For brokers, forwarders and 3PLs
Customs broker software for HS classification: bulk HTS codes for brokers, forwarders and 3PLs
Classification is licensed customs business, and it is the part that scales worst. Tariffwise classifies at catalog volume and returns a written rationale on every line, so a licensed broker reviews and signs off instead of starting from a blank HTS. Try it on a real product description.
Free while we build · No card required · AI recommendation for broker review, not a CBP ruling
Customs declaration · AI classifier
FORM TW-01
The short answer
Classification sits inside the definition of customs business under 19 CFR 111.3, so it is work only a licensed broker can transact for a client, and it is work CBP measures you on. The supervision factors in 19 CFR 111.28 explicitly include the instructions you issue to staff, your reject rate relative to volume, employee access to current editions of the tariff schedule, and how often a licensed broker audits transactions handled by employees. Tariffwise is built to sit under that structure rather than around it: it proposes a code with the reasoning, cites the notes and rules behind it, and leaves the sign-off with your licensed broker. The record it produces is retention-ready, which matters because the HTSUSA number is itself on CBP's list of records you must be able to produce on demand.
Last updated July 2026.
The classification workload just got structurally bigger
In June 2026 CBP indefinitely suspended the $800 de minimis exemption. For all modes other than the international postal network the suspension took effect June 24, 2026, and the companion rule covering the postal network takes effect July 24, 2026. Shipments valued at $800 or less now have to use formal or informal entry procedures, which means each one needs a classification it never previously needed. This is not a demand forecast, it is a published rule, and the volume lands on brokers, forwarders and 3PLs rather than on the shippers.
137,217
Entries of merchandise CBP processed per day in FY2025
$9.8B
Value of imported product arriving on a typical day
$618M
Duties, taxes and fees collected on a typical day
~14,000
Active individually licensed US customs brokers
Daily figures are CBP's published averages for fiscal year 2025. Broker headcount is CBP's own count of 13,952 active individual brokers as of 2022, from the continuing-education rulemaking.
Who actually owns the classification
The importer of record does. 19 USC 1484(a)(1) requires the importer of record, either in person or by an agent, to make entry using reasonable care, and to file the declared value, classification and rate of duty. Those four words, "or by an agent," are the whole point: filing an entry on a client's behalf does not transfer the reasonable-care duty to you, and it does not make you the importer of record. That is worth saying clearly to clients who assume otherwise.
What it does not mean is that a broker is insulated. Your exposure simply runs through a different regime. 19 CFR 111.91 provides for a monetary penalty of up to an aggregate of $30,000 for the conduct listed in 111.53, which also sets the grounds for suspending or revoking a license or permit. Under 111.2 a broker is held strictly responsible for the acts and omissions of an employee within the scope of employment. Sections 111.29 and 111.39 impose duties of diligence and care in the advice you give a client. And 19 USC 1592 reaches any person who enters merchandise by material false statement or omission, or who aids or abets it, so a broker is not categorically outside it. On top of all that, your reject rate relative to overall volume is an express supervision factor CBP weighs under 111.28(a)(4). Classification error rates are not just a client service problem, they feed directly into how CBP assesses your license compliance.
What a misclassification actually costs
These are the statutory caps under 19 USC 1592(c). Note the right-hand column: an error that is duty-neutral is still penalizable, which answers the common objection that the rate would have been the same anyway.
| Culpability | Where revenue is lost | Where no revenue is lost |
|---|---|---|
| Negligence | Lesser of domestic value or 2x the lawful duties, taxes and fees | 20% of dutiable value |
| Gross negligence | Lesser of domestic value or 4x the lawful duties, taxes and fees | 40% of dutiable value |
| Fraud | Up to the domestic value of the merchandise | Up to the domestic value |
The counterweight is prior disclosure under 19 USC 1592(c)(4). Disclose before, or without knowledge of, the commencement of a formal investigation and the merchandise is not seized, and for negligence or gross negligence the penalty is capped at the interest alone on the unpaid duties, provided you tender them on time. For fraud the cap is 100 percent of the lost duties. That is a large difference, and it exists only if you find the error first. It is the clearest financial argument there is for auditing a client's catalog proactively rather than waiting for a CBP inquiry.
Built for the way a broker has to work
Bulk classification
Run a whole client catalog rather than one SKU at a time. The volume argument got stronger the day de minimis was suspended.
A written rationale per line
Every recommendation cites the General Rules of Interpretation, the section and chapter notes, and the factors that drove the decision, so the file is defensible later.
Licensed broker sign-off
The tool proposes, your licensed broker approves. That is exactly the supervision structure 19 CFR 111.28 rewards, not a workaround for it.
