USA Trade Advisory: Accurate Customs Invoices Are More Important Than Ever

Trade Update • April 24, 2025

s global trade compliance measures tighten and enforcement actions escalate, it is critical to ensure your customs invoices are complete, accurate, and fully supportable.

With pending changes to De Minimis thresholds on goods from China and Hong Kong, and increased scrutiny from U.S. Customs and Border Protection (CBP) in light of recent tariff changes, now is the time to double-check your documentation.

Errors—whether accidental or intentional—can result in costly delays, fines, or enforcement actions.

What You Should Be Reviewing Now

• Product Descriptions – Be Thorough
  Are your Customs Invoice product descriptions clear, complete, and specific enough to support the HTS code you are using? Vague or generic descriptions no longer suffice under today’s enforcement standards.

• HTS Classification (10-Digit) – Get It Right
  Has the correct 10-digit Harmonized Tariff Schedule (HTS) code been assigned to your product? Misclassification can lead to improper duty assessment —or worse, enforcement actions.
  • Not sure your classifications are accurate? Consult with our US Trade Services team for a review.

• Country of Origin – Proof Is Essential
  • Are your goods properly marked with the country of origin and do your customs documents reflect that consistently?
  • Origin discrepancies are a common target of CBP inspections and audits. Do not wait for a customs inspection or audit to validate your origin claims – be proactive.

• Declared Value – No Room for Error
  Is your declared value aligned with the appropriate CBP appraisement method? Now is not the time for “creative” invoicing.
  • Reference CBP’s Informed Compliance Publications – Customs Value for valuable guidance.

• Intended Use Statements – Critical for Section 232 Compliance
  With changes under Section 232 tariffs (notably for steel & aluminum as of March 12, and auto parts effective May 3), clearly stating the intended use of your products on invoices is essential to ensure the correct duty rates and exemptions are applied.

• Manufacturer Identification (MID) – Required for Textiles
  • MID information is mandatory for formal entries of textile and apparel products. Include the full name and address of the manufacturer that performs the origin conferring process. HTS codes of textile and apparel products that need MID code information can be found here.

• Buyer Identification – EIN or SSN Required
  Does your Customs Invoice include the buyer’s IRS Number (EIN) or Social Security Number (SSN) when required?
  • CBP requires this number on all formal entries. Under the new tariffs, shipments valued over $250 require a formal entry. Missing or incorrect data will result in clearance delays.

• Terms of Sale – Indicate Who Pays for Duty & Brokerage
  • Are the responsibilities for duties, taxes, and brokerage fees clearly stated?
  • Use Incoterms® 2020 (e.g. DAP, DDP, EXW) to clearly define these terms and avoid confusion between buyers, sellers, and customs brokers.

• PGA Reporting – Know Your Goods
  • Determine whether the goods you are importing require reporting to a Partner Government Agency (PGA). If so, ensure that all necessary supplemental documentation is included to support the applicable PGA requirements.

• Record Keeping – Document Everything
  Are you keeping clear records of how you arrived at your classifications, values, and origin determinations?
  • With regulatory shifts happening quickly, proper documentation—including timestamps, source references, and internal notes—is critical. Robust records can help you efficiently respond to internal reviews or CBP audits.

Trade compliance is not optional. Protect your business by ensuring every Customs Invoice is accurate, complete, and defensible. When in doubt—ask. A quick consultation today could prevent a costly penalty tomorrow.

Additional Resource – CBP’s Informed Compliance Publications.

How GHY Can Help

GHY helps importers ensure every customs invoice is accurate, complete, and audit-ready. Our Global Trade Services team specializes in navigating complex compliance requirements—whether you’re managing changes to de minimis thresholds, Section 232 tariffs, or updated documentation standards enforced by CBP.

We offer targeted compliance audits, HTS classification reviews, and valuation consulting to uncover gaps and prevent costly errors. GHY also supports clients with origin determination, PGA reporting, and recordkeeping strategies aligned with the latest regulatory shifts.

With GHY as your compliance partner, you can reduce risk, avoid penalties, and maintain seamless customs clearance across all your shipments.

Please contact your Client Care Manager or our Global Trade Services Team gts@ghy.com, or call +1 (800) 667-0771.