When a Receiving Count Discrepancy Becomes a Post-Summary Correction

By Bernardo Campelo, Forbes Business Council E-Commerce Leader, Amazon SPN Certified provider, Amazon SP-API authorized partner, and Founder of PrepVia.

The question reaches my inbox a few days after a container clears. The broker transmitted the entry summary last week, declaring 2,400 units straight off the commercial invoice. The dock has just opened its sample cartons, and three boxes marked 48 hold 42 each. One pallet carries a SKU that appears nowhere on the packing list.

Then the importer asks the question I cannot answer. Do we need to fix the customs entry? That decision does not belong to the warehouse. It belongs to the importer of record and its licensed customs broker, and since August 5, 2026, the rules for making that fix are stricter than most operations teams realize.

What the dock can do is hand over the record the decision depends on, fast enough to matter and clean enough to use.

What CBP Changed in the PSC Test on August 5, 2026

The Post-Summary Correction has run since 2011 as a CBP test under 19 CFR 101.9(b), which is why its rules live in Federal Register notices rather than in the regulations. On July 6, 2026, CBP published a notice modifying and clarifying the PSC test (FR Doc. 2026-13574, 91 FR 41053), and participants had to comply as of August 5, 2026. CBP followed on August 3 with CSMS # 69428352, which walks filers through the payment mechanics. Four points changed or were clarified.

Payment. Any increase in estimated duties, taxes and fees that results from a PSC must now be paid electronically through ACH, debit or credit. Checks and cash are no longer accepted. If your company never enrolled in CBP's Automated Clearinghouse program, that enrollment now sits on the critical path of any correction that adds duty.

Sequencing. The filer may pay the full increase before liquidation or wait for the bill at liquidation, except an antidumping or countervailing duty increase, which must be paid through ACH within three business days of the PSC. Either way, no subsequent PSC can be filed on that entry until the increase from the previous PSC is paid in full and processed.

Interest. CBP will not accept interest on a PSC increase before liquidation. It bills any interest after it liquidates the entry.

Suspended entries. The notice formalizes filing beyond 300 days when liquidation is suspended beyond 300 days on a listed basis, such as antidumping or countervailing duty, an Enforce and Protect Act case, or a court injunction. CBP says it has allowed this in practice since 2022.

At the dock, sequencing matters most. CBP sets no limit on the number of PSCs filed for an entry inside the window, although its PSC page says a PSC that goes to team review blocks further ones. And if one correction adds duty and nobody pays it, the entry is locked against the next one. A second discrepancy found three weeks later on the same container waits behind an unpaid bill.

Why the Dock Count Almost Always Arrives After the Entry Summary

Unless the importer files the entry summary at the time of entry, 19 CFR 142.12 requires it within 10 working days after the time of entry. The container still has to be drayed, given a dock appointment, unloaded and opened. By the time anyone counts units inside a sealed carton, the entry summary has often been transmitted already.

A PSC cannot go in the moment that happens, either. CBP requires the entry summary to be accepted, fully paid, in CBP control and not under CBP review. It cannot be liquidated, and it cannot be associated with a protest. For an entry on a Periodic Monthly Statement, CBP's Post Summary Correction page says the entry must be truly paid first, which can take up to 45 days after the entry date.

That gap is useful. Your broker needs it to compare the dock record with the invoice and the entry summary, ask the supplier what happened, and decide whether anything on the entry is wrong.

Four Discrepancies a Dock Finds, and the Rule Each One Can Touch

Not every count gap means the entry is wrong. A shortage at the dock may already be reflected in the invoice, covered by a supplier credit, or have happened between the terminal and the warehouse. The dock sees the gap. It does not see what you paid, what your supplier credited, or how your broker classified the goods.

This matrix says which rule a finding can touch, not which rule applies to your entry.

Every row ends with the importer and its broker. The dock owns the second column and nothing else.

Under 19 CFR 158.3, when the carrier refuses to sign the claim for missing packages, the importer can attach copies of the dock receipt or other documents evidencing nonreceipt. Whether a given warehouse record serves that purpose is for CBP and your broker to judge, but the rule tells you what kind of paper the process expects.

