CBP Form 247 – Cost Submission

Jurisdiction: Country: USA | Province/State: Federal

What is a CBP Form 247 – Cost Submission?

CBP Form 247 is a standardized cost submission used by U.S. Customs and Border Protection to collect detailed cost and pricing information that supports customs valuation and duty assessment. You use it to show how you calculated the value of imported goods when CBP needs more than just the commercial invoice. The form organizes your cost data into defined categories so CBP can verify that your declared values are correct and complete.

You typically encounter this form when transaction value alone does not answer CBP’s questions about price, assists, or related-party transactions. It gives CBP a full picture of materials, labor, overhead, assists, general expenses, profit, and packing. It also captures how you allocate indirect costs and amortize tooling or engineering across production.

Who typically uses this form?

Importers of record, foreign manufacturers, contract manufacturers, and their customs brokers. In practice, you, as the importer, coordinate the submission. Your supplier or manufacturer prepares the cost breakdown because they hold the cost records. Your broker helps format and file the package.

You need this form when CBP asks for a cost breakdown to verify your declared value. That can happen during an entry review, a focused assessment, a valuation inquiry, or anytime CBP questions whether your price includes all required additions. If you use a computed value, or if your sale involves related parties, you should expect to provide a Form 247 or an equivalent cost package.

Typical usage scenarios

• CBP questions a related-party price. You show that the price covers all costs plus an appropriate profit and general expenses. You do that by submitting a completed Form 247 with supporting schedules.

• You provided an assist to your supplier, such as a mold or engineering. You need to add the prorated value of that assist to the customs value. You document the math and the allocation method on the form.

• The transaction value is not available or acceptable, so you rely on the computed value. Form 247 becomes the backbone of your computed value calculation, item by item.

• You claim special tariff provisions that require cost data. You need to prove the value of U.S.-origin components returned in a finished article, or you need to allocate costs for kits or sets. Form 247 captures those costs in a clear, auditable manner.

At the end of the day, CBP Form 247 is about transparency. You tell CBP exactly what makes up the value of your goods, how you calculated each component, and why the result is correct. You give CBP enough detail to verify your numbers without digging through raw accounting records.

When Would You Use a CBP Form 247 – Cost Submission?

You use CBP Form 247 when CBP requests cost data in connection with a specific entry, product line, or audit. You may also use it proactively when you know your valuation depends on costs that do not appear on the invoice. If you import under related-party pricing, if you provide assists, or if you apply computed value, this form is a practical tool.

For example, you import consumer electronics from a wholly owned subsidiary. The transfer price is stable across markets and sometimes sits below your supplier’s total cost early in the product life cycle. CBP notices that pattern and asks how you ensure the price is acceptable. You provide a Form 247 showing materials, direct labor, factory overhead, and an allocation of engineering costs. You add general expenses and profit to reach a computed value that supports the declared price.

Another example: You provide a $250,000 injection mold to a contract manufacturer. The mold will produce 500,000 units over three years. Your invoices do not include the mold’s value. CBP asks how you added the assist to your declared value. On Form 247, you show the math: $250,000 divided by 500,000 units equals $0.50 per unit, added to the customs value for each unit imported.

You might also use the form during a focused assessment or a post-summary review. CBP may request a representative sample of entries with full cost support. Form 247 helps you present consistent, complete cost data. It reduces back-and-forth and keeps your explanations aligned across different product families.

Typical users include import compliance managers, controllers, and supply chain finance teams. Your foreign manufacturer’s costing staff will often prepare detailed schedules. Your customs broker can help map cost lines to customs valuation rules and ensure the package meets port expectations. If you use a third-party contract manufacturer, expect to coordinate nondisclosure terms so they can share cost data for CBP’s review.

You might also rely on Form 247 for specialized provisions that look to cost. If you partially assemble goods abroad and return them, you need to separate the value of U.S. components from foreign processing costs. The form gives you a structured way to show those numbers and support your claim.

In short, if CBP needs to see what is behind your declared value, you use CBP Form 247. It is the accepted vehicle for that conversation.

Legal Characteristics of the CBP Form 247 – Cost Submission

Your cost submission is a statement to a federal agency. When you sign the certification, you affirm that the data is true, complete, and accurate to the best of your knowledge. That signature carries legal consequences. False or misleading statements can lead to penalties. If CBP relies on your numbers to assess duty, those numbers must be supportable in your books and records.

Is it legally binding?