Catalog consistency checks
Inconsistent codes for identical goods across entries is a classic audit trigger and feeds your reject rate. Catch it before CBP does.
Retention-ready records
Records relating to an entry must be kept five years. A searchable archive of the basis for each decision beats reconstructing it from memory.
Ruling candidates flagged
Where a call is genuinely close or the money is large, the tool flags it as a candidate for a binding ruling under 19 CFR Part 177 rather than guessing confidently.
Recordkeeping, and why the HTS number itself is a record
Under 19 CFR 163.4(a) records relating to an entry must be kept for five years from the date of entry, and 19 CFR 111.23(b) applies the same five-year period to brokers. Powers of attorney are kept until revoked, then five years after revocation or after the client stops being an active client, whichever is later. Records have to be maintained as original records, whether paper or electronic, and be capable of retrieval on lawful demand.
Here is the detail worth internalizing. CBP's interim (a)(1)(A) list, the appendix to Part 163 covering records required for the entry of merchandise, expressly includes the HTSUSA number and the description of merchandise. Your classification decisions are not incidental working notes, they are producible records, and failure to produce can result in penalty action or liquidation at a higher rate. A classification workflow that leaves no retrievable trail is a recordkeeping exposure, not just an efficiency problem.
Continuing education is live right now
Since the final rule at 19 CFR 111.102, individually licensed brokers must complete 36 continuing education credits per triennial period. CBP set January 1, 2025 as the compliance start and prorated the current 2024 to 2027 period to 20 credits, due by February 1, 2027. The full 36-credit requirement first applies to the triennial period beginning February 1, 2027. Failure to report triggers a notice, 30 days to correct, then suspension and eventually revocation under 111.104. The credit records themselves have to be retained for three years after the status report. If you are reading this in mid-2026, you are roughly 30 months into a 36-month cycle.
The boundary we will not blur
Only a ruling issued under 19 CFR Part 177 binds CBP. Section 177.9(a) makes a ruling letter the official position of the agency and binding on all CBP personnel until modified or revoked. By contrast, 177.1(b) states that even oral opinions from CBP's own personnel are not binding on CBP. If CBP's staff cannot bind the agency informally, no software can either. Rulings are generally available only for prospective transactions, and a question on an entry that has already liquidated cannot be the subject of a ruling request.
So here is what Tariffwise is and is not. It produces a classification recommendation grounded in the General Rules of Interpretation with a written rationale, designed for licensed-broker review and sign-off, and it flags lines where a Part 177 ruling is worth requesting. It is not CBP-approved, it is not binding, it does not guarantee correctness, and it does not discharge the importer's reasonable-care duty under 19 USC 1484. Any vendor telling you otherwise is selling you a liability. If a call is close and the money is real, the honest answer is to request a binding ruling, which is free and takes about 30 days.
Broker and forwarder questions, answered
Is the customs broker or the importer liable for an incorrect HTS classification?
The importer of record bears the legal duty. 19 USC 1484(a)(1) requires the importer of record, in person or by an agent, to use reasonable care in declaring classification. A broker filing on the importer's behalf does not assume that duty, but carries separate exposure under 19 CFR Part 111 and potentially under 19 USC 1592.
How long must a customs broker keep entry records?
Five years. 19 CFR 163.4(a) requires records relating to an entry to be kept five years from the date of entry, and 19 CFR 111.23(b) applies the same period to brokers. Powers of attorney are kept until revoked, then five years after revocation or after the client becomes inactive, whichever is later.
Do customs brokers need continuing education now?
Yes. 19 CFR 111.102(b) requires 36 continuing education credits per triennial period. CBP set January 1, 2025 as the compliance date and prorated the 2024 to 2027 period to 20 credits, due by February 1, 2027. The full 36 credits first apply to the triennial beginning February 1, 2027.
What is the penalty for misclassifying imported goods?
Under 19 USC 1592(c), negligence is capped at the lesser of domestic value or twice the lost duties, gross negligence at four times, and fraud at full domestic value. Where no revenue is lost, penalties are 20 percent of dutiable value for negligence and 40 percent for gross negligence.
Does a prior disclosure reduce customs penalties?
Substantially. Under 19 USC 1592(c)(4), disclosing before or without knowledge of a formal investigation caps a negligence or gross negligence penalty at interest alone on the unpaid duties, provided those duties are tendered on time. Merchandise is not seized. Fraud is capped at 100 percent of the lost duties.
Run a client catalog through the classifier and keep the rationale on file.
Related: HS code API, tariff classification software, best HS code classification software.