CF-28 and CF-29: how to audit yourself before CBP asks

What is a CF-28, and what is a CF-29?

They are the two forms CBP uses to question an entry summary after it has been filed.

The CF-28, Request for Information, asks you for documents, answers or samples about one entry. The form cites 19 CFR 151.11 as its authority and states that your reply is required under 19 U.S.C. 1509. CBP's own instructions on the form say what it is for: the information is "necessary for proper classification and/or appraisement" of your merchandise or for import compliance. It names the entry number, the HTS number, the invoice and the CBP officer who sent it.

The CF-29, Notice of Action, tells you CBP intends to change something on the entry, or already has. CBP's ACE entry summary business rules (version 11.0, section 1.12) say a CF-29 may change the classification or value on the entry summary and "may result in a rate advance of duty", and that the Center of Excellence and Expertise explains on the form why it acted.

A CF-29 often follows a CF-28, but the two forms answer different questions. The CF-28 asks "show us". The CF-29 says "here is what we are changing".

How long do you have to respond?

The windows are short and they run per entry. Here is what each notice means and where the clock comes from.

Two details people miss. First, the 30 days on a CF-28 run from the date the form was issued, not the date someone at your company opened it. CBP's business rules send the form to the importer, with a courtesy copy to the broker, so agree in advance who watches for it and who answers. Second, the Form 28 instructions tell you to contact the named officer if you cannot reply within 30 days "or if you wish to discuss any of the questions". Ask early: for written demands for entry records, 19 CFR 163.6(a) requires an extension request to reach CBP before the due date, and the same habit serves you on a CF-28.

What does CBP ask for on a CF-28?

The form itself lists the standard questions, and they map neatly to the valuation and classification rules.

Questions you answer:

• Are you related to the seller, and if so how does the relationship affect the price?
• What additional costs were incurred: packing, commissions, proceeds that accrue to the seller, assists, royalties or license fees?

Items you furnish:

• The contract, or purchase order and seller's confirmation, with any revisions.
• Literature explaining what the product is, how it is used and how it works.
• A breakdown of components, materials or ingredients by weight, with their actual cost at assembly.
• Samples.

CBP's business rules add the documents a reviewer may ask for: cost submissions, header and line-level spreadsheets, commercial invoices, packing lists, bills of lading, purchase orders, contracts, manufacturer's affidavits, inventory records, documents supporting the apportionment of assists and free trade agreement certificates of origin.

Each request tests a specific field on your entry. The related-party and additional-cost questions test entered value against the additions in 19 CFR 152.103(b). The component breakdown tests classification and, on metal lines, the content reported for Section 232. CBP reminded filers on October 17, 2025 (TIN #66531250) that steel and aluminum content and quantities must be reported accurately, and that failure "may result in enforcement actions, including documentation reviews". Certificates of origin test any preference you claimed.

Why audit yourself before CBP asks?

Because your options narrow the moment CBP starts looking, and because the law already expects you to check.

Reasonable care is your duty, not the broker's. CBP's Reasonable Care publication explains that under 19 U.S.C. 1484 the importer of record is responsible for using reasonable care to enter, classify and value merchandise. One of the publication's own checklist questions asks whether you have a reliable system to receive copies of what was submitted to CBP, review them for accuracy and tell CBP promptly about needed corrections. A periodic review of your filed entries is the plainest answer to that question.

The cheap correction closes once CBP is reviewing. CBP's business rules list the conditions for filing a post-summary correction, and one is that the entry summary "cannot be under a CBP review". Before a CF-28, a wrong line on an unliquidated entry can be corrected by your broker in a routine filing. After it, that entry goes through CBP's process.

Prior disclosure only works before you know of a formal investigation. Under 19 CFR 162.74, the reduced penalties apply when you disclose "before, or without knowledge of, the commencement of a formal investigation". Section 162.74(i) lists events that create a presumption you knew, such as a special agent asking about the violation or CBP issuing a prepenalty notice.

