Trade Compliance Checklist for Importers and Exporters

Most compliance failures don't come from a missing policy document. They come from a step skipped under deadline pressure, a screening that didn't run before a new customer's first order, or a certificate of origin nobody filed away.

A checklist doesn't replace judgment. But it catches the routine steps that get missed when a shipment is due out the door and everyone's focused on getting it there.

This checklist is organized around the points in a transaction where compliance obligations actually apply, from onboarding a new partner through post-shipment recordkeeping. Use it as a working reference, not a one-time audit.

Before Onboarding a New Customer or Supplier

Compliance starts before the first purchase order, not after.

• Screen the counterparty against OFAC's SDN List, BIS's Entity and Denied Persons Lists, and applicable EU/UK/UN sanctions lists
• Check ownership structure, not just the company name. Under BIS's 2025 Affiliates Rule, export restrictions on parties owned 50% or more by a listed entity now extend automatically to those affiliates
• Verify the counterparty's business is consistent with the products or services being transacted (a mismatch is a documented red flag under BIS guidance)
• Confirm the counterparty's country isn't subject to a categorical embargo or licensing restriction
• Document the screening result and date, even when the result is clean Trademo sanctions and PEP screening and ownership and control screening capabilities support this ownership-level check.

Before Every Shipment

Screening once at onboarding isn't enough. Lists change, and so do the specifics of each transaction.

• Re-screen the counterparty if the last screening is more than a few months old, or if this is a high-value or high-risk transaction
• Confirm the product's HS/HTS classification is current, especially if the product has changed since it was last classified
• Confirm the ECCN (or equivalent export control classification) for controlled items
• Determine whether the destination, end user, or end use triggers a license requirement
• Watch for red flags: reluctance to share end-use information, unusual payment terms, or shipment routed through a freight forwarder with no clear final destination

Product Classification Checklist

Classification errors are often invisible until an audit or a customs hold surfaces them.

• Confirm the HS/HTS code reflects the product's current composition and function, not just what was assigned at launch
• Recheck classifications after the WCO's periodic HS updates, which occur roughly every five years
• Recheck classifications after any packaging, material, or component change
• Confirm the ECCN classification separately from the HS code. They serve different purposes and can produce different outcomes
• Maintain a documented classification rationale for each SKU, not just the final code Trademo HS classification and ECCN classification capabilities apply this logic across large product catalogs.

Country of Origin and Duty Checklist

• Determine origin based on where substantial transformation occurred, not simply where final assembly happened
• Confirm the applicable duty rate matches the current classification and origin
• Check whether the shipment qualifies for a free trade agreement, and gather the documentation required to claim it
• Calculate landed cost including duties, freight, insurance, and applicable fees, not just product costLink
• For shipments using assists, royalties, or related-party pricing, confirm these are reflected in the declared customs value Trademo duties and tariff management, FTA qualification, country of origin determination, and landed cost calculator support these steps.

Forced Labor and Supply Chain Due Diligence

This applies specifically to US imports under the Uyghur Forced Labor Prevention Act (UFLPA), but the underlying discipline, mapping suppliers past tier one, is relevant wherever forced labor risk exists in a supply chain.

• Screen suppliers against the current UFLPA Entity List, which as of August 2026 includes 187 entities following the largest expansion in the list's history
• Map suppliers into tier-2 and tier-3, particularly in sectors CBP has flagged for enforcement, including aluminum, apparel, copper, cotton, and tomato products
• Maintain documentation, bills of material, production records, supplier attestations that could support a rebuttal if a shipment is detained
• Review CBP's current forced labor enforcement guidance, issued as a consolidated update in June 2026, rather than relying on older internal procedures Trademo supply chain mapping and forced labor compliance capabilities support multi-tier supplier visibility.

Documentation and Recordkeeping

Importers claiming preferential tariff treatment must maintain all supporting records for five years after the date of the claim. The same five-year standard applies broadly to entry records under CBP's recordkeeping rules.

• Retain bills of lading, commercial invoices, packing lists, and entry summaries for at least five years
• Retain certificates of origin and supporting bills of material for FTA claims for five years from the date of the certificate
• Keep export licenses, license exceptions used, and end-use certifications on file for the retention period that applies in your jurisdiction
• Confirm records are stored in a format CBP can review on request. Entry records generally must be produced within 30 calendar days of a CBP demand
• Assign a specific owner for recordkeeping. It shouldn't default to whoever filed the entry

Ongoing Program Maintenance

A compliance program isn't a one-time setup. These checks should run on a recurring schedule.

• Re-screen existing customers and suppliers periodically, not only at onboarding
• Track regulatory changes that affect your specific goods, destinations, and industries (tariff actions, entity list additions, classification updates)
• Audit a sample of past entries or export transactions each year to catch classification or valuation drift before CBP or a regulator does
• Confirm that reference data (tariff schedules, sanctions lists, regulatory content) used in classification and screening tools is current across every country you operate in
• Review internal ownership of each compliance function annually, since gaps often appear when a process owner changes roles Trademo global trade content capability provides regulatory intelligence across 140+ countries to help keep this reference data current.

Quick Reference: What to Check and How Often

A Note on Using This Checklist

This checklist covers common obligations that apply broadly across import and export compliance, but requirements vary by product, destination, and jurisdiction. A checklist built for a US importer of consumer electronics will look different from one built for a company exporting controlled industrial equipment to multiple markets. Treat this as a starting framework to adapt, not a substitute for a program built around your specific goods, trade lanes, and risk profile. Where any of these steps rely on manual, periodic review today, that's usually the first place to look for both risk and improvement.