Cervo AI

If you work in customs brokerage long enough, CF-28s and CF-29s become a fact of life. U.S. Customs and Border Protection (CBP) issues thousands of these forms each year, and how you respond can mean the difference between a routine resolution and a costly dispute. This guide covers what each form means, why you received one, how to respond effectively, and how to reduce their frequency going forward.

What Is a CF-28 (Request for Information)?

CBP Form 28, commonly called a CF-28, is a formal Request for Information about a specific customs entry. When CBP issues a CF-28, they are asking you to provide additional documentation or clarification before they make a decision about the entry.

CF-28s typically focus on three areas:

Value: CBP questions the declared transaction value, often because the price seems unusually low for the commodity or origin country.
Classification: The you filed does not appear to match the product description, or CBP needs more detail to confirm accuracy.
Country of origin: CBP needs evidence to confirm where the goods were manufactured or substantially transformed, especially for products subject to antidumping/countervailing duties or trade remedy tariffs.

A CF-28 is not an accusation. It is a request. But ignoring one, or responding poorly, can quickly escalate to enforcement action.

What Is a CF-29 (Notice of Action)?

CBP Form 29, or CF-29, is a Notice of Action. Unlike the CF-28, which asks questions, the CF-29 tells you that CBP intends to change something about your entry. This is a proposed action, and it carries real financial consequences.

Common CF-29 actions include:

HTS reclassification: CBP has determined the goods belong under a different tariff subheading, often one with a higher duty rate.
Value adjustments: The declared value is being increased or recalculated, resulting in additional duties owed.
Marking violations: The imported goods do not meet country-of-origin marking requirements under 19 CFR Part 134.
Quota or visa issues: The entry involves merchandise subject to quota restrictions or textile visa requirements, and documentation is insufficient.

A CF-29 frequently follows a CF-28 when CBP is unsatisfied with the response, but it can also be issued independently based on CBP's own review.

Common Reasons for Receiving CF-28s and CF-29s

Why You Got a CF-28

Unusual valuations: A declared value that falls significantly below the CBP-expected range for the product and origin country.
Questionable classifications: An HTS code that does not clearly align with the product description, or one that carries a suspiciously low duty rate.
Missing documentation: Incomplete commercial invoices, absent packing lists, or missing certificates of origin.
Random selection: CBP uses risk-based targeting but also conducts random reviews. Sometimes there is no red flag - your entry was simply selected.

Why You Got a CF-29

HTS reclassification after review: CBP's import specialists determined a different classification applies, often following an inadequate CF-28 response.
Value adjustments based on analysis: CBP applied deductive or computed value methods when transaction value was not accepted.
Marking violations identified on exam: Physical inspection revealed missing or incorrect country-of-origin markings.
Quota or visa discrepancies: Textile or steel entries that exceed quota limits or lack proper visa documentation.

Timeline Requirements: Do Not Miss These Deadlines

CF-28 deadline: You have 30 days from the date of issuance to respond. If you do not respond, CBP may take action based on available information alone - and that rarely works in the importer's favor.

CF-29 deadline: You have 20 days from the date of issuance to respond. The shorter window reflects the fact that CBP has already made a preliminary determination and is moving toward liquidation.

Both deadlines are measured from the date printed on the form, not the date you received it. Build in buffer time when tracking these internally, and flag them in your workflow management system the moment they arrive.

How to Respond to a CF-28

A strong CF-28 response is thorough, well-organized, and directly addresses CBP's questions. Here is a practical framework:

Gather supporting documentation. Pull together commercial invoices, purchase orders, bills of lading, certificates of origin, product spec sheets, and any other documents that support your entry. If value is questioned, include evidence of arm's-length transactions.
Provide clear, direct explanations. Address each question CBP raised. Do not leave anything unanswered. If CBP asked about classification, explain the product's function, material composition, and intended use in plain language.
Include ruling references. If there are existing CBP Headquarters or New York rulings that support your position, cite them. Cross-rulings and court decisions (CIT, CAFC) strengthen your argument considerably.
Be thorough but concise. Provide everything CBP needs to make a decision, but do not bury the import specialist in irrelevant material. Organize your response with a cover letter summarizing the key points.

