Mark’s Memo: What Happens When you Actually Start Checking your Customs Data

There is a common assumption in most organisations that if something was wrong with their customs declarations, they would be aware of it. On the surface, that feels reasonable. Customs Declarations are being processed, goods are moving, and there are no immediate issues being raised.

Unfortunately in practice, that assumption rarely holds up to scrutiny

This is not because people are careless, and it is not because customs brokers or agents are not doing their job. The issue is more structural than that. Most companies simply do not have a consistent way of checking or a business process in place to see what is actually being declared in their name. Without that process, there is very little to support the belief that everything is broadly correct.

Customs Declarations move, but they are not revisited

In most organisations, customs is treated as a process that needs to function efficiently on a day-to-day basis. Declarations are submitted, shipments are cleared, and documents are stored for record-keeping. The focus is understandably on keeping operations moving.

What is often missing is a structured way of going back and reviewing what has already been declared.

Not just confirming that the shipment went through but understanding whether the data itself is consistent and correct. That includes how products are classified, how procedures are applied, and whether the instructions given internally are reflected in the declarations submitted by customs brokers.

These are not theoretical questions. They sit at the core of compliance.

What becomes visible when you look across the data

When companies introduce a more structured approach to reviewing their declarations, the findings are usually quite consistent.

It is not always major failures, although I have seen enough of those over the years to know they do happen. More often, the issues are smaller and less visible when looked at in isolation. The same product may be classified differently across shipments. Procedures may be applied one way in one market and another way elsewhere. Certain fields may be left incomplete or interpreted differently depending on who is handling the declaration.

Individually, these differences may not stand out. When viewed across a larger set of data, they become much clearer.

The role of customs brokers, and where responsibility sits

Customs brokers and agents play an essential role in this process. They are responsible for submitting declarations based on the information and instructions they receive, and in most cases, they do this efficiently.

However, the responsibility for the accuracy of what is declared does not sit with them. It remains with the importer or exporter of record. That includes not only the correctness of individual declarations, but also the consistency of how rules are applied over time, and the ability to explain and document this if required.

This is where many organisations have a gap. The operational process is in place, but there is limited visibility into the quality of the output.

Why reviews tend to happen too late

In many cases, detailed reviews of customs data are only carried out when something triggers them. This might be an audit from customs authorities, a question raised internally by finance or tax, or a major discrepancy that needs to be explained.

At that point, the work becomes reactive. Instead of reviewing data in a controlled and structured way, the organisation is trying to reconstruct what has happened, often across multiple brokers, carriers, systems, and time periods.

That is time-consuming, and it is not always possible to reach a clear conclusion.

Introducing structure into the review process

A more robust approach is to treat the review of customs data as a regular business activity, rather than an exception.

In practice, this means selecting a defined set of customs declarations, based on criteria that reflect the supply chain areas you want to understand better. This could be a full set of declarations over a given period, or a more targeted selection based on specific brokers, countries, or types of goods.

The key is that the selection is deliberate and repeatable.

Once the data has been identified, it can be reviewed at line level, with findings recorded as part of the process. Errors can be corrected, and patterns can be identified over time. This does not need to be complex, but it does need to be structured.

What changes when this becomes part of how you work

When companies start working in this way on a consistent basis, the conversation shifts.

There is a clearer understanding of how declarations are actually being completed across different parts of the organisation. It becomes easier to identify where inconsistencies occur, and to address them through better instructions or follow-up conversations with brokers and processors.

Just as importantly, there is a record of what has been reviewed and what has been found. That provides a level of documentation that is often very difficult to establish retrospectively.

Where Emma Compliance fits in

This is the type of process the Self-Audit Function in Emma Compliance is designed to support.

It allows users to define the scope of a review, generate a corresponding set of declarations, and work through them in a structured checklist. Findings, corrections, and commentary are recorded as part of the process, and completed audits are stored and available for later reference and reporting.

Because the same approach can be repeated over time, it becomes possible to build a consistent view of data quality across different brokers, markets, and periods.

The practical reality

Reviewing your own customs data is not a new idea, but it is still not something most organisations do in a systematic way. As a result, there is often a gap between what is assumed and what can actually be demonstrated.

Closing that gap does not require a large transformation programme. It requires a decision to start working with the data in a more structured way, and to continue doing so over time.