ATA Carnet for Robotics brought to you by RobotLife

Something went wrong in the US. Now what?

US carnet problems are fixable, but the machinery is deadline-driven and most of the clocks start at the carnet's expiry date. Two rules apply to every scenario: act before the carnet expires where you still can, and tell your issuer early. It guarantees your carnet and has handled all of this before.

"I left the US without the exit stamp"

Nothing happens at the moment you leave. The trouble arrives months later, as a claim (next section). So close the gap before it becomes one:

  1. Get the next country's import stamp, or your home re-import stamp, while the carnet is still valid. US regulations (19 CFR 10.39) accept another country's import or re-import particulars as proof the goods left.
  2. If a US claim still arises, USCIB charges a $50 regularization fee when you have carnet-based proof (a third-country stamp or home re-import before expiry), or $100 when all you have is non-carnet foreign proof like a landing certificate, waybill or bill of lading.
  3. Don't treat this as a guaranteed escape hatch. USCIB itself says acceptance of non-carnet proof is not guaranteed. It usually works, it costs a fee, and it sits at customs' discretion.

The prevention side (finding the CBP officer yourself, stamping where you check the goods in) is covered in using your carnet in the US.

"A claim letter arrived"

Here's the mechanism, straight from the regulations (19 CFR 10.39): if CBP hasn't received proof of re-export or destruction within 30 days after the carnet expires, the port director sends a written demand for liquidated damages of 110% of the estimated duties to both the holder and USCIB. USCIB then has 6 months from the claim to furnish proof. If you end up paying and proof lands within 3 months of payment, the money comes back. And no claim can be made against the guaranteeing association more than 1 year after expiry.

Your job is evidence. In descending order of strength:

  1. The re-export counterfoil stamped by the claiming country (here: the US).
  2. A US-validated re-import or export voucher.
  3. A third-country counterfoil showing the goods arrived somewhere else.
  4. Non-carnet proof: a CBP-validated Certificate of Disposition (CBP Form 3227), foreign duty-paid receipts, US re-import entries. USCIB does not guarantee these will be accepted.

Two cost layers stack on top of any settlement. First, USCIB's claims-handling fees: from $50 for claims up to $150, rising in steps to 5% (capped at $4,000) for claims over $10,000. Second, if the goods were re-exported late but you can prove it, USCIB and Roanoke describe a mitigation scale: roughly 25% of the duty plus a 10% penalty when the re-export was validated within about 90 days after expiry, roughly 50% plus 10% within about 180 days, and full duty plus 10% beyond that. Treat those bands as USCIB's description, not a CBP promise: the exact day boundaries differ between sources, and the scale is applied at claim stage, not at the exit desk.

"The goods must stay longer than the carnet allows"

Forget extensions. A carnet's 12 months are fixed (19 CFR 114.23: the validity "cannot be extended"), and the US also does not accept replacement carnets, the fresh-document trick that works in some other countries. You may read elsewhere that US carnets can be extended a year; that's wrong, the regulations say otherwise.

The one sanctioned route is converting to a Temporary Importation under Bond (TIB), before the carnet expires, through a licensed customs broker:

  1. The broker files the TIB entry with the carnet number on the TIB paperwork.
  2. The description, weight and value must match the carnet's General List.
  3. CBP validates your re-export voucher referencing the TIB, which closes the carnet cleanly.

How long does the TIB buy you? Roughly one further year, possibly more. CBP's directive and the regulations phrase the extension limits differently, so treat the exact ceiling as a question for your broker.

"The customer wants to keep the robot"

Say a mobile-robotics startup demos an inspection robot at a US plant and the customer wants to buy it on the spot. Do not just file a normal import ("consumption") entry: that does not discharge the carnet, and you can end up paying duties twice when a claim lands anyway.

The sanctioned route, while the carnet is still valid, is an anticipatory breach through the CBP Entry Team at the port where you imported:

  1. Send a letter on the holder's letterhead itemizing the goods staying behind, with the carnet cover, the General List and the validated import counterfoil.
  2. The Entry Team assigns a case number and tells you what to pay.
  3. The payment receipt discharges those items from the carnet. Keep it with the carnet forever.

"I lost the carnet"

  1. Ask your original issuer for a duplicate. It must carry the same expiry date and the same General List as the original; if it does, CBP is required to accept it (19 CFR 114.25). Fees apply.
  2. At the end of the trip, both documents (duplicate, and the original if it turns up) go back to the issuer.

Prevention is embarrassingly cheap: a dedicated folder and photos of every page after every stamp.

"The carnet expired while the goods are still in the US"

Expect the claims machinery above to start: a liquidated-damages demand for 110% of estimated duties. Still take the goods to CBP on the way out. An expired carnet is still processed at exit; the officer annotates it to record that the goods left, which is exactly the evidence that feeds the mitigation scale.

One reassuring asymmetry: direction matters. A US-issued carnet that expires while the goods are abroad draws no US penalties or duties, and the goods can still come home on it. The expiry date only limits entry into foreign countries (whose own claims remain possible). More edge cases in the US FAQ.

Sources

Every factual claim on this page comes from the sources below, checked on the "last reviewed" date in the footer. Official resources are linked in whatever language they are published in.