Yes, in the sense that your certified statements become part of the official entry file. CBP can rely on them to liquidate entries and assess duties, taxes, and fees. If your cost submission understates required additions, CBP can assess the difference with interest. If the misstatement is material, CBP can pursue penalties under customs laws covering negligent or fraudulent entry.

What ensures enforceability?

The certification, your duty to keep records, and CBP’s audit and verification rights. You must retain supporting records for a defined period after entry. CBP can examine your records at any time within that window. If CBP doubts a figure, it can ask for back-up, such as bills of materials, time sheets, overhead allocation policies, and financial statements. CBP can also disallow a claim if you cannot substantiate it. Your signature block shows who is accountable for the submission.

You should also consider confidentiality. You can mark proprietary cost data as business confidential. CBP will handle confidential data under applicable rules, but you should only include what is relevant. Use summaries and schedules rather than raw ledgers when possible. If CBP needs more detail, it will ask.

Finally, be mindful of consistency. Your cost submission should align with your transfer pricing policies, financial statements, and internal cost accounting. If your customs value assumes certain allocations, those allocations should match your normal books unless you explain the differences. Inconsistent stories raise questions and prolong reviews.

How to Fill Out a CBP Form 247 – Cost Submission

You want to complete the form once and get it right. Use the steps below to prepare a clean, defensible submission that answers CBP’s questions on the first pass.

Step 1: Gather the right records

• Commercial invoices and packing lists for the covered entries.
• Entry numbers, ports, and dates.
• Bills of materials and standard cost sheets for each SKU.
• Purchase orders and terms of sale (Incoterms and currency).
• Labor rates and overhead burden rates, with support for how you calculated them.
• Engineering, tooling, molds, and other assists, including invoices and amortization schedules.
• General and administrative expense allocation policies.
• Profit margins or target returns for the product line.
• Transfer pricing documentation if you buy from an affiliate.
• Freight, insurance, and packing costs if not part of the invoice price.
• Exchange rates used and dates of conversion.

Decide on the scope. Identify the time period, the entries, and the SKUs included. Make sure your numbers tie to the period and entries CBP asked about.

Step 2: Choose your costing approach and allocations

• Decide if you will present actual costs, standard costs, or a mix. If you use standard costs, reconcile to actual later.
• Define your overhead allocation base (labor hours, machine hours, or materials cost). Use a method consistent with your books.
• Identify assists and decide on a reasonable amortization base (units produced, units imported, or time-based).
• Set your general expenses and profit approach. For the computed value, include both and explain how you derived them.

Document each choice. CBP will want to see the method and the math.

Step 3: Complete the header and parties

• Importer of Record Name and Number: Your legal name and identification number.
• Manufacturer/Supplier: Full name and address of the producer of the goods.
• Exporter (if different): Full name and address.
• Customs Broker: Name and filer code, if they will submit the package.
• Port(s) of Entry and Entry Numbers: List the entries covered.
• Date Range Covered: State the production and shipment dates relevant to the costs.
• Contact Person: List a person who can answer technical cost questions, with title and email/phone.

Keep names and numbers consistent with your entry summaries.

Step 4: Identify the goods

For each product family or SKU:

• Product description, model or SKU number, and HTS classification.
• Country of origin and plant location.
• Terms of sale (for example, FOB factory).
• Quantity imported during the period.

If you cover multiple SKUs, you may present a representative sample. Make sure your sample reflects the larger population and explain your selection.

Step 5: Materials cost schedule

For each SKU or product family:

• List major components and raw materials with unit costs.
• Show scrap or yield factors if relevant.
• Identify any materials supplied by the buyer at reduced or no cost.

Tie totals back to the bill of materials. If you use standard costs, show a variance analysis or a reconciliation to actual costs for the period.

Example: Component A at $4.20, Component B at $1.10, PCB at $7.65, plus minor parts at $0.85, total materials $13.80 per unit.

Step 6: Direct labor and factory overhead

• Direct labor: Show labor minutes per unit and the loaded labor rate. If you include benefits or statutory charges, identify them.
• Factory overhead: Show your burden rate and base. Explain how you calculated depreciation, utilities, indirect labor, and maintenance.

Example: 12 minutes per unit at $18.00 per hour equals $3.60 direct labor. Overhead at 150% of direct labor equals $5.40 per unit.

If your overhead is based on machine hours, show machine time per unit and the hourly burden.

Step 7: Assists with specialized tooling

Identify all assists provided by or paid for by the buyer:

• Tooling, molds, and dies.
• Engineering and design work undertaken outside the United States for the imports.
• Materials or components supplied free or at reduced cost.

