Definition
What Are CF-28 and CF-29 Notices?
A CF-28 is CBP Form 28, a Request for Information sent when CBP has questions about a customs entry. A CF-29 is CBP Form 29, a Notice of Action announcing CBP's intent to reclassify, revalue, or change origin on an entry. After liquidation, the importer has 180 days to file a protest (CF-19).
When CBP can question your entry
Customs entries remain open until liquidation — CBP's formal closing of the entry. The default liquidation timeline is 1 year from entry, extendable in 1-year increments up to 4 years. AD/CVD entries can remain open for years pending Commerce administrative review. CBP can request information, propose adjustments, and reliquidate at any point in this window.
Responding to a CF-28
A CF-28 is a question, not an accusation. Respond within the stated timeframe — typically 30 days — with complete substantive documentation. A non-response or thin response signals CBP that you cannot defend your declared values, and CBP will proceed to a CF-29 decision based on available information. For entries with significant duty exposure or fraud implications, consult a customs attorney before responding; CF-28 responses can be used in later penalty proceedings.
Responding to a CF-29
A CF-29 is CBP's stated decision. You have a brief comment window (typically 20–30 days) to submit additional facts before the action becomes final. A binding ruling for the same product from CBP's CROSS database is particularly powerful at this stage — CBP must follow its own rulings. After CBP finalizes the action and reliquidates the entry at the adjusted rate, the protest path begins.
The 180-day protest deadline
Under 19 USC § 1514, an importer has 180 days from the date of liquidation to file a protest (CF-19). This is a statutory deadline; protests filed even one day late are rejected as untimely regardless of merit. Liquidation notices are posted to the ACE portal — set up a process to track liquidation dates for any entry that received CF-28 or CF-29 correspondence. CBP has up to 2 years to act on a filed protest; a denial can be appealed to the US Court of International Trade within 180 days of denial.
Prior disclosure as the alternative
If you discover a misclassification, valuation error, or origin error before CBP initiates an inquiry, voluntary prior disclosure under 19 CFR § 162.74 reduces penalties dramatically — often to zero for unintentional violations, or 2× rather than 4× for gross negligence or fraud. The window closes once CBP has opened an inquiry on the affected entries. For systemic issues uncovered by internal audit, prior disclosure is often the lowest-cost resolution path.
Frequently asked questions
- Is a CF-28 a penalty notice?
- No. A CF-28 is a Request for Information — CBP has questions but has not taken a position. It deserves a serious response because failing to respond will lead CBP to make an adverse determination on the available information, but it is not in itself a penalty.
- What's the difference between a CF-28 and a CF-29?
- A CF-28 is the question stage; CBP is gathering information. A CF-29 is the answer stage; CBP has made a determination and intends to act. The CF-28 typically precedes a CF-29, but CBP can issue a CF-29 directly if the issue is clear from the entry record.
- Can I challenge CBP's decision after a CF-29?
- Yes — through a protest (CF-19) filed within 180 days of liquidation. The protest must specify the entries, the nature of the objection, and the relief requested. A denial can be appealed to the US Court of International Trade.
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Longer-form articles that go deeper than the definition above.
CF-28, CF-29, and protests — full guide
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