When your original 7501 entry data is accurate and well-documented, assembling a CF-28 response is significantly faster because the supporting information already exists in your files.

How to Respond to a CF-29

When you receive a CF-29, you have three options:

Accept the proposed action. If CBP's determination is correct, the simplest path is to accept it. The entry will be reliquidated accordingly, and any additional duties will be assessed.
Provide additional information. If you have evidence that was not previously submitted, respond within the 20-day window with supporting documentation. This is your last chance to change CBP's mind before liquidation.
File a protest (CBP Form 19). If you disagree with the action and the entry has been liquidated, you can file a formal protest within 180 days of liquidation. Protests trigger a formal review and, if denied, can be escalated to the Court of International Trade.

The protest route is time-consuming and expensive. In most cases, the best strategy is to provide compelling information during the 20-day CF-29 response window rather than waiting to protest after liquidation.

Best Practices for Reducing CF-28 and CF-29 Frequency

The most effective way to handle CF-28s and CF-29s is to receive fewer of them. Here is what consistently works:

Accurate classification from the start. Use the General Rules of Interpretation (GRI) systematically. Do not default to "close enough" HTS codes. Understanding can help you validate your decisions before filing.
Proper valuation methodology. Document your valuation method for every entry. When using transaction value, ensure you can demonstrate arm's-length pricing with purchase orders, payment records, and contracts.
Complete documentation on every entry. Attach all required documents at the time of filing. Missing a packing list or certificate of origin is one of the easiest triggers for a CF-28.
Consistent filing patterns. CBP's targeting algorithms flag anomalies. If you suddenly file the same product under a different HTS code or at a materially different value, expect scrutiny.
Pre-entry review processes. Implement a quality check before submission. A second set of eyes on classification, value, and documentation catches errors that would otherwise invite CBP attention.

The Connection Between Data Quality and CF-28 Volume

There is a direct relationship between the quality of your initial entry data and how often CBP sends you information requests. Entries filed with incomplete descriptions, inconsistent values, or mismatched HTS codes are far more likely to be flagged by CBP's Automated Targeting System.

The math is straightforward: better data at the point of entry means fewer CF-28s to respond to, fewer CF-29s to fight, and fewer protests to file. Every hour spent improving entry accuracy on the front end saves multiple hours of compliance work on the back end.

This is where the gap between high-performing brokerage operations and struggling ones becomes most visible. Brokers who invest in data quality - through better processes, better training, or better technology - spend less time reacting to CBP inquiries and more time processing new business.

How Technology Reduces CF-28 and CF-29 Frequency

Modern customs entry automation platforms address the root causes of CF-28s and CF-29s by improving entry accuracy at the point of filing. AI-powered tools bring specific capabilities that directly reduce CBP scrutiny:

Confidence scores on classification: Instead of a single HTS code suggestion, AI systems provide confidence-scored recommendations that flag uncertain classifications for human review before filing - not after a CF-28 arrives.
Automated compliance checks: Pre-submission validation catches missing documentation, inconsistent values, and flagged country-of-origin combinations before the entry reaches CBP.
Consistent data extraction: AI extracts invoice data, quantities, and values uniformly across entries, eliminating the manual keying errors that create anomalies in CBP's targeting system.
Historical pattern matching: Parts libraries and entry history databases ensure that the same product is classified and valued consistently across entries, reducing the filing inconsistencies that trigger reviews.

The goal is not to eliminate human judgment from the process. It is to ensure that human expertise is applied where it matters most - on genuinely complex classification decisions and trade compliance strategy - rather than on preventable data quality issues.

Reduce CF-28s with Better Entry Data

Fewer CF-28s and CF-29s start with more accurate entries. Cervo AI helps customs brokers file with confidence by automating document extraction, validating classifications with confidence scores, and running compliance checks before submission.

Learn how AI-powered customs entries reduce CF-28 frequency →

CF-28 and CF-29 Response Guide: What Every Customs Broker Needs to Know