Reconciliation is a CBP program that allows importers of record to file an entry summary using estimated information for specific elements that are not yet final, and to reconcile the final amounts later — generally within 21 months of the entry date. Authorized by 19 U.S.C. § 1484(b) and administered under 19 CFR Part 10.171-10.180.
Reconcilable issues (the "flagged" elements):
- Value — assists, royalties, indirect payments, transfer pricing adjustments that aren't yet final at entry
- Classification — for goods subject to pending binding ruling requests
- Section 9802 / chapter 98 — U.S. content claims for goods assembled abroad of U.S. components
- FTA preference claims — particularly USMCA, KORUS, CAFTA-DR, and others where origin determination requires post-import data
How it works:
- The importer files the underlying entry summary with the "RECON" flag indicator
- Liquidation is held open (suspended) for the flagged issue
- Within 21 months of the entry date, the importer files the reconciliation entry with the final data
- The reconciliation entry is liquidated; refunds or bills issue accordingly
Form and bond. A separate reconciliation bond rider is required on top of the importer's continuous bond. The reconciliation entry is filed via ACE and uses CBP Form 7501 with Entry Type 09 (formal reconciliation) or 10 (informal reconciliation).
Why use it. Reconciliation is invaluable for:
- Pharmaceutical and biotech importers with annual transfer pricing true-ups
- Auto and electronics importers with complex global supply chains
- Importers claiming FTA preferences where finalized origin data trails the shipment by months
- Apparel importers with USMCA or CAFTA-DR yarn-forward documentation
Reconciliation is one of the most powerful customs compliance tools, but underused — fewer than 1,000 importers participate at any given time.