Penalties & Enforcement

Voluntary Tender

Also known as: Voluntary Payment · Tender of Duty

A voluntary payment of additional duties owed without filing a formal prior disclosure — appropriate for small or straightforward errors, but offers less penalty protection.

A Voluntary Tender is a voluntary payment of additional duties, taxes, or fees owed to CBP on previously entered merchandise, without filing a formal prior disclosure under 19 U.S.C. § 1592(c)(4). It is most commonly used for small, isolated, or unambiguous errors where the additional protections of a full prior disclosure are not warranted — or not available.

Tender mechanisms in ACE:

  • Post-Summary Correction (PSC) under 19 CFR § 174 — Used when liquidation has not yet occurred. PSC amends the original entry summary, and additional duties are billed and paid.
  • Protest under 19 U.S.C. § 1514 — Used after liquidation when the importer challenges (or seeks to correct) the liquidated rate. Not strictly a "tender" but can result in additional payment.
  • Reconciliation — For importers participating in CBP's Reconciliation Program, an unresolved value, classification, or origin issue can be reconciled within 21 months of the original entry.
  • Voluntary letter to CBP — A straightforward letter to the port director enclosing payment for additional duties owed on identified entries; receipt acknowledged by CBP and the duty applied to the entries.

Voluntary Tender vs. Prior Disclosure — key differences:

Voluntary Tender Prior Disclosure
Statutory basis None (administrative practice) 19 U.S.C. § 1592(c)(4)
Penalty cap reduction None — full § 1592 exposure remains Statutory cap (interest only for negligence/gross negligence; 1× duty for fraud)
CBP acknowledgment Receipt of payment Formal acceptance letter
Recommended for Small, isolated, unambiguous errors Material errors, pattern violations, sophisticated issues

When Voluntary Tender is appropriate:

  • Minor clerical or arithmetic errors (incorrect quantity, transposed values) detected internally
  • Single-entry classification errors with low duty impact and clear correction
  • Pre-liquidation corrections via Post-Summary Correction
  • Reconciliation of known issues already flagged in the original entry

When Prior Disclosure is the better choice:

  • Pattern errors across many entries
  • Material loss of duties (typically >$10,000 in additional duties)
  • Issues that would be hard to defend if discovered in audit
  • Any sense that CBP may already be investigating

Caution: A Voluntary Tender does not prevent CBP from later assessing a Section 1592 penalty for the same conduct — the importer still has full statutory exposure. Counsel should evaluate the facts before choosing tender over disclosure; for material errors, the additional procedure and disclosure-letter content of a formal prior disclosure is almost always worth the modest extra effort.

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