recovery action is filed by the licensed customs broker or customs attorney.
| Route | Authority | When Used | Deadline | Filed By |
|---|---|---|---|---|
| Post Summary Correction | 19 CFR 141.91 | Before liquidation, where any error on the 7501 is identified. | Pre-liquidation | Licensed customs broker |
| Protest (CBP Form 19) | 19 USC 1514, 19 CFR 174 | After liquidation, where duty was overpaid or liquidation was at variance from entry. | 180 days from liquidation, non-extendable | Licensed customs broker or customs attorney |
| Drawback | 19 USC 1313(a), (b), (c), (j) | Goods re-exported, destroyed under CBP supervision or used in manufacture of exported product. | 5 years from importation | Licensed customs broker or drawback specialist |
| Prior Disclosure | 19 USC 1592, 19 CFR 162.74 | Where underpayment is identified before CBP formally initiates an investigation. | Before CBP investigation opens | Customs attorney |
| Reconciliation | 19 USC 1484(b), 19 CFR 141.0a | Where transfer pricing, NAFTA/USMCA preference or computed value requires final adjustment after entry. | 15 months from underlying entry | Licensed customs broker |
US Sample Audit. Path B Briefing Sheet.
One-page overview of the five-day sample audit: what you get back, what we need from you, how your data is protected and the four-step process from NDA to findings debrief.
See the audit in action. Two ways in.
Choose the path that fits where you are. Both lead to the same dashboard. Both respect the same data governance perimeter.
Live Audit on a Demonstration Dataset
569 simulated declarations across 13 origins, December 2024 through April 2026. Section 232, 301 and IEEPA layers active. Full dashboard, full findings, full recovery view. No data exchange required.
- Zero data inflow
- Zero contract overhead
- Instant access
Sample Audit on Your Own Entries
We run the full three-layer audit on three of your recent entries and return the dashboard, the findings and the recovery schedule within five business days. Available under a signed short-form NDA and Data Processing Agreement. Data destroyed thirty days after delivery.
- NDA and DPA before any document inflow
- Isolated sample audit tenant, AWS KMS encrypted
- Thirty-day retention, then verified destruction