For importers, filing a Post Summary Correction (PSC) is often viewed as a routine compliance step—a way to fix an entry after submission. But a PSC is not simply an administrative fix. It’s an invitation that asks U.S. Customs and Border Protection (CBP) to reexamine the entry, which can trigger a review far beyond a single corrected field.
Understanding what CBP may examine during a PSC review helps importers prepare documentation, strengthen internal controls, and reduce the risk of additional scrutiny. A well-managed PSC process doesn’t just correct an entry, it demonstrates reasonable care and reinforces compliance credibility.
Why Post Summary Corrections draw CBP attention
A PSC reopens the entry for review. That means CBP can reassess whether the entire submission reflects reasonable care, including:
- Correct classification
- Accurate customs value
- Verified country of origin
- Appropriate duty and tax treatment
- Reliable, aligned documentation
CBP’s review often goes beyond checking documents—it evaluates whether the importer can substantiate each element of the entry with consistent data and supporting records.
What CBP can further examine during PSC review
When CBP reviews a PSC, the agency typically evaluates several core elements of the entry to ensure accuracy, consistency, and supporting documentation:
1. Classification
Classification is often one of the first areas CBP revisits during a PSC review. Importers should expect questions about accuracy of the HTS code, the documentation supporting classification decisions, and whether classification is applied consistently across systems.
2. Valuation
CBP may scrutinize transfer pricing and related-party rationale, price setting and allocation methodologies, and whether declared value aligns with financial records. The agency may also review the use of first sale, assists, or arm’s-length pricing approaches. Supporting documentation often includes items such as the chart of accounts, freight and logistics invoices, intercompany transaction documentation, and payment records that reconcile to declared values.
3. Origin
CBP expects origin to be clear, documented, and consistent. During a PSC review, the agency may examine bills of materials, production records, supply chain routing visibility, and documentation supporting free trade agreement claims to ensure the declared origin is substantiated.
4. Special duty programs and risk areas
A PSC may also draw attention to trade remedy exposure and other risk areas, including AD/CVD exposure, incorrect trade remedy tariffs under Section 232, Section 301, or IEEPA, reconciliation inconsistencies, and whether duty drawback has been filed.
5. High-risk patterns
CBP increasingly uses analytics, data-sharing, and whistleblower information to detect potential compliance risks. These reviews may look for patterns associated with misclassification, undervaluation, false origin declarations, transshipment activity, or abusive tariff engineering. Even compliant importers can be flagged if their data resembles known risk patterns.
Building strong compliance foundations
Importers can reduce PSC-related risk by building consistent compliance processes across classification, origin, valuation, and entry oversight. Strong documentation, aligned systems, and proactive monitoring help ensure corrections can be made confidently when needed.
Here are six governance strategies that help reduce compliance risk and strengthen PSC readiness:
1. Classification governance and system consistency
Consistency across ERP, GTM, and customs systems is foundational to defensible compliance. Maintaining centralized classification decisions—along with version-controlled rulings and justifications—helps ensure HTS determinations are applied uniformly across entries and systems. This level of documentation and control reduces discrepancies and makes classification decisions easier to substantiate during a PSC review.
2. Origin transparency
Origin documentation should be clear, verifiable, and traceable across the supply chain. This includes maintaining verified bills of materials, end-to-end supplier visibility, and documentation supporting production processes, origin determinations, and free trade agreement claims. Strong origin transparency helps importers substantiate origin declarations if CBP requests additional review.
3. Valuation controls
Valuation compliance depends on documented pricing rationale and consistent reconciliation practices. Importers should be able to reconcile invoices, payments, and declared values while monitoring for outliers or exceptions that could signal discrepancies. These controls help demonstrate that declared values reflect a consistent and defensible methodology.
4. Broker oversight
Effective broker oversight helps ensure alignment between the importer and customs filing partners. Defined expectations, periodic audits, and alignment on classification, origin determinations, and valuation criteria help reduce entry errors and improve documentation consistency.
5. Internal monitoring
Ongoing internal monitoring helps identify issues before they require correction. Data-driven entry review, anomaly dashboards, and formal correction and prior disclosure processes allow importers to detect and address inconsistencies early, strengthening overall compliance governance.
6. Duty engineering (use carefully)
Legitimate tariff planning can be part of a compliance strategy, but only when it is transparent, substantiated, and legally and technically defensible. Clear documentation and consistent application are essential to ensuring duty engineering decisions withstand regulatory review.
A PSC should reinforce your compliance—not expose weakness
A PSC is both a compliance obligation and a risk event. Importers who maintain clear documentation, consistent data, and strong internal controls are best positioned to correct entries confidently without drawing unwanted scrutiny.
With the right infrastructure, a PSC becomes a tool for strengthening compliance—rather than a trigger for deeper examination.
Stay informed
Developments in customs and trade continue to evolve—stay informed to be prepared:
