REASONABLE CARE FOR CUSTOMS COMPLIANCE

When importing goods into the United States, U.S. Customs and Border Protection (CBP) expects importers to use reasonable care. This means taking practical, good‑faith steps to ensure that the information you provide to CBP is accurate, complete, and compliant with U.S. customs laws.

This guide breaks down CBP’s official guidance into clear, simple language so you can understand what’s expected and how to reduce risk.

KEY POINTS

Reasonable Care - The Basics

Key Areas of Reasonable Care

CBP Guidance

Reasonable Care - The Basics

What Does “Reasonable Care” Mean?

Reasonable care means:

  • Knowing what you are importing

  • Knowing where it comes from and how it is made

  • Providing correct information for classification, value, and origin

  • Keeping proper records

  • Asking for help when things are unclear

There is no single checklist that fits every shipment. Reasonable care depends on your business, your products, and your experience as an importer.

Failure to use reasonable care can lead to:

  • Delayed cargo release

  • Extra inspections

  • Penalties or fines

  • In serious cases, enforcement action

Who Is Responsible?

The Importer of Record is legally responsible for using reasonable care. Even if you use a customs broker or consultant, you are still accountable for the information filed with CBP.

CBP and the trade community share responsibility:

  • CBP provides guidance, regulations, and rulings

  • Importers must follow the rules and provide accurate data

Core Questions Every Importer Should Ask

Before importing, ask yourself:

  • Do we have access to CBP regulations and the Harmonized Tariff Schedule (HTS)?

  • Are our customs entries reviewed for accuracy?

  • Do we understand what our broker is filing on our behalf?

  • Do we have written customs procedures?

  • Are similar shipments handled consistently?

If the answer to any of these is “no,” there may be compliance risk.

Key Areas of Reasonable Care

  • You should be able to clearly answer:

    • What is the product?

    • What is it made of?

    • How is it made?

    • Where was it made?

    Best practices:

    • Use clear and complete product descriptions

    • Assign the correct HTS classification

    • Research prior CBP rulings when needed

    • Request a binding ruling if classification is unclear

    • Keep technical specs, composition details, and supporting documents

  • You must correctly declare the price paid or payable for your goods.

    Make sure you understand:

    • The terms of sale (EXW, FOB, CIF, etc.)

    • Whether assists, royalties, commissions, or rebates apply

    • If the buyer and seller are related

    • Whether the value is final or estimated

    Best practices:

    • Maintain invoices, contracts, proof of payment, and shipping documents

    • Confirm the correct valuation method is used

    • Seek expert guidance for related‑party transactions

  • You are responsible for correctly determining and declaring country of origin.

    This includes:

    • Proper country of origin reporting

    • Correct marking on products or packaging

    • Understanding quota or visa requirements

    • Knowing how the product was manufactured

    Best practices:

    • Communicate marking requirements to suppliers

    • Verify origin before shipping

    • Keep certificates of origin and supporting records

    • Monitor quota fill levels when applicable

  • You must ensure imported goods do not violate U.S. intellectual property laws.

    Ask:

    • Are trademarks or copyrights used?

    • Are the goods genuine and authorized?

    • Are there any exclusion orders in place?

    Best practices:

    • Verify authorization from rights holders

    • Avoid gray‑market or counterfeit goods

    • Keep licensing and authorization documents

  • U.S. law prohibits importing goods made wholly or in part with forced or convict labor.

    You should:

    • Understand your supply chain

    • Know where and how goods are produced

    • Identify high‑risk countries or products

    Best practices:

    • Vet suppliers regularly

    • Include forced labor prohibitions in contracts

    • Conduct internal or third‑party audits

    • Maintain transparency and documentation

  • Some goods are regulated by other U.S. agencies, such as:

    • FDA

    • EPA

    • DOT

    • CPSC

    • USDA

    Best practices:

    • Confirm all required permits and licenses before import

    • Verify if goods are subject to antidumping or countervailing duties

    • Ensure the correct entry type is filed

Recordkeeping Matters

Reasonable care includes maintaining records that support your customs filings.

You should be able to produce:

  • Entry documents

  • Invoices and contracts

  • Origin and marking records

  • Valuation support

  • Certifications and permits

Records must be maintained in accordance with CBP retention requirements. With Entry Insight, your documentation is securely stored and organized—giving you instant access when you need it most. Contact us to schedule a demo and see how it simplifies compliance and recordkeeping.

When to Ask for Help

If something is unclear, it is reasonable care to:

  • Consult a licensed customs broker

  • Seek legal or trade compliance advice

  • Request a binding ruling from CBP

Relying only on general information may not meet reasonable care standards.

How Juno Supports You

Reasonable care is about being informed, consistent, and proactive. Importers who invest in clear procedures, accurate data, and strong documentation are better positioned to avoid delays, penalties, and compliance issues.

If you are unsure whether your current process meets reasonable care expectations, a compliance review or consultation can help identify gaps before they become problems. Contact us at info@junologistics.com to schedule a consultation.

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