Under 19 CFR 158.5, a concealed shortage, meaning units missing from packages that arrived intact, is claimed by the importer alone, and the Center director must be satisfied the claim is valid. Both allowances turn on action taken before liquidation becomes final. A claim that depends on a CBP official being satisfied is only as good as the record behind it.

None of this is the same problem as units Amazon reports missing after check-in, a gap that runs inside Amazon against your shipment plan, as our guide to declared vs received FBA units explains.

Who Decides, and Why It Is Never the Warehouse

CBP is plain about ownership. Its PSC page says a filer submits a PSC because it is legally obligated to correct an entry under 19 U.S.C. 1484 and 1485, and that the trade is responsible for submitting it. Section 1484 requires the importer of record to make entry using reasonable care. Section 1485 requires a declaration that the importer will produce at once any document or information received showing that statements in the entry are not true or correct.

That clause is why a dock record matters. It is information. Whether it shows that a statement on the entry was wrong is a legal question for your broker and your customs attorney, and a warehouse that answers it for you is overstepping.

The PSC itself has limits that make the broker's role obvious. Some data cannot be changed through a PSC at all, including the importer of record, date of entry, bond, surety code and port of entry. Each PSC needs at least one reason code and a text explanation, and CBP allows up to five reason codes on a single PSC. The dock record is raw material for that explanation, never the explanation itself.

CBP's ACE Entry Summary Business Rules and Process Document (version 12.0, December 2023) adds a warning: PSCs typically address data that could have been determined at the time of entry, so filers that use them excessively may be penalized for failing to exercise reasonable care. One more reason the dock record should arrive complete.

At PrepVia, the line is simple. We receive the container in Miami after customs release, count it against the packing list and photograph the freight at intake. Our published standard is discrepancy reporting within 24 hours of arrival, with photos, and that report goes to you. We are not your importer of record or your customs broker, we do not file PSCs, and we do not decide whether one is needed. Our receiving report is a warehouse record, nothing more.

For where each party stops, read who does what between a broker, a forwarder and a 3PL and why the dock that unloads your container is not the importer of record.

The Correction Clock, From Entry to Liquidation and After

Here is the clock, from entry to the point where the PSC route closes.

CBP's PSC page also refers to a 314-day liquidation cycle, so the 300-day limit is not a comfortable margin. The deemed liquidation row is the one I would underline. Under 19 CFR 159.11, an entry CBP does not liquidate within a year, and whose liquidation was not extended or suspended under 19 CFR 159.12, liquidates at the quantity the importer asserted. In that case, the number nobody corrected is the number that liquidates. Silence is a decision.

After liquidation, the tools change and get heavier. Under 19 CFR 174.12, a protest must be filed within 180 days after liquidation for entries made on or after December 18, 2004. A prior disclosure under 19 CFR 162.74 covers a violation of 19 U.S.C. 1592 disclosed before, or without knowledge of, a formal investigation; the disclosing party identifies the entries, explains the false statements or omissions, and tenders any actual loss of duties. Both are conversations for your broker and your customs attorney, not for your dock.

The IEEPA Trap: Quantity Corrections Go Before the CAPE Declaration

If your entries carried IEEPA duties, the order of operations matters as much as the count. CSMS # 68340863, issued April 13, 2026, prohibits filers from initiating an IEEPA duty refund request by filing a PSC. The same message says PSCs for any other issue should be filed before submitting a CAPE Declaration.

CBP's IEEPA Duty Refunds FAQ, in answers last updated May 20, 2026, closes the door behind it. Once an entry is on a CAPE Declaration, no PSC can be submitted for it, and entries cannot be removed from a Declaration already filed. The April message adds that unliquidated entry summaries accepted on a Declaration are set to liquidate 45 days after acceptance, except warehouse entries and entries in suspended, extended or under review status.

A broker assembling a CAPE file needs to know, before upload, whether any container in it had a count problem. A report sitting in a warehouse inbox is invisible to that decision. If your broker is building a Declaration, ask your warehouse in writing for every open discrepancy on those containers, and let your broker decide the order.

I am not telling you whether to file anything. I am telling you that a dock record which arrives after the CAPE upload is too late to matter for a PSC on that entry. For issues found after that, CBP points to a protest or a prior disclosure once the entry liquidates.

