What Is a Reconciliation Entry?
Short version: a reconciliation entry is an entry you file with CBP when you don’t yet know all the final numbers, with a built-in promise to come back and true them up later.
That’s it. The rest is detail, but the detail matters, so stick with me.
Why reconciliation exists
A lot of trade doesn’t settle at the port. The final value of an assist, royalty payments, transfer-price adjustments, a free trade agreement claim, an HTS 9802 value, these often aren’t nailed down at the time your goods enter. You can’t always know the exact number on day one.
CBP’s answer to that is reconciliation. Instead of guessing wrong and scrambling to fix it, you file the entry summary with your best available information, and you flag the entry. The flag is your notice of intent. It tells CBP, “this number isn’t final, a correction is coming.”
How a reconciliation entry works
It runs in two stages.
First, the underlying entry gets flagged, either one at a time or through a blanket application that flags everything for a set period. The goods clear, you pay based on your best estimate, and the entry sits open on the reconciliation issue.
Second, once the real numbers come in, you file the Reconciliation itself. That’s the document that delivers the final, correct information. CBP then liquidates it with a single bill if you owe more, or a single refund if you overpaid.
The clock: you file the Reconciliation within 12 months of the earliest entry for certain free trade agreements, or within 21 months for everything else. One Reconciliation can cover up to 9,999 underlying entries. CBP’s own write-up is here.
And worth knowing: a Reconciliation is treated like any other CBP entry for liquidation and protest. Same rights, same clocks, once it liquidates.
Are my entries part of reconciliation?
This is the real question most importers have, and the answer isn’t always obvious from your side of the desk. Entries can be flagged individually or under a blanket application your broker set up, sometimes years ago, sometimes without you thinking about it since. If you’ve ever made post-entry adjustments to value or claimed certain FTAs, there’s a good chance reconciliation is in the picture.
The only way to know for sure is to look at the entry data.
Why this matters right now: IEEPA refunds
Here’s the timely part. A flagged reconciliation entry is still open, it hasn’t finally liquidated. And open entries are exactly the ones CBP is set up to refund administratively through CAPE, no court order, no lawsuit. CBP’s Phase 2 rollout is aimed squarely at reconciliation entries.
So if your entries are flagged for reconciliation, that’s not a complication. Right now, it might be an advantage.
If you’re not sure where your entries stand, we can pull the data and tell you which are open, which are flagged, and which are eligible for a refund. Reach out and we’ll take a look.
Frequently Asked Questions
Q: What is a reconciliation entry? A reconciliation entry is a CBP entry filed with an importer’s best available information when certain details aren’t final yet, such as value, royalties, an assist, or a free trade agreement claim. The importer flags the entry as a notice of intent, then later files a Reconciliation with the corrected figures, and CBP liquidates it with a single bill or refund.
Q: How do I know if my entries are flagged for reconciliation? You usually can’t tell from your own records, because entries are often flagged by your customs broker, either individually or under a blanket application covering a set time period. The only reliable way to know is to check the entry data in ACE. If you’ve made post-entry value adjustments or claimed certain free trade agreements, reconciliation is likely in play.
Q: What is the deadline to file a Reconciliation? A Reconciliation is due within 12 months of the earliest entry date for certain free trade agreements, and within 21 months for all other issues such as value. A single Reconciliation can cover up to 9,999 underlying entries, and once filed, it is liquidated and treated like any other entry for purposes of protest.
Q: Are reconciliation entries eligible for IEEPA tariff refunds? Yes, and they’re in a stronger position than most. A flagged reconciliation entry is still open, meaning it has not finally liquidated. Open entries are the ones CBP can refund administratively through its CAPE process without a court order or lawsuit. CBP’s CAPE Phase 2 rollout is aimed specifically at entries in reconciliation status.
Q: Why does reconciliation status matter for getting an IEEPA refund? Because the refund path depends on whether an entry has finally liquidated. Entries that already went final are the contested group fighting for refunds in court. Entries still open, including those flagged for reconciliation, can be refunded directly by CBP. If your entries are in reconciliation, that status may now work in your favor.
