The Post-Clearance Audit (PCA) is a compliance verification process conducted by the Bureau of Customs after goods have been released from customs custody. It checks whether importers correctly declared the value, classification, and other details of their shipments, and that the right duties and taxes were paid.
Legal Basis
The PCA is authorized under the Customs Modernization and Tariff Act (CMTA), which gives the Bureau of Customs the power to audit importers' records for up to three years from the date of final payment of duties and taxes.
Who Is Subject to PCA?
All importers are potentially subject to post-clearance audit, including:
- Regular importers with recurring shipments
- Non-Regular Importers (NRI)
- Companies that availed preferential tariff rates under Free Trade Agreements
What the Audit Covers
Customs auditors review:
- Goods declarations and supporting documents
- Accuracy of declared customs values
- Correctness of tariff classification (HS Code)
- Completeness of import documentation
- Compliance with permit and regulatory requirements
- Consistency between financial records and customs declarations
What to Keep on File
Importers should maintain the following records for at least three years:
- Commercial invoices and packing lists
- Bills of lading or airway bills
- Goods declarations (import entries)
- Import permits and regulatory clearances
- Payment records for duties and taxes
- Accounting and financial records related to importations
Possible Outcomes
- No findings - Audit closed with no deficiency
- Deficiency assessment - Additional duties and taxes are demanded, with surcharges and interest
- Penalties - Administrative fines for violations found during the audit
- Criminal referral - For serious violations, cases may be elevated to the Department of Justice
The best defense against a PCA is accurate declarations from the start. Importers who work with licensed customs brokers and maintain complete records are far better positioned when an audit comes.
