CBP Reasonable Care Checklist for Importers in 2026

What Is Reasonable Care?

Under the Customs Modernization Act of 1993, every importer is legally required to exercise "reasonable care" when entering goods into the United States. This means using the degree of care that a reasonably prudent person would use under the same circumstances to ensure that information provided to CBP is accurate, complete, and timely. The concept is deliberately broad — CBP intentionally avoids defining a rigid checklist, because what constitutes reasonable care varies by the complexity of the goods, the importer's experience level, and the specifics of each transaction.

The Informed Compliance Standard

Reasonable care operates within CBP's broader framework of "informed compliance." CBP publishes rulings, informed compliance publications, and the Customs Bulletin to help importers understand their obligations. The expectation is that importers proactively seek out this information and apply it to their operations. Ignorance of published guidance is not a defense — if CBP has issued a ruling on a classification question, importers dealing with the same goods are expected to be aware of it.

10-Point Reasonable Care Checklist

1. Tariff classification: Have you obtained and verified the correct HTS code for every product? Are you using current rulings and the latest HTS edition?
2. Valuation: Is the declared value accurate? Have you included all dutiable assists, royalties, and selling commissions?
3. Country of origin: Can you substantiate the declared country of origin with documentation? Have you considered substantial transformation rules?
4. Marking and labeling: Do all imported goods comply with 19 USC 1304 marking requirements? Are country-of-origin marks legible and permanent?
5. Trade agreements: If claiming preferential duty rates under USMCA, GSP, or other FTAs, do you have valid certificates of origin on file?
6. Admissibility: Have you verified that goods are not subject to antidumping/countervailing duties, trade sanctions, or other import restrictions?
7. Recordkeeping: Are you maintaining all required records for the statutory period (typically 5 years from date of entry)?
8. Customs broker oversight: If using a customs broker, have you provided complete and accurate information? Do you review entries before filing?
9. Internal controls: Do you have written procedures for import compliance? Are they followed and periodically reviewed?
10. Continuous monitoring: Do you track regulatory changes, new CBP rulings, and trade policy updates that affect your products?

Penalties for Failing Reasonable Care

CBP classifies violations into three tiers based on culpability. Negligence — a failure to exercise reasonable care — can result in penalties of up to the domestic value of the merchandise for the first violation and up to two times the domestic value for repeat violations. Gross negligence penalties can reach up to four times the domestic value, and fraud penalties can reach the full domestic value of the goods with potential criminal prosecution.

How to Document Reasonable Care

Documentation is your best defense during a CBP audit or focused assessment. Maintain written classification rationale for every HTS code, including the GRI analysis, relevant rulings consulted, and the qualifications of the person who made the determination. Keep valuation worksheets that show how you calculated the entered value, including any additions or deductions. Record your origin determinations with supporting supplier declarations or certificates.

How Technology Supports Reasonable Care

Modern classification and compliance platforms like TariffPro create automatic audit trails that document your reasonable care process. Every classification decision is logged with the AI confidence score, the GRI rules applied, the CBP rulings consulted, and a timestamp. This digital paper trail is exactly what CBP auditors look for when evaluating whether an importer exercised reasonable care — and it is available instantly, without rummaging through filing cabinets or email threads.