The ABF Has Queried the Value of Your Goods

If the Australian Border Force has asked you to substantiate the customs value on an import declaration, nothing has gone irretrievably wrong yet. It means the declared value did not match what the ABF expected for those goods, and they want to see how the figure was reached. What you send back, and how quickly, decides whether this ends as a correction or becomes a penalty.

Answer the query. Do not ignore it, and do not simply resubmit the same invoice. A valuation query that goes unanswered does not go away — it escalates.

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Working with licensed customs brokers · All Australian ports · We will tell you if you don’t need us

What a valuation query actually is

Customs value is the figure duty is calculated on, and it is also the base for GST — the value of the taxable importation is the customs value plus transport, insurance and any duty payable. So a wrong customs value produces two wrong numbers, not one.

For most commercial imports the customs value is the transaction value: the price actually paid or payable for the goods, with specific adjustments. A query usually means the ABF is not satisfied that the declared figure is the full price actually paid or payable.

This is a revenue and compliance matter rather than a border hold. Your goods may already have been delivered. That does not close the issue — the ABF can review a declaration long after the container has left the wharf.

Why the ABF queries a customs value

In our experience the same handful of causes come up repeatedly:

• Price-related costs left out. Costs the buyer incurs before the goods leave the place of export generally belong in the customs value — production assists, packing, certain commissions, royalties and licence fees, and inland freight and insurance to the place of export. Leaving these out understates the value.
• The invoice does not reflect what was actually paid. Separate payments, deposits paid outside the invoice, or a supplier issuing a lower-value invoice on request.
• Free-of-charge or replacement goods declared at nil. Goods supplied at no charge still have a customs value; nil is rarely the right answer.
• Related-party pricing. Where buyer and seller are related, the ABF may test whether the relationship influenced the price.
• Declared value out of step with comparable goods. If similar goods from the same origin routinely declare higher, that difference is visible to the ABF.
• Currency, Incoterm or apportionment errors. A FOB price declared as if it were CIF, or freight apportioned incorrectly across a mixed container.

What to do now, in order

1. Read what has actually been asked. A request to substantiate a value is different from a demand for underpaid duty. The wording tells you which one you have.
2. Note the date you must respond by and diarise it. Missing a response date is the most common way a manageable query becomes an infringement.
3. Assemble the commercial record, not just the invoice. The ABF is asking how the price was arrived at, which means the surrounding evidence matters more than the document you already lodged.
4. Reconcile what you actually paid. Match remittances to invoices. If the totals do not agree, find out why before you write back.
5. Get your broker involved before you respond. The importer is legally responsible for the accuracy of the declaration, and an answer given quickly but loosely is difficult to walk back.
6. If you find a genuine error, consider a voluntary disclosure. The ABF actively encourages importers to review their own declarations and correct errors, and says voluntary disclosure minimises disruption and can help avoid administrative penalties. Disclosing before you are pushed is treated differently from being found out.

What the ABF will normally want to see

Expect to be asked for some combination of the following. Having it ready shortens the exchange considerably:

• The commercial invoice and packing list for the consignment
• Proof of payment — telegraphic transfer records, bank statements, or letter of credit documents
• The purchase order and any supply agreement or price list
• Correspondence with the supplier about price, discounts or rebates
• Evidence of any separate payments — tooling, moulds, samples, design work, royalties
• The freight invoice and insurance certificate, showing what sits inside and outside the goods price
• For related parties, an explanation of how the price was set

What it costs to get this wrong

Under the Infringement Notice Scheme, penalties for businesses start upwards from AUD 8,100. Non-payment of duty or taxes is an offence and can lead to financial penalties or legal action, and the ABF can review past declarations rather than only the one in front of them — so a single systematic error can multiply across every shipment that carried it.

Set against that, the cost of answering a query properly the first time is small. That asymmetry is the whole argument for taking it seriously.

How we help

We work with licensed customs brokers and we coordinate the response — pulling the commercial record together, reconciling payments against declared values, identifying whether the shortfall is real, and preparing the answer with the broker who will lodge it.

What we will not do is tell you the outcome in advance or give you legal advice. If the honest answer is that the value was understated, we will say so, and the conversation becomes about voluntary disclosure rather than argument. If you already have a broker handling it competently, we will tell you that too.

Questions importers ask about valuation queries

The supplier put the wrong value on the invoice. Is that my problem?

Yes. The importer is responsible for the accuracy of the declaration regardless of what the supplier issued. A supplier who offers to invoice lower is creating a liability that sits with you, not with them.

Can the ABF review shipments from previous years?

Yes. A valuation query on one declaration frequently leads to questions about earlier ones where the same pattern applies.

Do I have to pay before the query is resolved?

That depends on what has actually been issued. A request for information is not a demand for payment. Read the document, and if it is unclear, ask your broker rather than assuming.

Will answering honestly make things worse?

The ABF publishes its position on this: it encourages importers to review their documents proactively and correct errors, and treats voluntary disclosure as reducing disruption and helping avoid administrative penalties. Silence is the option that reliably makes things worse.

The declaration itself is lodged as part of customs clearance, and most valuation queries trace back to how the goods were classified — our note on tariff classification and HS codes covers how that decision is made. For importers bringing in goods regularly, see commercial imports.

Get help with a valuation query

Send us the query, the declaration and the commercial invoice. We will tell you what the ABF is likely asking for and what your realistic options are.

Planning an import rather than answering a query? Request a freight quote.