CBP itself recommends it. In its Prior Disclosure publication, CBP answers the question of what to do when Regulatory Audit has announced a visit in two months: use that time for a self-assessment, because violations found and fully disclosed before the audit team arrives may still get prior disclosure benefits.

Self-audits also find money going the other way. Overpaid lines on unliquidated entries can be corrected, and liquidated entries can be protested within 180 days. The routes are compared in how to recover overpaid import duty.

How do you audit the same fields CBP checks?

Work from your own entry data, and check every line, not a sample. A CF-28 is about one entry, but the error it finds is usually in every entry of the same product.

1. Pull the population. Get every entry summary line for the period from your broker's entry export: entry number, entry date, line number, HTS number, Chapter 99 numbers, country of origin, entered value, quantity and duty by line. Cover at least the entries still inside the five-year retention window in 19 CFR 163.4.
2. Pair each entry line with its invoice line. Match the commercial invoice and packing list to each line. An entry line you cannot pair to a document is itself a finding, because a CF-28 will ask for that document. Reconciling broker entry exports with invoices and your ERP covers where the numbers drift.
3. Check classification against the product. Read the invoice description and your product records against the HTS heading on the line. Note any binding ruling you rely on and whether the line follows it.
4. Check the duty stack on the entry date. Confirm the base rate and every Chapter 99 line that applied on that date: Section 232, Section 301 (including the forced-labor headings for goods entered from July 24, 2026), IEEPA and any Section 122 line, with the right order and the right exclusions. You can check a single line with the duty calculator; why your entry shows the wrong duty stack walks through the common errors.
5. Answer the CF-28 value questions per supplier. For each supplier, write down whether you are related, and whether you pay packing, commissions, assists, royalties or license fees that are not in the invoice price. These are the five additions in 19 CFR 152.103(b).
6. Check quantities and units. Compare the entry quantity with the invoice and packing list, in the unit the HTS number requires.
7. Check origin and preference claims. For every line that claimed a trade-agreement rate, confirm you hold the certificate or the origin support today, not only that the broker had it at entry.
8. Check metal content and melt and pour reporting. On Section 232 lines, confirm the metal quantity, the content value for derivatives entered before April 6, 2026 (after that date the duty is on the full value), and the country of melt and pour or smelt and cast against the supplier's mill certificates.
9. Record a result for every line. Correct, overpaid, underpaid or unsupported (right answer, missing document). Keep the evidence next to the result, so a CF-28 answer is a copy of work already done.

TariffSense does this on a whole period at once: it reads Form 7501 lines and the invoices and packing lists behind them in whatever format your broker sends, checks each line against the measures in force on its entry date, and returns a finding per line with the reason and the corrected value. See post-entry audit.

How should you answer a CF-28 that has already arrived?

1. Calendar the deadline from the issue date. Thirty days from issuance, per CBP's business rules. If you need longer, contact the officer named on the form now.
2. Read exactly what is asked. The Form 28 instructions say everything you send must relate to the shipment described on the front of the form. Answer the indicated questions and furnish the indicated items.
3. Run the self-audit steps on that entry first. Check classification, stack, value, quantity and origin on the questioned line before drafting anything, so you know whether the answer helps or hurts.
4. Check the same product on your other entries. If the questioned line is wrong, the same error is probably on other entries. Those other entries are where prior disclosure can still matter, and you decide the scope of a disclosure.
5. Have the right person sign. The form requires a company official to certify the reply as true and correct, unless a foreign firm completes it.
6. Send it the way CBP asked and copy your broker. CBP's business rules say the reply goes through the ACE Portal or the Document Imaging System where applicable. Keep the full reply and its attachments with the entry file.

What happens when a CF-29 arrives?

Read the box that says whether the action is proposed or taken.

If it is proposed, you have 20 days under CBP's business rules to respond. Use them to send the evidence for your position: the ruling you relied on, the cost breakdown, the mill certificate, the origin record. If CBP's proposal is right, a response that says so and explains what you have fixed on other entries is still worth sending.