For each assist:

• State the total cost, date placed into service, and the intended production volume.
• Choose the amortization base (units produced or units imported).
• Show the per-unit add-on.

Example: A $250,000 mold for 500,000 planned units yields $0.50 per unit. If you import 100,000 units this year, your declared value includes $50,000 in assist value.

Include invoices and acceptance records for the assistance. If you used a time-based amortization, explain why that method fits the production reality.

Step 8: Packing, inland freight, and other costs

• Packing: Include the cost of cartons, foam, manuals, or pallets required for export shipment if not in the invoice price.
• Inland freight and handling in the country of export are not included in the price and are required by your terms.
• Buying commissions: Identify them separately. Do not include if they qualify as buying commissions. Be ready to substantiate the nature of the services.
• Selling commissions: Include in value if paid by you to your seller’s agent.

State which items are included in the invoice price and which you add separately. Align your treatment with your Incoterms.

Step 9: General expenses and profit (for computed value or related-party tests)

If you apply the computed value, include:

• General expenses: A percentage for administrative and selling costs incurred by the producer. Derive from the producer’s financials.
• Profit: A reasonable profit for the producer on the exported goods. Use the producer’s actual profit for the class or kind where available.

If you are not using a computed value, you may still present these figures to demonstrate that a related-party price covers all costs plus profit. Explain your sources and calculations in a short narrative.

Step 10: Currency conversion and period alignment

• State the currency of each cost element.
• Identify the exchange rates used and the date of conversion.
• Use a consistent approach across the submission. If you use average period rates, say so. If you use transaction-day rates, say so.

Reconcile the per-unit costs to the quantities and the date range CBP requested. If you mix periods, explain the rationale.

Step 11: Summarize per-unit computed value (if applicable)

For each SKU:

• Materials
• Direct labor
• Factory overhead
• Assists (per-unit)
• Packing
• General expenses
• Profit

Provide a clean per-unit total. Cross-check against your declared unit value. If the declared value differs, explain why and how you accounted for the difference.

Step 12: Entry-level roll-up

Tie your per-unit results to the entries:

• Quantity per entry.
• Per-unit additions (for assists or packing) multiplied by the quantity.
• Any entry-specific adjustments.

Provide a control sheet that lists each entry number with the total value impact. This helps CBP reconcile your entry summaries.

Step 13: Certifications and signature

Complete the certification:

• Name and title of the responsible officer or authorized agent.
• Company name.
• Date of certification.
• Signature (wet or electronic, as allowed).

The certification states that the information is true and complete. Ensure the signer understands the content. They may be asked to explain it.

Step 14: Attachments and exhibits

Include only what supports your numbers:

• Bills of materials and standard cost sheets.
• Overhead rate calculations and policies.
• Assist with invoices and amortization schedules.
• Packing lists for special packing claims.
• Financial statements or extracts showing general expenses and profit.
• Transfer pricing policies if relevant.
• Reconciliations to entry summaries.

Label each exhibit and reference it in the body. Use clear file names if you submit electronically.

Step 15: Submission and follow-up

Submit the package to the CBP office or team that requested it. Confirm the due date and format. If you need more time, request an extension in writing before the deadline and explain why.

After submission, be ready for follow-up questions. Keep your costing lead and your broker on call. If CBP requests plant-level records, arrange secure transfer and clarify confidentiality handling.

Practical tips to avoid delays

• Be consistent. Use the same SKU names and numbers as your invoices and entries.
• Keep math transparent. Show the formula and the result. Avoid black-box summaries.
• Explain anomalies. If a cost spikes or drops, include a one-line reason.
• Separate non-dutiable items. If a charge is outside customs value, identify it and explain why.
• Reconcile to the penny. Tie totals to entry values and quantities.
• Mark confidential pages. Limit distribution to those who need to see it.

Common pitfalls to avoid

• Missing assists. Tooling and engineering are often overlooked. Confirm with sourcing and R&D.
• Double-counting overhead. If your labor rate is loaded, don’t add the same costs again under overhead.
• Misaligned periods. Standard costs from last year with current-period entries invite questions. Reconcile to the actual.
• Unsupported allocations. If you switch allocation bases mid-year, document the change and the reason.

A quick example walk-through

You import 10,000 units of a smart thermostat from your related manufacturer. Your declared price is $28 per unit, terms FOB factory. You provided a $100,000 test rig used only for this model, expected to cover 200,000 units.

