September 8, 2025
Due to a combination of policy shifts, operational enhancements, and strategic priorities under the current administration, CBP enforcement is at one of its highest levels in recent history. Compliance is no longer a back-office function — it’s a core business requirement. U.S. Customs and Border Protection (CBP) has intensified its oversight, placing both importers and exporters under heightened scrutiny. From revenue protection to trade security, CBP’s message is clear: every shipment must meet strict customs compliance standards. Failing to comply can lead to CBP penalties, shipment delays, or even criminal investigations.
For businesses moving goods across U.S. borders, the legal requirement to exercise reasonable care has never been more important. Whether importing industrial components from Asia or exporting medical devices to Europe, understanding CBP’s expectations is critical to avoiding compliance violations.
CBP is more than just a border security agency — it is one of the largest revenue-collecting arms of the U.S. government. The agency processes more than $4 trillion in imports annually, collecting billions in customs duties, taxes, and fees. Protecting this revenue is a top CBP priority.
Recent developments in global trade have only increased CBP’s enforcement activities. Changes in tariff schedules, the expansion of anti-dumping and countervailing duty investigations and orders[MC1] , and rising concerns over forced labor and intellectual property rights (IPR) violations have prompted CBP to take a harder line. Businesses can expect:
For companies involved in international trade, this means every entry must be correct the first time — mistakes are no longer overlooked as minor administrative issues.
The principle of reasonable care is central to CBP’s enforcement framework. Under 19 U.S.C. §1484, every importer is legally responsible for ensuring that all entry documentation is complete, accurate, and submitted on time. This includes proper Harmonized Tariff Schedule (HTS) classification, correct customs valuation, and accurate country of origin declarations.
Reasonable care also requires recordkeeping compliance. CBP expects importers to maintain accurate electronic or hard copy records for at least five years and to make them available during an audit. Staying informed about regulatory changes is part of this obligation.
Failing to exercise reasonable care can result in shipment delays, liquidated damages, and administrative or criminal penalties. While the standard is written for importers, exporters face similar responsibilities under Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and Foreign Trade Regulations (FTR).
Maintaining a strong compliance record can offer benefits beyond avoiding penalties. Businesses that show thorough compliance may access programs like CBP's Trusted Trader Program. This program may offer expedited customs processing, reduced inspections, and other perks.
Benefits include:
In essence, reasonable care is not just a legal obligation; it's smart business practice.
The consequences of non-compliance are not just theoretical — they can directly impact operations and profitability. Monetary penalties for negligence can reach tens of thousands of dollars, while penalties for fraudulent activity can equal the domestic value of the merchandise.
Cargo delays are another common issue. In just-in-time supply chains, even a two-day delay can cause significant disruptions and increase costs. Goods may be seized or forfeited if CBP determines they violate U.S. trade laws. Companies enrolled in trusted trader programs like CTPAT risk losing their status if compliance lapses are found.
Reputational damage is another consideration. For businesses competing in the global market, being known as a company with CBP violations can undermine customer trust and make it harder to secure partnerships.
For importers, customs compliance is an ongoing and non-delegable responsibility. Even if suppliers provide classification or valuation data, CBP holds the importer of record accountable. This means importers must verify every detail themselves.
The most common risks for importers include incorrect HTS codes, undervaluation or overvaluation of goods, and improper country of origin marking. Importers must also ensure that all documentation — from commercial invoices to packing lists — is accurate and available in case of a CBP audit.
A robust internal compliance program can help mitigate these risks. This might include regular classification reviews, valuation checks, and supplier compliance monitoring.
Importers should consider several actions to meet their reasonable care obligations:
While CBP enforcement is often import-focused, exporters also face significant compliance challenges. Exporters must file accurate Electronic Export Information (EEI) through the Automated Export System (AES), comply with export licensing rules, and avoid shipping to restricted or sanctioned parties.
Failure to comply with OFAC sanctions, EAR controls, or ITAR regulations can result in fines, loss of export privileges, and even criminal charges. Exporters must also ensure that documentation matches the goods shipped and that end-use and end-user statements are accurate.
Use the BIS and CBP compliance resources as guidance tools.
CBP’s regulations apply equally to electronic and hard copy records, but digital recordkeeping presents its own challenges. Many companies assume electronic documentation is less likely to be audited — but CBP now uses advanced tools to cross-check electronic submissions against other government and commercial data.
Importers and exporters must ensure electronic records are complete, accurate, and retained for the required period. Systems should maintain audit trails to track changes, and backups must be secure to prevent data loss. In many ways, digital compliance demands more precision than traditional paperwork.
Navigating heightened CBP enforcement requires expertise, resources, and proactive planning. Crane Worldwide Logistics offers trade compliance consulting through our dedicated Trade Advisory team, helping businesses reduce risk and operate efficiently.
We conduct compliance audits and risk assessments to identify vulnerabilities before they lead to penalties. Our advisors verify tariff classifications, review valuations, and ensure documentation meets CBP standards. We also provide customs brokerage support, manage recordkeeping processes, and deliver compliance training to your staff.
If CBP issues a notice of action or penalty, we assist with penalty mitigation strategies, helping to resolve issues quickly and minimize financial impact. Beyond enforcement defense, our advisory team helps optimize supply chains by leveraging free trade agreements, reducing duty costs, and improving customs clearance processes.
CBP’s high-enforcement posture in 2025 is not a short-term trend — it is the reality of today’s international trade landscape. Businesses that fail to exercise reasonable care risk financial penalties, shipment delays, and long-term reputational damage.
By partnering with Crane Worldwide Logistics’ Trade Advisory team, you gain an experienced compliance ally who understands both the regulatory requirements and the operational pressures of global trade. We work with you to ensure that every shipment meets CBP’s standards, helping you maintain compliance while keeping your goods moving smoothly across borders.
If your company is ready to strengthen its compliance program and stay ahead of CBP enforcement, now is the time to act. Contact Crane Worldwide Logistics today to schedule a trade compliance review and learn how we can help safeguard your business in 2025 and beyond.
Let one of our client advocates build a solution that fits your logistics needs.
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