What this is
What is a customs broker instruction?
What is a customs broker instruction?
It is the written direction an importer or exporter gives a licensed customs broker on how to enter a shipment: commodity codes, values, origin, Incoterms and any preference claim, plus the record of what the broker actually filed. Brokers act under power of attorney, but the instruction is the importer's own evidence of what it asked for, separate from the broker's filing.
Who is liable if the broker files an entry incorrectly?
The importer of record is liable for the entry, not the broker, even where the broker made the classification or valuation error. Reasonable care is judged on the importer's own conduct, including whether it gave a documented instruction and checked what was filed, which is why this record exists as a standalone document rather than living inside the broker's own files.
Why does the instruction need a verification step after filing?
Because a broker can file something other than what it was told, by error or by applying its own default classification, and nothing catches that unless someone compares the filed entry against the instruction. The Verification after filing section is that comparison; without it, an instruction is just a request with no evidence it was followed.
Scope
When is a customs broker instruction required?
This record is one step in a larger programme. Using it for work that belongs to a neighbouring template produces records that are hard to report on later.
Use this template when
- A shipment is being entered by a broker under power of attorney and needs a documented instruction before filing
- An entry has already been filed and needs checking against what was actually instructed
- The workspace is being set up, or the broker register needs an entry added or retired
- You are running the Trade and Customs Compliance programme and this is one of its steps
- A linked record needs this one to exist: Import Documentation and Vendor Scorecard reference it
Do not use it for
- Import Documentation Check, which checks that an inbound shipment carries the documents customs will ask for, not what the broker was told to file.
- Export Documentation Check, which checks an outbound shipment's classification and certificates, not the broker's own filing accuracy.
- Country of Origin Verification, which establishes the origin evidence a preference claim relies on, before that claim goes into this instruction.
- Dangerous Goods Shipment Declaration, which classifies and declares a hazmat consignment; the broker instruction assumes that work is already done.
- Anything outside KnowLogistics, which belongs in the workspace that owns that process
Compliance mapping
Which 49 CFR 172 requirements does this satisfy?
The instruction sits between two liability regimes: the broker's duty to file what it was told, and the importer's duty to have told it correctly and checked the result. The clauses below attach to whichever side of that line a given field actually evidences.
| Clause | Requirement | Where it lands |
|---|---|---|
| 19 U.S.C. § 1484 (Entry; reasonable care) | The importer must exercise reasonable care in providing information for the entry, even where a broker files on its behalf. | Instruction content |
| 19 CFR Part 111 (Customs brokers) | A broker must be given a written instruction it can act on, not verbal or after-the-fact direction. | Header |
| 19 CFR 111.29 (Responsible supervision and control) | The broker's own actions are supervised internally, but the importer's instruction is the independent record of what was actually asked for. | Header |
| 19 CFR Part 141 (Entry of merchandise) | Entered value, classification and origin must match the information the importer provided, not what the broker assumed. | Verification after filing |
| 19 U.S.C. § 1592 (Penalties for fraud, gross negligence, negligence) | A mismatch between instruction and filed entry, left uncorrected, is evidence of negligence in a penalty proceeding. | Outcome |
| 19 CFR Part 163 (Recordkeeping) | Entry records and the instruction behind them must be retained for the statutory period, not just the broker's own paperwork. | Verification after filing |
| 49 CFR Part 172 (Hazardous materials shipping papers) | Where the shipment carries dangerous goods, the instruction must also carry the correct hazmat description, not only a tariff classification. | Instruction content |
| 19 U.S.C. § 1509 (Examination of books, records and witnesses) | Customs can call for the instruction and the filed entry together; a scorecard entry with no evidenced check does not satisfy that demand. | Outcome |
What it does not cover
- Instruction Given In Writing, which turns a phone call into unauditable direction the broker can reinterpret however suits it.
- Entry Copy Received, which means nobody has actually seen what was filed under the importer's own liability.
