Wrong Chapter at 4-Digit Level
Product classified in Chapter 84 (machinery) when it belongs in Chapter 73 (iron/steel articles) — or vice versa. Often happens with multi-component products without GRI 3(b) analysis.
HTS Classification Refund · Entry-Level Audits
The single largest source of duty overpayment. And the hardest to spot.
A wrong HTS code at the 8-digit level can push a product into a higher-duty line — sometimes adding 25% Section 301 burden where the correct code carries none. We perform line-by-line entry summary audits, file corrections under 19 USC §1520(d), and protests under 19 USC §1514, all on a pure contingency basis.
~85%Of importers carry classification errors
1–3%Typical recoverable share of duty paid
180 daysProtest window (§1514)
1 year§1520(d) window for FTA corrections
— Where Misclassifications Hide
Five recoverable error patterns.
Wrong Subheading at 8-Digit Level
Correct chapter and heading, wrong specific subheading. The 8-digit level frequently determines whether Section 301, Section 232, or AD/CVD applies. Recoverable via PSC or protest.
Missed FTA Preference at Entry
Goods qualified for USMCA, KORUS, CAFTA-DR, or another FTA preference but certification wasn't provided. Recoverable under 19 USC §1520(d) within 1 year.
Missed Section 301 Exclusion
A granted or reinstated USTR Section 301 exclusion not applied to qualifying entries. Recoverable through Section 301 filings.
Incorrect Country of Origin
Country of origin determines whether Section 301, Section 232, AD/CVD, or FTA preferences apply. Substantial transformation analysis under 19 CFR Part 102 frequently changes the answer.
Reconciliation Adjustments
Issues identified after entry but before final liquidation can be resolved through reconciliation entries (Type 09) within 21 months of earliest filing.
— Filing Vehicles
Pick the right tool.
| Vehicle | Statutory basis | Window | What it covers |
|---|---|---|---|
| PSC | 19 CFR §141.91 | Up to 300 days from filing, before liquidation | Pre-liquidation HTS, value, or origin corrections |
| Protest | 19 USC §1514 | 180 days from liquidation | Liquidated-entry challenges; exclusion application |
| §1520(d) claim | 19 USC §1520(d) | 1 year from import | Post-import FTA preference claims |
| §1501 voluntary reliquidation | 19 USC §1501 | 90 days post-liquidation | Basis for CAPE Phase 1's 80-day window |
Find out what you’re owed.
Book a free 30-minute call with Cardinal Customs. We’ll review your import footprint, estimate your IEEPA refund window, and flag other duty recovery opportunities. No commitment, no upfront fees.
Schedule a Free Call— Or call us directly
(347) 670-3777Speak with a recovery specialist. No automated menus, no gatekeeping.
Mon–Fri · 8:30 AM – 6:00 PM ET