A CBP Form 28 arrives with a 30-day clock already running, and nothing about the letter tells you that. It’s a one-page request, usually a handful of questions about an entry you filed weeks or months ago, and it rarely explains what happens if those questions go unanswered. For a small business importer running apparel, cosmetics, food, or electronics through a handful of ports, that ambiguity is the actual risk not the form itself.
What a CBP Form 28 Actually Is
Customs and Border Protection issues Form 28, titled “Request for Information,” when the paperwork on file for an entry doesn’t fully support the classification, value, or origin declared at the time of import. The authority for this sits in 19 CFR 151.11: CBP is responsible for appraising and classifying merchandise, and when the invoice or supporting documents don’t provide enough detail to do that with confidence, the officer asks for more.
The form itself is explicit that it isn’t a penalty notice and isn’t evidence of a formal investigation. CBP has been directed not to use it that way. It’s a fact-finding step that happens after your goods have entered the country but before the entry liquidates the point at which CBP’s determination on duty owed becomes final.
Why You Got One
Most CF-28s fall into a few recurring categories, and the questions on the form usually make clear which one you’re dealing with.
Valuation questions: The declared value doesn’t match what CBP would expect for the merchandise, the invoice is missing line-item detail, or there’s a related-party transaction that needs a transfer pricing explanation.
Classification questions: The Harmonized Tariff Schedule code doesn’t obviously match the product description, or the description itself is too vague for CBP to confirm the code without more detail material composition on an apparel shipment, for instance, or the specific function of an electronic component.
Country of origin questions: CBP wants documentation supporting where the goods were actually made or substantially transformed, which matters for duty rates, trade agreement eligibility, and any applicable Section 301 exposure.
Admissibility questions: For food, cosmetics, and certain consumer goods, CBP may be checking whether FDA or another agency’s requirements were met before the goods can clear.
Trade preference and duty program questions: If the entry claimed a reduced or zero duty rate under a trade agreement or special program, CBP will sometimes ask for the underlying qualification records regional value content calculations, sourcing records for materials, or the specific certification that supported the claim. This category shows up most often on apparel and electronics entries where components come from more than one country.
The 30-Day Clock
The form itself states it plainly: if you can’t reply within 30 days of the request date, you need to contact the officer before that deadline to discuss an extension or the specific questions. That’s the entire mechanism. There’s no grace period built in, and CBP has no obligation to follow up before the window closes.
Missing the deadline doesn’t trigger an automatic penalty. What it does is remove your best opportunity to resolve the officer’s question with documentation, before CBP has to make a decision based on what’s already in the file. If that decision goes against you, the next document you’ll likely see is a CBP Form 29, Notice of Action, which proposes or finalizes a change to classification, value, or duty owed. A pattern of unresolved CF-28s across multiple entries, or a CF-28 that surfaces a bigger compliance gap, is also how CBP builds the record for a penalty case under 19 U.S.C. 1592, which covers negligence, gross negligence, and fraud in customs declarations.
None of that is inevitable. It’s what happens when the form sits in an inbox, or when the reply is partial, defensive, or inconsistent with what’s already on file.
Building a Response CBP Won’t Send Back
The questions on a CF-28 point directly at the documents that answer them. Matching the response to the actual question, rather than sending everything you have, is what makes the difference between a closed inquiry and a follow-up request.
What CBP is asking about, and what typically resolves it:
- Valuation → commercial invoice with full line-item detail, purchase order, proof of payment, any assist or royalty agreements
- Classification → product specification sheets, material composition breakdowns, manufacturer’s technical data, prior binding ruling if one exists
- Country of origin → manufacturer’s affidavit, bill of materials showing where transformation occurred, production records, certificates of origin where applicable
- Admissibility → FDA prior notice confirmation, lab or testing reports, product registration records, labeling documentation
A few habits matter more than any single document. Answer every question on the form, in order, rather than attaching a bundle of files and letting the officer sort through them. Keep the language in your response consistent with what’s already on the entry summary a CF-28 reply that contradicts the original filing raises more questions than it answers. And if the deadline is tight because documents are coming from an overseas supplier, ask for the extension in writing before the 30 days runs out, not after.
The cover response itself should read like a direct answer, not a narrative. Reference the entry number, port of entry, and the date on the form at the top, then work through the officer’s questions one at a time using the same numbering they used. Attach the supporting documents as separate, labeled files rather than one merged PDF an officer working through a stack of open CF-28s is far more likely to close yours quickly if they can find the invoice, the affidavit, and the spec sheet without opening forty pages to locate each one. Skip the explanation of why the original filing was correct unless a question specifically asks for it; the documents should carry that weight, not the prose around them.