- Codes Filed Match Our Instruction, which is the one comparison that catches a broker's classification error before it compounds across future entries.
- Amendment Required, which is left unanswered while an entry with a known discrepancy sits on file uncorrected.
- Records Retained For The Required Period, which is the field a customs audit will ask for first.
Global
Customs Broker Instruction requirements by country
Broker liability regimes differ in name, but land on the same point: the instruction is what separates the importer's exposure from the broker's.
19 U.S.C. § 1484 and 19 CFR Part 111
Liability for the entry rests with the importer of record, not the broker who filed it.
Reasonable care is judged on the importer's own conduct, including whether it gave written instructions and checked the filed entry, not on the broker's competence.
Union Customs Code, Regulation (EU) No 952/2013, Article 18
A customs representative acting in an indirect capacity is jointly liable with the person it represents.
The written instruction is the evidence that separates the representative's own liability from the importer's, and its absence leaves both exposed.
Taxation (Cross-border Trade) Act 2018 and CDS indirect representation rules
An indirect representative and the importer share customs debt liability, on the same logic as the EU regime it replaced.
HMRC treats the instruction and the post-filing check as the paper trail showing who told the broker what, which is what a post-clearance audit asks for first.
How to complete it
How to complete a customs broker instruction, step by step
None of these are answered by following the form. Each one is a judgement about whether the paper trail would survive a post-entry audit, not whether the box got ticked.
A verbal instruction confirmed in writing before the entry is filed still counts. One that only exists in the broker's notes after the fact does not. Instruction Given In Writing is asking whether the record predates the filing, not whether a conversation happened.
Codes Filed Match Our Instruction and Values Filed Match are asking for an exact comparison against what was instructed, not a broker's assurance that the entry is fine. A rounding difference in currency conversion is not the same finding as a different tariff heading, even though both could be answered No.
Duty Variance is a number, not a verdict. The judgement is deciding at what size that variance stops being noise and starts requiring Amendment Required to be answered Yes; a workspace that never sets that line will always answer No, because nobody is forced to look.
Errors Found can be non-zero while Action Required is still No, if the error was caught and corrected before it affected duty owed or the tariff outcome. That call belongs to trade compliance, not to whoever is closing the form, because it is the difference that decides whether a CAPA gets opened.
What auditors find
Most common customs broker instruction findings
These are the six ways this record most often fails to hold up, and the clause each one is actually tested against.
| Finding | Clause | What fixes it |
|---|---|---|
| Instruction given only over the phone, with no written confirmation before filing. | 19 CFR Part 111 / 19 U.S.C. § 1484 | Require a written instruction, email is sufficient, logged before the Entry Number is captured, not reconstructed after the fact. |
| No entry copy on file, so Codes Filed Match Our Instruction is being answered without a document to check against. | 19 U.S.C. § 1509 (Examination of books) | Make Entry Copy Received a hard gate on the fields below it; a comparison without the document isn't a comparison. |
| Duty Variance recorded but never connected to a decision on Amendment Required. | 19 CFR Part 141 | Set a variance threshold, even a rough one, above which Amendment Required must default to a review rather than a pass. |
| Preference Claim Instructed marked Yes with no origin evidence attached elsewhere in the workspace. | Country of Origin Verification (LOG-039) linkage | Cross-check against the origin record before the preference claim goes in; an unfounded claim is the exposure a customs audit targets first. |
| Feeds Broker Scorecard answered Yes with no Vendor Scorecard ID entered. | Internal workflow integrity, no external clause | Block completion until the scorecard ID is populated, or the vendor scorecard is silently missing entries it should carry. |
| Records Retained For The Required Period marked Yes with no retention date or location recorded anywhere on the form. | 19 CFR Part 163 (Recordkeeping) | Add a retention-until date at the point of filing rather than a yes/no that relies on someone remembering the policy. |
Case in point
Case in point: the classification nobody checked
A broker was told by phone which tariff heading to use on a routine import. No written instruction went across, and the entry was filed under the broker's own default code for that product line instead, a code that had been correct for a similar item two years earlier. The shipment cleared without incident and the entry sat in the broker's files, unseen by trade compliance.
Eighteen months and forty more entries later, a customs post-entry audit pulled the file and asked for the instruction behind the classification. There wasn't one. What existed instead was a pattern of entries under the wrong heading, a duty shortfall across all of them, and no record showing the importer had ever told the broker anything different. The Verification after filing section exists specifically to catch this on entry one, not on audit.
The template
The template, field by field
The form exactly as it installs. Every field, option, score and conditional rule is editable, and the links to other templates come with it.
4 sections
- Reference
- LOG-040
- Archetype
- Record
- Record ID
- BRK-2026-000
- Scoring
- Entries matching instruction
- Direction
- High is good
- Singleton
- Yes
- Basis
- 49 CFR 172
- Links
- Links Import Documentation and Vendor Scorecard
- Tags
- Customs, Broker
- Sections
- 4
- Fields
- 39
- Follow up fields
- 3
- Repeating sections
- 0
- Links out
- 4
Header
13 fieldsInstruction ID*
Auto sequence. Format BRK-2026-000.
The record's own ID. Other templates point at this value.
Status*
Drives who this goes to next.
- Planned2 pts
- In progress2 pts
- Complete3 pts
- Deferred0 pts
- Open0 pts
- Closed3 pts
- Overdue0 pts
Date and Time*
Completed By*
Site*
Site ID*
Format SITE-000.
Links to FDN-001 Site ID
Broker
Shipment Reference*
Entry Type*
Import, export, transit, or warehousing.
Instruction Issued*
Entry Number
Instruction Given In Writing*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Filed In Your Name
You remain liable for the entry a broker makes on your behalf. Instructing them in writing and checking what was actually filed is the only way that liability is manageable.
Instruction content
6 fieldsCommodity Codes Provided By Us*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Values And Currency Stated*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Origin Stated*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Incoterms Stated*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Preference Claim Instructed*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Special Procedures Instructed*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Verification after filing
6 fieldsEntry Copy Received*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Codes Filed Match Our Instruction*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Values Filed Match*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Duty Charged As Expected*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Errors Corrected Promptly*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Records Retained For The Required Period*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Outcome
14 fieldsEntry Correct*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Errors Found
Duty Variance
Amendment Required*
- Yes0 pts
- No2 pts
- N/Aexcluded from denominator
Feeds Broker Scorecard*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Vendor Scorecard ID
Links to QUA-041 Scorecard ID
Action Required*
Raise the action record, then enter its reference here.
- No2 pts
- Yes0 pts
Priority
- High0 pts
- Medium1 pt
- Low3 pts
CAPA ID
Format CAPA-2026-00000.
Links to FDN-014 CAPA ID
Action Owner
Trade Compliance*
Signature*
Finance*
Second Signature*
LOG-040 · record IDs look like BRK-2026-000 · Links Import Documentation and Vendor Scorecard
Open in KnowellaRun it with agents
From a document you fill in to a programme that runs itself
The form is the easy part. Keeping the instruction ahead of the filing, and holding the evidence together once the entry clears, is the work that actually slips.
Holds the broker instruction register against every entry, flags where Instruction Given In Writing or Entry Copy Received is missing, and keeps the evidence trail intact.
Owns the Vendor Scorecard this record feeds; ties a broker's amendment and duty-variance history back to the scorecard so a pattern of errors shows up before it becomes a habit.
Rolls this record into the wider Trade and Customs Compliance picture, so a missing verification step or an unresolved amendment surfaces at programme level, not just per entry.
Coordinates the crew, rolls completion and exceptions into one view, and holds every write for your approval before it touches a record.
This template lives in KnowLogistics — supply chain execution. Inbound, outbound, inventory, yard, claims, supplier lifecycle and customs.
Glossary
Customs Broker Instruction definitions and key terms
- Importer of record
- The party legally liable for an entry's duties, taxes and accuracy, regardless of who physically filed it.