Your per-unit cost schedule:

• Materials: $12.40
• Direct labor: $2.60
• Overhead (150% of labor): $3.90
• Assist (test rig): $0.50 ($100,000/200,000 units)
• Packing: $0.30
• General expenses: $2.10 (based on producer’s actual)
• Profit: $1.20 (based on the producer’s actual)

Computed value total: $22. — This supports that your $28 declared price exceeds the total cost plus profit. You include the $0.50 per unit assist in your declared customs value if it was not embedded in the invoice price. You tie the additional $5,000 in assist value to the specific entry (10,000 units x $0.50). Your control sheet shows how the entry’s dutiable value reflects that addition.

That is exactly what CBP expects to see: clear costs, reasonable allocations, and a straight reconciliation to the entry.

If you follow this structure, you will answer the key questions upfront. You will also reduce the risk of rework, penalties, or prolonged reviews. Your Form 247 becomes a reliable record that supports your entry values now and during any future audit.

Legal Terms You Might Encounter

Transaction value means the price you paid the seller for the goods. It includes certain costs, like packing, that you pay for the seller’s benefit. If CBP accepts transaction value, you may not need detailed cost data. When CBP questions the price, your cost submission helps support or replace it.

Computed value is a valuation method based on the producer’s costs. It adds materials, fabrication, and an amount for profit and general expenses. Your cost submission supplies these figures. CBP uses them when the transaction value does not apply or lacks credibility.

Deductive value uses U.S. resale prices to value imports. It deducts allowable costs, like commissions, transport, and duties. If CBP uses deductive value, your form still matters. It can support cost-based adjustments and explain price structures.

Assists are items or services you provide to the producer at no charge or reduced cost. Examples include molds, dies, engineering, or materials. They can increase customs value. On this form, you must disclose assets and show how you allocated them to each unit.

Related party means you and the seller have a relationship that could affect the price. Examples include ownership, control, or family ties. CBP reviews related-party pricing closely. Your cost submission helps show that the price reflects market reality.

General expenses and profit represent the producer’s overhead and margin. They include factory overhead and other indirect costs. They also include the producer’s profit. You must state these amounts clearly. CBP wants to see how you arrived at them.

Packing costs cover the materials and labor used to pack the goods for export. This includes retail packaging and export packing. They belong in the customs value. Your form should list packing separately to avoid confusion.

Apportionment means spreading a cost across multiple products or shipments. You do this for assists, freight, or shared overhead. CBP expects a reasonable method that you apply consistently. Document your basis and show your math.

Reconciliation is a process to report value changes after entry. You use it when exact figures are not known at entry. Your cost submission may feed into a later reconciliation. Keep your calculations consistent with what you file later.

Liquidation is CBP’s final calculation of duties for an entry. After liquidation, changes are hard to make. Your cost submission can affect liquidation. Accurate and timely data helps prevent extra duties or delays.

FAQs

Do you need to file a cost submission for every entry?

No. You submit cost data when CBP requests it, or when the transaction value is not appropriate. You also submit costs when you rely on a computed value. Follow any CBP notice you receive. If you file reconciliation, your cost figures may support that filing.

Do you include profit in the computed value?

Yes. The computed value includes profit and general expenses. Use amounts that reflect the producer’s normal margin on similar goods. If you use an industry benchmark, explain why it fits. Show your method and the period used.

Do you include assists even if they were free to the producer?

Yes. Assists in increasing customs value. State the assistant’s total cost and how you allocated it to each unit. Include engineering or design work done outside the U.S. if you provided it. Keep backup for invoices, labor, and time records.

Do you convert foreign currency to U.S. dollars?

Yes. Use a consistent conversion date and rate. Explain your rate source and the date of conversion. Apply the same approach to all parts of the submission. Keep records of the original currency values.

Do you need to provide translations for foreign cost sheets?

Yes, if CBP requests them or if clarity is at risk. Provide a clear English summary for each key document. Include translations for headings, line items, and notes. Attach the original files as backup.

Do you need to break out packing and inland freight separately?

Yes. CBP needs to see each cost component. Separate packing, inland freight, international freight, insurance, and handling. Note which costs occur outside the U.S. Breakouts help CBP test the value correctly.

Who can sign the form?

An officer, partner, or authorized employee with knowledge of the facts should sign. A customs broker may prepare the form. You remain responsible for accuracy. Make sure the signer can explain the numbers if CBP calls.

Can you amend a cost submission after filing?

