For U.S. importers, the end of the year is a critical moment to evaluate compliance, correct issues, and prepare for the year ahead. With tariff changes, supply chain uncertainty, and an increased focus on enforcement, importers who take a proactive approach now will start the new year strong. Here's a practical checklist for your year-end review.
1. Review Import Data for Accuracy
Begin with a thorough audit of your import data. Confirm that HTS classifications are correct and current, declared values accurately reflect your transactions, and country-of-origin determinations are well documented. Small mistakes can lead to large penalties.
2. Reassess Tariffs and Duty Exposure
Year-end is the ideal time to evaluate whether you are paying unnecessary duties and explore your options for tariff mitigation strategies. Consider what exclusions have changed, whether tariff engineering may reduce costs, or whether sourcing strategies should be updated. Many importers discover duty-saving opportunities simply by reassessing their tariff positions annually.
3. Strengthen Forced Labor Compliance
With UFLPA enforcement intensifying, importers must confirm that supplier information, ownership structures, and supply chain documentation are up to date. Now is the time to verify traceability records, refresh internal training, and assess whether high-risk suppliers require additional review.
4. Update Written Compliance Procedures
If your compliance manual or SOPs haven't been updated this year, they're likely outdated. Written processes should reflect current regulations, product updates, tariff changes, and internal workflow adjustments. CBP expects importers to document their compliance efforts clearly and accurately.
5. Conduct a Recordkeeping Audit
Recordkeeping is a key part of an importer's duty to use reasonable care. Ensure you can quickly retrieve all required import documents from invoices and packing lists to HTS support, bills of lading, and supplier certifications. Recordkeeping failures are one of the most common issues CBP flags during audits, and year-end is the perfect time to clean up files.
6. Update Internal Training
Import compliance is only as strong as the people involved. Year-end is an excellent opportunity to refresh your team's understanding of classification, valuation, country-of-origin rules, reasonable care, and forced labor compliance. Well-trained teams help prevent mistakes and reduce future risk.
7. Assess Audit Readiness
Consider how prepared your company is to respond to a CBP Form 28 or 29, a Focused Assessment, or a forced labor detention. If gaps or uncertainties exist, year-end provides the chance to correct them, strengthen documentation, or make a plan to improve your readiness approach over the coming weeks.
8. Set Compliance Goals for the Upcoming Year
Finally, look forward. Establish measurable goals for the new year, whether it's improving classification accuracy, reducing filing errors, tightening supplier oversight, implementing new technology, or enhancing training. Strategic goals help transform compliance from a reactive function into a competitive advantage.
Contact Diaz Trade Law for Compliance Help
A year-end compliance review is one of the most valuable things an importer can do to reduce risk, control costs, and prepare for the evolving trade environment. Diaz Trade Law has decades of experience helping importers with pre-compliance. With an increased focus on enforcement expected in 2026, NOW is the time to get your compliance strategy in order. Contact us today for assistance. 305-456-3830 or info@diaztradelaw.com.
Learn more:
- Bloomberg Law: CBP Recordkeeping Requirements
- Bloomberg Law: Responding to a CBP Form 28 or 29
- Bloomberg Law: What is an Importer's Reasonable Care Standard?
- Band-Aid or Stitches? What's Your Compliance Approach?
- UFLPA DHS Forced Labor Guidance – What Importers Need to Know
- Know Your Supply Chain: Forced Labor
- Webinar: Tariff Mitigation Strategies
- Webinar: Importing 101 – Introduction to U.S. Customs
- Webinar: ACE: Auditing Your Import History
- Webinar: CBP 201 – Building & Maintaining an Effective Import Compliance Plan
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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