Where This Goes Wrong
One recurring pattern involves apparel importers who get a country-of-origin CF-28 and respond with a general statement about their supplier relationship instead of the specific manufacturing paperwork CBP asked for. The officer can’t verify a claim that isn’t backed by a document, so the file sits open, the deadline passes, and the entry liquidates with CBP’s own determination standing instead of the importer’s. From there, the same documentation gap tends to surface again on the next shipment from that supplier, because nothing about the underlying paperwork changed.
The fix isn’t complicated, but it has to happen before the CF-28 arrives, not after. Supplier-level documentation manufacturing affidavits, bills of materials, testing records needs to exist and be retrievable before an entry ships, not assembled under a 30-day deadline once CBP asks. Importers who get flagged repeatedly are almost always importers whose compliance documentation lives in someone else’s inbox.
A second, quieter pattern shows up on electronics entries: a CF-28 asking about classification arrives, the importer’s response focuses on the product’s marketing description rather than its technical function, and the officer comes back with a follow-up because the two don’t answer the same question. A component’s tariff classification usually turns on what it does mechanically or electrically, not what it’s called on the packaging. Pulling the manufacturer’s technical data sheet before drafting a reply, rather than relying on internal product descriptions, avoids that round trip entirely.
When to Bring in Your Broker or Trade Counsel
A straightforward valuation question with a clean paper trail is usually something your customs broker can close out directly. Where it’s worth escalating: any CF-28 touching country of origin where trade agreement eligibility or Section 301 duty is at stake, any request that references multiple prior entries rather than a single shipment, or any reply where you’re not fully confident the documentation actually supports the original declaration. That last case is the one importers most often get wrong by handling it themselves the instinct is to explain the discrepancy rather than correct the record, and CBP reads those very differently.
If CBP has already flagged a shipment and it’s sitting at the port while the CF-28 gets sorted out, the hold itself has its own timeline and release conditions worth understanding separately (see our CBP shipment hold guide).
Cost is usually the reason importers hesitate to bring in outside help on what looks like a simple documentation request. In practice, the time spent assembling the wrong response, missing the deadline, and then working through a Notice of Action almost always costs more than a broker’s fee to review the reply before it’s filed. A ten-minute conversation with someone who reads CF-28s regularly can catch a missing document or a phrasing problem before it becomes CBP’s next question, rather than after.
What Happens After You Respond
A complete, well-documented reply usually closes the inquiry without further action, and the entry proceeds toward liquidation on the original terms. If CBP isn’t satisfied, the next step is the Notice of Action, which gives you a further window to respond before any duty change becomes final. Either way, the response you filed for the CF-28 becomes part of the permanent entry record, which is exactly why accuracy at this stage matters more than speed.
There’s also a longer-term effect worth planning around. CBP tracks compliance history at the importer level, not just per entry, and a documentation gap that generates one CF-28 tends to generate another on the next shipment with the same characteristics — same supplier, same product line, same classification. Treating a CF-28 as a one-time fire drill misses that pattern. Treating it as a signal to fix the underlying paperwork before the next shipment leaves the factory is what actually stops the follow-up requests. A bond adequate to the entries you’re running also matters here, since duty advances following a Notice of Action draw against it (see our customs bond calculation guide for how that figure gets set).
Frequently Asked Questions
What happens if I ignore a CBP Form 28?
CBP proceeds to a determination based on the file as it stands, without your documentation. That often means a Notice of Action proposing a higher duty rate or a different classification, and repeated non-response across entries is a pattern CBP tracks.
How long do I have to respond to a CBP Form 28?
The form specifies 30 days from the date of the request. If you can’t meet that deadline, the form itself instructs you to contact the issuing officer before it passes.
Can I request an extension?
Yes. Extensions are routinely granted when requested before the deadline, particularly when the delay is due to documents coming from an overseas manufacturer or supplier.
Does receiving a CF-28 mean I’m under investigation?
No. CBP has specifically directed that the form not be used as notice of a formal investigation. It’s a documentation request tied to a specific entry, issued before that entry liquidates.
What’s the difference between a CBP Form 28 and a CBP Form 29?
The Form 28 asks for information. The Form 29, Notice of Action, is issued after CBP has reviewed what it has including your CF-28 response, if you filed one and proposes or finalizes a change to classification, value, or duty.
Can a CBP Form 28 lead to a penalty?
Not directly, but the documentation gaps a CF-28 exposes are the same gaps CBP relies on when building a penalty case under 19 U.S.C. 1592. A thorough response is also a chance to correct the record before that becomes relevant.
Should my customs broker handle the response for me?
Your broker can prepare and file most CF-28 responses. You remain the importer of record either way, which means the accuracy of what gets submitted is ultimately your responsibility, not just your broker’s.
If a CF-28 has landed on an entry and the deadline is already close, book a free consultation call with AIT TAHIPO LLC. We handle customs clearance and entry compliance work directly, including CF-28 and CF-29 responses, for importers running shipments through Los Angeles and other major U.S. ports.rts.
