Question 1

What is a CF-28 Request for Information and how should I respond?

Accepted Answer

A CF-28 (CBP Form 28) is a Request for Information from U.S. Customs and Border Protection seeking clarification about your import entry. CBP typically requests documentation or explanations regarding classification, valuation, country of origin, or other entry data. Response is required within 30 days (extendable upon request). Strategic response is critical because inadequate answers can result in CF-29 issuance, rate advances, or audit escalation. Our CF-28 response attorneys analyze the request, gather supporting documentation, and prepare strategic written responses that prevent enforcement escalation.

Question 2

What is a CF-29 Notice of Action and what are my options?

Accepted Answer

A CF-29 (CBP Form 29) is a Notice of Action informing importers that CBP has taken or proposes to take action affecting their entries, typically a rate advance increasing duties owed. Options include accepting the determination, filing a protest under 19 USC 1514 within 180 days of liquidation, or requesting administrative review. Our CF-29 defense lawyers evaluate each determination, assess protest viability, gather supporting evidence, and aggressively defend against improper duty increases.

Question 3

Why did I receive a CF-29 Notice of Action?

Accepted Answer

You received a CF-29 because CBP has determined that action is needed on your import entry. Common reasons include: (1) classification errors where CBP believes your goods should be classified under a different HTS code with higher duties, (2) valuation discrepancies where CBP determined the declared value was incorrect requiring additional duties, (3) preference claim denials where CBP rejected your USMCA, CAFTA-DR, or other FTA preference claim, (4) country of origin changes affecting duty rates or trade remedy applicability, (5) incomplete or unsatisfactory CF-28 responses that failed to resolve CBP's questions, or (6) audit findings from Focused Assessments or Quick Response Audits identifying compliance issues. Our attorneys analyze the specific reasons stated in your CF-29 and develop targeted defense strategies to challenge improper determinations.

Question 4

What is the deadline to respond to a CF-28?

Accepted Answer

CF-28 responses are typically due within 30 days of the notice date. Extensions can be requested by contacting the CBP import specialist listed on the form before the deadline expires. Our CF-28 response attorneys recommend engaging counsel immediately upon receipt to maximize preparation time. Failure to respond can result in CBP making adverse determinations based on available information, potentially leading to CF-29 notices and duty increases.

Question 5

Can a CF-28 lead to a CBP audit?

Accepted Answer

Yes, CF-28 responses are sometimes used by CBP to identify potential compliance issues that warrant further examination. Patterns of classification errors, valuation discrepancies, or origin concerns revealed through CF-28 responses can trigger Quick Response Audits (QRAs) or Focused Assessments. A Quick Response Audit is a single-issue CBP audit focusing on one compliance area such as classification, valuation, or origin—often initiated based on CF-28 findings. Focused Assessments are more comprehensive audits examining multiple compliance areas across your import operations. Our customs attorneys prepare CF-28 responses that address CBP questions while minimizing information that could expand scrutiny into Quick Response Audits or Focused Assessments. We also evaluate whether prior disclosure is appropriate if responses reveal systematic violations.

Question 6

What documentation should I include with a CF-28 response?

Accepted Answer

Documentation depends on what CBP is questioning. Classification questions require product specifications, technical documentation, and HTS analysis. Valuation questions require commercial invoices, contracts, and related party transaction documentation. Origin questions require manufacturing records, supplier certifications, and bills of material. Our CF-28 response attorneys identify exactly what documentation supports your position while avoiding production of materials that could raise additional questions.

Question 7

How do I protest a CF-29 Notice of Action?

Accepted Answer

Protests against CF-29 determinations are filed under 19 USC 1514 within 180 days of liquidation. The protest must identify the entry, specify the decision being challenged, provide legal grounds for disagreement, and include supporting evidence. Our CF-29 defense lawyers prepare comprehensive protest packages including technical analyses, binding ruling citations, and documentary evidence. We track protest status and pursue further review or litigation when CBP denies protests.

Question 8

What is a rate advance in a CF-29?

Accepted Answer

A rate advance occurs when CBP determines that goods should be classified under a different HTS subheading with a higher duty rate than originally declared. The CF-29 notifies the importer of the proposed classification change and increased duty amount. Our CF-29 rate advance defense attorneys challenge improper classifications by demonstrating that the original classification was correct, providing technical evidence of product characteristics, and citing binding rulings or court decisions supporting our position.

Question 9

Should I hire an attorney for a CF-28 response?

Accepted Answer

While importers can respond to CF-28s directly, professional representation significantly improves outcomes. CF-28 responses establish the factual record that CBP uses for enforcement decisions. Poorly prepared responses can create admissions, trigger escalation, or miss opportunities to prevent adverse determinations. Our CF-28 response attorneys understand CBP examination priorities, prepare strategically focused responses, and prevent common mistakes that lead to CF-29 issuance or audit selection.

Question 10

What happens if I ignore a CF-28 or miss the deadline?

Accepted Answer

Ignoring a CF-28 or missing the deadline allows CBP to make determinations based on available information without your input. This typically results in CF-29 notices proposing rate advances, duty increases, or other adverse actions. Once a CF-29 issues, your options become more limited and costly. Our urgent CF-28 response services include deadline extension requests and expedited response preparation when time is short.

Question 11

How much does CF-28/CF-29 legal representation cost?

Accepted Answer

Costs vary based on the complexity of the issue, number of entries affected, and documentation requirements. Simple CF-28 responses may require limited engagement, while complex valuation or classification disputes involving multiple entries require more extensive representation. We provide transparent fee estimates after reviewing the notice and discussing your situation. The investment in professional representation typically saves significant money compared to unchallenged duty increases and potential penalties.

Question 12

Can a CF-29 lead to penalties under Section 1592?

Accepted Answer

Yes, if CBP determines that the original entry contained material false statements or omissions, Section 1592 penalties can apply in addition to duty adjustments. Penalties range from loss of revenue (negligence) to 4x domestic value (fraud). Our CF-29 defense includes penalty exposure assessment and, when appropriate, prior disclosure submissions to limit penalty exposure. We also defend against penalty assessments by demonstrating reasonable care and mitigating circumstances.

CF-28 & CF-29 Notices: Requests for Information & Notices of Action

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