The Discrepancy Packet: What Your Dock Should Hand Your Broker

This is the checklist I would put in any receiving agreement for imported freight. It decides nothing. It makes sure the people who decide get what they need, once, in one file.

Here is the difference between a fact and a projection, with illustrative numbers. The invoice and the entry summary say 50 cartons of 48 units, or 2,400 units. The dock receives 50 cartons, so the carton count matches. Your trigger rule calls for a 20 percent sample, and the dock opens 10 cartons. Three of them hold 42 units.

The fact the dock can sign is 18 units short across 10 opened cartons. The projection is 90 units short across the container. If your broker needs a container-wide number, the 40 unopened cartons need a full count, and paying for it is your call. Handing a projection to a broker as a count is how a correction goes in wrong and needs another correction.

The trade-offs between said to contain, sample and full counts are in real counts vs said-to-contain receiving. The clauses that make this packet enforceable belong in your prep center agreement, and what happens before anyone opens a carton is in container unloading in Miami.

Frequently Asked Questions

Does every receiving count discrepancy require a Post-Summary Correction?

Not automatically. A count gap at the dock may or may not mean the entry summary is wrong. The regulations also provide allowance claims for missing packages and for deficiencies in package contents under 19 CFR 158.3 and 158.5. Which route fits, if any, is for the importer of record and its broker to decide.

Can my prep center or 3PL file a Post-Summary Correction for me?

CBP says the trade is responsible for submitting a PSC, and an authorized ACE entry summary filer can file one for an entry another filer transmitted if the same importer of record authorizes it. PrepVia is not an importer of record or a customs broker, does not file PSCs, and does not decide whether one is needed.

What is the deadline to file a Post-Summary Correction?

A PSC must be filed within 300 days of the date of entry or up to 15 days before the scheduled liquidation date, whichever is earlier, and ACE rejects late PSCs automatically. Entries whose liquidation is suspended beyond 300 days on a listed basis, such as AD/CVD, EAPA or a court injunction, can take a PSC after day 300, a practice CBP has allowed since 2022 and formalized in its July 2026 notice.

How do I pay for a Post-Summary Correction that increases duties?

Since August 5, 2026, any PSC increase in duties, taxes and fees is paid through ACH, debit or credit, never by check or cash. Except for an AD/CVD increase, which is due within three business days, you may pay the full increase before liquidation or wait for the bill at liquidation, but you cannot file another PSC on that entry until the previous increase is paid in full and processed. CBP bills any interest after it liquidates the entry.

Can I use a Post-Summary Correction to claim an IEEPA tariff refund?

No. CSMS # 68340863, issued April 13, 2026, prohibits initiating an IEEPA duty refund request through a PSC. CBP says a PSC for any other issue, such as a quantity correction, should go in before the entry is on a CAPE Declaration, because after that no PSC can be submitted for it.

What should my warehouse send my broker when the count does not match?

One complete packet tied to the container, seal and entry number: the count method, carton by carton results against the packing list marks, timestamped photos, carton weights, and units counted kept apart from anything estimated from a sample.

What happens if nobody corrects the entry before liquidation?

Under 19 CFR 159.11, an entry not liquidated within one year of entry, unless liquidation was extended or suspended, is deemed liquidated at the rate, value, quantity and duties the importer of record asserted, and after a PSC CBP uses the most recently accepted PSC. After liquidation, CBP lists a protest or a prior disclosure as the remaining routes, both for your broker and your customs attorney.

Final Take

A receiving count discrepancy is a fact about cartons. A Post-Summary Correction is a legal act about an entry. The first becomes the second only when the importer of record and its broker read the dock record, compare it with the invoice and the entry summary, and decide the entry is wrong. No warehouse should make that decision.

What changed in 2026 is the cost of a slow or messy handoff. ACH is the only way to pay a PSC increase, an unpaid increase blocks the next correction, and a CAPE Declaration shuts the PSC door. And the 300-day clock started before the container reached a dock.

So build the handoff before you need it. Write the count method and the trigger rule into your receiving agreement, ask for one complete discrepancy packet, and route it to your broker by default. Then the question in my inbox becomes one your broker can answer with the evidence in hand.