If it is taken, CBP has changed the entry. Once the entry liquidates, the business rules say the trade "will have to protest CBP's decision". Under 19 CFR 174.12(e) a protest is due within 180 days of the liquidation decision for entries made on or after December 18, 2004. How long do you have to fix a past entry? explains how those dates run per entry.

Either way, a CF-29 is a finding about a product, not just an entry. Check every other entry of that product, in both directions.

What if your self-audit finds an underpayment?

Correct it, and decide with counsel whether to make a prior disclosure. Underpayment is a finding you act on, not one you sit on.

On unliquidated entries, your broker can usually file a post-summary correction. CBP's business rules say that a filer who amends entries this way remains "subject to the usual penalties" for any violation, so a correction on its own does not settle the penalty question.

A prior disclosure under 19 CFR 162.74 has four parts. It identifies the class or kind of merchandise; identifies the entries by number, or by port and approximate dates; explains the false statements or omissions and how and when they happened; and sets out the correct information, with any unknown data to follow within 30 days. You tender the actual loss of duties either with the disclosure or within 30 days after CBP sends its calculation.

What it changes. Without a disclosure, 19 U.S.C. 1592(c)(3) caps a negligent violation at the lesser of the domestic value of the merchandise or two times the lost duties, taxes and fees; gross negligence is capped at four times. With a valid disclosure of a negligent or grossly negligent violation, section 1592(c)(4)(B) limits the penalty to "the interest (computed from the date of liquidation at the prevailing rate of interest applied under section 6621 of title 26)" on the lost duties, provided you tender them. CBP's Prior Disclosure publication adds that the penalty amount is zero where the entries are unliquidated and no fraud is involved.

A worked illustration. Say your self-audit finds that a missed Chapter 99 line left $40,000 of duty unpaid across twelve entries: $30,000 on eight liquidated entries and $10,000 on four unliquidated ones. Without a disclosure, the statutory ceiling for negligence is two times the loss, up to $80,000 in penalties (or the domestic value of the goods, if lower) on top of the duty. With a valid prior disclosure, you tender the $40,000; the penalty is interest on the $30,000 from each liquidation date to the tender date, and zero on the unliquidated entries. These are statutory ceilings, not predictions of what CBP would assess, and the numbers are illustrative.

Scope. You decide what the disclosure covers. CBP's publication suggests covering the period not barred by the statute of limitations: five years from entry for negligence or gross negligence. Violations CBP later finds outside your stated scope do not get prior disclosure treatment, per 19 CFR 162.74(h).

Filing a prior disclosure is a legal step. Confirm the scope, the tender and the timing with a licensed customs broker or customs counsel before anything is sent.

How do Focused Assessments and other CBP audits fit in?

The CF-28 is the everyday version. The larger version comes from CBP's Trade Regulatory Audit, which conducts audits that "generally have targeted audit objectives and are compliance driven", often based on a referral. Its Focused Assessment is described as a comprehensive audit of your internal control over import activities, in up to three phases: a pre-assessment survey, assessment compliance testing and a follow-up audit.

Two rules make preparation pay. A written demand for entry records must be answered within 30 calendar days under 19 CFR 163.6(a), and failure to produce carries penalties per release of up to $10,000 or 40 percent of appraised value (negligence), or up to $100,000 or 75 percent (willful), whichever is less. And the same self-assessment that answers a CF-28 is the evidence of internal control a Focused Assessment tests.

What should you do on your own entries this week?

Pull last quarter's entry export from your broker, pair each line with its invoice, and run the nine checks above on every line of your three highest-duty products. The post-entry audit guide walks through the same fields box by box. Write down what is correct, overpaid, underpaid and unsupported. If you find an underpayment, talk to your broker or counsel about a correction or a prior disclosure before CBP asks; if you find an overpayment, check each entry's liquidation date and start the recovery route that is still open.