Yes, if you find errors or receive new data. File a corrected submission quickly. Mark it as a revision and explain the changes. Update any related entries or reconciliation filings. Keep a record of both versions.

Checklist: Before, During, and After

Before signing

• Product scope. Confirm the exact models, SKUs, and time period.
• Producer details. Legal name, factory addresses, and contact information.
• Cost period. State the accounting period used. Align it with the shipments.
• Bills of materials. Materials, quantities, scrap rates, and unit costs.
• Labor. Direct labor rates, hours per unit, and fringe details.
• Overhead. Factory overhead pools and allocation bases.
• General expenses. Selling, administrative, and other indirect costs.
• Profit. Amount and basis used. Internal or benchmark data.
• Assists. Description, total cost, useful life, and allocation method.
• Packing. Materials and labor for export and retail packs.
• Freight. Inland freight to port, handling, and international freight.
• Insurance. Marine or cargo insurance amounts and coverage period.
• Currency. Rates, dates, and rationale for conversions.
• Transfer pricing. Any adjustments made to align with customs value.
• Supporting records. Invoices, ledgers, payroll, and production reports.
• Prior filings. Related entries, CF 28 or CF 29 responses, and reconciliations.
• Signer authority. Evidence that the signer can certify the facts.

During signing

• Entity names. Check that the importer and producer names match your records.
• Period dates. Confirm fiscal or production dates are accurate.
• Unit of measure. Match units across BOM, labor, and shipments.
• Quantity tie-out. Costs must reconcile to units produced and sold.
• Math checks. Recheck totals, per-unit costs, and apportionments.
• Assists with allocation. Confirm method and useful-life assumptions.
• Profit and expenses. Ensure they reflect normal producer experience.
• Packing breakout. Keep packing separate from product costs.
• Freight split. Separate foreign inland and international segments.
• Currency conversions. Confirm rates and dates are consistent.
• Narrative notes. Add short explanations where numbers may raise questions.
• Signature block. Date, title, and correct contact information.

After signing

• Submission method. Deliver the form as instructed by CBP or your broker.
• Acknowledgment. Keep proof of submission date and recipient.
• Entry alignment. Ensure entries reflect the same value logic.
• Reconciliation plan. Calendar deadlines if you reconcile the value later.
• Monitor status. Track CBP questions and respond on time.
• Update stakeholders. Notify finance, sourcing, and your broker of any impacts.
• Amendments. File corrections promptly if numbers change.
• Duty impact. Model duty differences and post any extra security if needed.
• Recordkeeping. Store all supporting data for the required period.
• Post-liquidation review. Check liquidations match your submission.
• Internal controls. Update procedures to prevent repeat issues.

Common Mistakes to Avoid

Don’t forget assists. Missing assists understates customs value. CBP can assess extra duties and penalties. Late corrections can delay liquidation.

Don’t mix cost periods. Using mismatched months breaks your tie-out. CBP may reject your figures. Align production, cost, and shipment dates.

Don’t bury packing in materials. Packing belongs to customs value. If you hide it, you risk underpayment. Break it out and document it.

Don’t ignore related-party impacts. If you buy from an affiliate, support the price. Provide market data or computed value. CBP will scrutinize your pricing.

Don’t use unsupported allocations. Vague splits invite questions. Choose a reasonable base and document it. Explain why it fits your operations.

What to Do After Filling Out the Form

Submit the form as instructed. Use the channel indicated by CBP or your broker. Keep a copy and proof of delivery.

Coordinate your entries. Make sure reported values match your cost submission. Update any open entries that rely on provisional figures.

Prepare for questions. Assign a contact who understands the numbers. Respond to CBP requests quickly. Provide clean schedules and short explanations.

Assess duty exposure. Estimate duties based on your submitted values. If duties increase, confirm you have funds or security in place.

Consider reconciliation. If you expect later changes, plan to reconcile. Track the data you will need to finalize the value.

Maintain records. Keep cost sheets, invoices, ledgers, and translations. Keep working papers that show your calculations. Store versions and change logs.

File amendments when needed. If you discover an error, correct it fast. Submit a revised form that highlights changes. Adjust related entries if required.

Update internal controls. Fix root causes, such as weak BOMs or poor currency tracking. Train teams on documentation standards.

Monitor entry outcomes. Watch for CBP notices and final duty calculations. Compare liquidations to your expectations. Escalate discrepancies for review.

Brief leadership. Summarize duty impacts, risks, and next steps. Align on timelines and responsibility for follow-ups.