- Power of attorney (customs)
- The legal authorisation an importer gives a broker to file entries on its behalf.
- Commodity code (HS/tariff classification)
- The classification used to determine the duty rate and admissibility of a shipment.
- Preference claim
- A claim for a reduced or zero duty rate under a trade agreement, based on the goods' verified origin.
- Post-entry audit
- A customs authority's review of an entry after it has already cleared, often requesting the instruction and supporting evidence behind it.
FAQ
Frequently asked questions about customs broker instruction
What is the customs broker instruction template based on?+
It is built against 49 CFR 172, the United States hazardous materials transport rule covering classification, packaging, marking and shipping papers, which applies wherever the instructed shipment carries dangerous goods alongside its customs entry.
What sections does the customs broker instruction contain?+
Four sections: Header, Instruction content, Verification after filing, and Outcome. The first two capture what was asked for; the last two capture what actually happened.
Does completing the instruction section mean the entry is compliant?+
No. The instruction only records what the importer asked the broker to do. Compliance is only evidenced once the Verification after filing section confirms the entry that was actually made matches it.
Which programme does the customs broker instruction belong to?+
Trade and Customs Compliance, alongside import and export documentation checks, dangerous goods declarations and origin verification. Its output feeds the Vendor Scorecard for the broker.
How is a customs broker instruction scored?+
By entries matching instruction, where high is good. Fields reward a clean instruction, a documented verification, and an amendment history of No rather than Yes.
What happens when Amendment Required is Yes?+
It scores lower than No, because an entry that needs correcting after filing is the failure this record exists to catch early. It should also drive an Action Required entry and a CAPA where the underlying cause could recur.
Keep going
Related templates and programmes
Industries this is written for
Programmes this belongs to
Used together in Trade and Customs Compliance
Dangerous Goods Shipment Record
Records the shipping documents, placarding and segregation for a dangerous goods load
Import Documentation Check
Checks that an inbound international shipment has the documents customs and the regulator will ask for
Export Documentation Check
Checks that an outbound international shipment carries the correct classification, certificates and declarations
Dangerous Goods Shipment Declaration
Classifies, packs, marks and declares a dangerous goods consignment, and records who was trained to do it
Country of Origin Verification
Verifies and evidences the origin claimed for a material or product, which drives duty, labelling and customer claims
Safety Data Sheet
Holds the full sixteen section safety data sheet for one substance, in the order fixed by GHS and adopted by WHMIS 2015 and OSHA 1910
More in Trade and Customs
Import Documentation Check
Checks that an inbound international shipment has the documents customs and the regulator will ask for
Export Documentation Check
Checks that an outbound international shipment carries the correct classification, certificates and declarations
Dangerous Goods Shipment Declaration
Classifies, packs, marks and declares a dangerous goods consignment, and records who was trained to do it
Country of Origin Verification
Verifies and evidences the origin claimed for a material or product, which drives duty, labelling and customer claims
Written and reviewed by
Siddarth Singh
Founder & Chief Executive Officer, Knowella
Certified Safety Professional and industrial and systems engineer with more than a decade inside food supply chain, freight and manufacturing operations. This page was written against the current text of the standards it cites, not against secondary summaries of them.
- Certified Safety Professional (CSP), Board of Certified Safety Professionals
- MBA, University of Chicago Booth School of Business
- MS and BS, The Ohio State University, Industrial and Systems Engineering
- Six Sigma Black Belt
Sources and last review. Reviewed 16 August 2026 against:
- 49 CFR Part 172 — Hazardous materials shipping papers and packaging
- 19 U.S.C. § 1484 — Entry of merchandise; reasonable care
- 19 CFR Part 111 — Customs brokers
- 19 CFR Part 163 — Recordkeeping
- Regulation (EU) No 952/2013 — Union Customs Code, Article 18 (Customs representative)
This page is general guidance, not legal advice. Confirm requirements with your jurisdiction’s regulator.