The Justice Department filed a civil case on October 7 seeking $67.9 million in unpaid customs duties and $222.5 million in fraud penalties from kitchen and bath importer Uni-Tile & Marble Inc. and its CEO, Xin Mian Pan. Total: roughly $290.4 million.

The government alleges the defendants used shell companies to transship, undervalue, and misdescribe Chinese merchandise across 503 customs entries between September 2018 and August 2023. Products included wooden cabinets and vanities, quartz surfaces, and ceramic tiles.

These are allegations. The Justice Department's announcement states there has been no determination of liability.

Three Risks Sellers Encounter Routinely

The case attaches current numbers to familiar mechanisms: value, country of origin, and product classification. A lower invoice, a third-country shipping route, or a different tariff code all reduce the duty shown at entry. None of that makes the method lawful.

The time span deserves attention. Some alleged entries date to 2018. A shipment clearing customs does not mean the declaration is permanently settled. Entry records, supplier communications, payment evidence, and sourcing documents can surface years later.

The October complaint follows criminal charges announced in December 2025 against Pan, Uni-Tile, and other parties. Those are separate proceedings, and neither constitutes a finding of fraud.

Your Broker Files the Entry. You Own the Risk.

A customs broker classifies products, files entries, and communicates with CBP. The importer of record remains responsible for accurate information and duties owed.

That distinction gets lost when a supplier offers delivered-duty-paid shipping or a forwarder says it will handle customs. Ask which legal entity appears as importer of record, whose bond supports the entry, and what value, origin, and HTS code get declared.

If your team cannot retrieve an entry summary or explain the declared customs value on a recent shipment, you do not have enough control over the process.

The Four Fields Creating Most Exposure

Start with recent and high-duty imports. Pull the commercial invoice, purchase order, payment records, packing list, bill of lading, entry summary, HTS classification, and country-of-origin support for the same shipment.

Then review four areas with your broker or trade counsel:

Customs value. Confirm the declared value follows the applicable valuation method and reconciles with actual payments, assists, royalties, tooling, and related-party arrangements.

Country of origin. Document where the product underwent the processing that legally determines origin. A new box, label, or shipping route does not transform Chinese goods into goods of another country.

Classification. Verify the HTS code matches the product's material, function, construction, and intended use. Keep the reasoning behind any difficult classification.

Importer identity. Confirm the entity named on the entry is eligible, active, and aware of the declaration. CBP's Form 5106 enforcement makes this check more consequential than it was a year ago.

Do not ask a supplier to pick the lowest-duty code without giving them complete product facts. Do not accept two invoices for one transaction. Treat unexplained third-country routing, unusually low declared values, and reluctance to identify the importer as stop signs.

Fix Weak Records Before the Next Shipment

If your review turns up an error, do not improvise a correction. Customs remedies depend on timing, facts, and who made the original statement. Ask a qualified customs lawyer or broker which procedure applies, including whether a post-entry correction, protest, or prior disclosure fits.

Going forward, assign one person to approve customs data before departure. Require your broker to send the completed entry package after clearance and reconcile it against purchase and payment records. Keep written classification and origin decisions in the SKU file.

The lesson from Uni-Tile is not that every importer faces a nine-figure case. It is that small declaration choices accumulate across hundreds of entries, and the government can examine the pattern long after the inventory sold.