Import Compliance & Tariff Strategy
Errors in classification, valuation, country of origin, or compliance can trigger substantial duty bills, CBP enforcement actions, and costly operational disruption. The window to respond is narrow — and how you respond determines the outcome.
Great Lakes Customs Law has been representing importers in CBP compliance matters for more than 15 years, at ports nationwide. Whether your company is seeking certainty through binding rulings, defending against tariff-related penalties, or responding to CBP inquiries, we provide strategic representation before CBP, Centers of Excellence & Expertise, and the Office of Regulations & Rulings.
Most CBP penalty notices and liquidated damages claims require a response within 60 days. Protests must be filed within 180 days of liquidation. Prior disclosures must be filed before CBP formally initiates a penalty investigation. If you have received a notice from CBP, the time to act is now — not after the deadline has run.
Import Compliance & Tariff Matters We Handle
Binding Ruling Requests
Before importing merchandise, or when compliance is unclear, CBP allows companies to request formal rulings on tariff classification, country of origin, marking requirements, valuation methodology, USMCA eligibility, substantial transformation analyses, and Internal Advice Requests. A well-written ruling request eliminates guesswork and dramatically reduces enforcement risk — giving clients predictable duty outcomes and defensible compliance records.
Learn MoreProtests Against CBP Decisions
Importers have the right to challenge adverse CBP actions through the formal protest process — including classification and rate advances, valuation disputes, country-of-origin determinations, USMCA eligibility denials, and liquidation errors. Protests must generally be filed within 180 days of liquidation. When necessary, we prepare supplemental protests and requests for internal advice, escalating to the Office of Regulations & Rulings for binding guidance.
Learn MoreAD/CVD Scope Determinations & Administrative Reviews
When product eligibility under an antidumping or countervailing duty order is unclear, we prepare scope ruling requests, circumvention analyses, administrative review submissions, and responses to CBP or Department of Commerce questionnaires. Clients rely on us to obtain clarity on whether duties apply and to minimize exposure to retroactive assessments — which can run to millions of dollars in some industries.
Learn MoreDrawback & USMCA Drawback
We advise on and file drawback claims involving same-condition drawback, unused merchandise drawback, rejected merchandise, substitution drawback, and post-entry USMCA refunds. We ensure claims are timely, documented, and defensible — maximizing recoverable duty amounts for importers and manufacturers who export or destroy qualifying merchandise.
Learn MorePrior Disclosures
When importers discover compliance errors, a timely and properly drafted prior disclosure can eliminate or substantially reduce penalties under 19 USC 1592. We help clients identify the scope of violations, quantify revenue loss, prepare comprehensive disclosures, and negotiate duty repayment schedules. A prior disclosure must be filed before CBP formally initiates a penalty action — once the investigation is open, the opportunity for full penalty elimination is lost.
Learn MoreCustoms Valuation
We resolve disputes and ensure compliance relating to customs valuation under 19 USC 1401a, including related-party transactions, first sale for export, and assists and non-dutiable charges. These issues often require detailed fact development and legal argumentation — something our firm is uniquely experienced in providing both at the entry level and in post-entry proceedings before CBP and the Court of International Trade.
Learn MoreCountry of Origin & Marking Compliance
Country of origin affects duty rates, free trade agreement eligibility, and strict marking requirements enforced by CBP. Determining origin is rarely straightforward when multiple countries contribute materials, components, or manufacturing steps. Errors can trigger denied entries, extra duties, penalties, and costly delays. We advise on substantial transformation analyses, marking obligations under 19 USC 1304, CBP origin verifications, and preferential treatment eligibility.
Learn MoreTrademark Enforcement & Counterfeit Seizures
We assist both rights holders and importers navigating CBP’s intellectual property rights enforcement system — including recordation of trademarks, enforcement strategies, detention and seizure response, product authentication, and counterfeit risk mitigation. For importers facing penalties under 19 USC 1526, the maximum penalty equals the domestic value of the genuine goods — making mitigation representation essential from the moment of seizure.
Learn MoreResponses to Requests for Information & Notices of Action
A CF-28 is often the first sign that CBP is questioning an import. How importers respond can determine whether a routine inquiry becomes a penalty case. We prepare complete, accurate, and strategic responses that protect our clients’ interests and reduce enforcement risk. Do not respond to a CF-28 or CF-29 without counsel — the positions you take at this stage have lasting consequences in any subsequent penalty proceeding.
Penalty Defense & Liquidated Damages
If CBP has issued a penalty notice or a notice of liquidated damages, you have 60 days to respond. Paying the full assessed amount without filing a petition for mitigation is almost always a mistake — CBP’s mitigation guidelines provide meaningful reduction opportunities for importers who respond correctly. We represent importers in penalty proceedings under 19 USC 1592 and in liquidated damages cases at ports nationwide.
Learn MoreNot Sure Where to Start?
Import compliance issues rarely arrive with clear labels. A CBP inquiry can become a penalty case. A classification dispute can trigger an audit. A missed prior disclosure deadline can cost an importer millions. If you have received a notice from CBP — or if you have identified a potential compliance issue — contact us for a free consultation. We will tell you exactly what you are dealing with and what your options are.