Value Reconciliation is a CBP program under 19 U.S.C. § 1401(s) and 19 CFR § 24.25 that allows importers to file an "indeterminate" entry summary with respect to specific elements — value, classification, NAFTA/USMCA origin, or 9802 tariff preferences — and finalize them in a separate reconciliation entry filed within 21 months of the underlying entry's filing date.
The program is most commonly used for related-party transaction value where:
- Transfer pricing year-end true-ups will adjust the entered value
- Royalties or proceeds of resale are determined after importation
- Assists like tooling are not yet apportioned at the time of import
- Intercompany rebates or volume discounts will adjust the final price
To participate, the importer must:
- Apply to CBP and be approved as a Reconciliation participant
- Flag eligible entries as "Recon" at the time of filing (via ACE)
- File the Reconciliation entry within 21 months, reporting the final values and paying additional duties (or claiming a refund)
Reconciliation is mandatory for related-party importers using transfer pricing studies that result in year-end adjustments. CBP guidance in HQ H037375 and the Informed Compliance Publication on Reconciliation explains the mechanics.
The program is a major risk-mitigation tool — rather than filing a prior disclosure for understatements caused by post-import adjustments, the importer reconciles in the ordinary course. Failure to file a required Recon entry, however, is itself a § 1592 violation.