---
title: CBP Form 28 or CF-29 on a China Import | China Agent
description: CBP Form 28 asks you to prove what you declared. A CF-29 is CBP's decision. The proof for both is at the actual factory in China that makes your goods.
---

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 CBP FORM 28: REQUEST FOR INFORMATION

# CBP sent a CF-28. It's asking you to prove what you already declared, and the proof is in China.

###### This is manageable, and there is an honest way through it. A CF-28 is CBP asking questions about an entry you already filed: who really made the goods, what you really paid, where they really came from, whether you classified them right. A CF-29 is CBP telling you what it has decided about the entry.

###### Your factory may offer a paragraph in English and a certificate. It means well, but that isn't the response. CBP wants the business records that already exist in the factory, and for a good supplier most of them do. Here is what is happening, what to do today, and what the file has to contain. Then, if you want it, what we do.

[Book a 30-minute call →](https://www.china-agent.com/booking?hsLang=en)

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### What is CBP Form 28 (CF-28)?

 CF-28: Request for Information. CBP has looked at your entry and wants proof of something you declared. It isn't an accusation. It's a question with a deadline, and you answer it with records.

The checks behind a CF-28 have good reasons. Keep forced labor out of the products people buy. Stop goods being routed through a third country to hide where they were made. Make sure honest factories aren't undercut by ones that cut corners. The result is better, safer products, and duty paid on what the goods really are.

### What is CBP Form 29 (CF-29)?

 CF-29: Notice of Action. CBP has reached a decision. Either it proposes to change your entry (reclassify, revalue or reassign origin) and you have a short window to respond, or it has already made the change and a bill follows. The form says which, so read that line first.

Both forms sit on the same three facts every entry is built on: the HTS classification, the country of origin, and the entered value. CBP calculates every dollar of duty from those three. Get one wrong and the entry is wrong.

### How long do I have?

 The deadline is printed on the letter. The form itself asks for a reply within 30 days from the date of the request, and the date is on your letter.

Three things about that date. It runs from the date CBP issued the letter, not the day it reached you. Your broker can ask the officer named on it for more time, and often gets it if asked before the date, not after. And if there's no answer, CBP can move to a CF-29 based on its own numbers.

 In this order. You can do all of it yourself.

## What should I do today?

**1. Read the letter for four things.** The entry number. The date. The name and contact of the CBP officer. And the actual question: it will be about who made it, what it's worth, where it's from, or how it's classified. Sometimes two of those. Rarely all.

**2. Pull your own paper.** The entry summary (Form 7501), the commercial invoice, the packing list, the bill of lading, and every payment you made for this shipment: the wires, not the invoice. Put them in one folder. Half the answer is already on your side of the ocean.

**3. Call your customs broker.** They filed the entry. They will file the response. Tell them the entry number and read them the question. Ask them what the officer will want to see. They know the reviewer's habits.

**4. Write down your supplier's legal Chinese name and the factory's address.** Not the trading company on your invoice. The entity on the business licence, at the place the goods were made. If those are two different companies, you have just found the question CBP is asking.

**5. Keep CBP contact with you and your broker.** Ask the factory politely not to write to CBP, by email or through your broker. The entry is yours, so the answer should come from your side, with the factory's records behind it.

**6. Ask for records, not a certificate.** The factory will probably send one, and it means well. But it's a paper the factory wrote about itself. Ask for the records behind it, listed below.

 *Source: DOJ/DHS Trade Fraud Guide, July 2026, pp.4–5* 

 Almost every CF-28 on a China entry is one of these. Find yours.

## Which of the three questions is CBP asking?

**Who made** it. Trading company on the invoice. Factory in the building. Or a third name on the bank slip. CBP wants the manufacturer, not the seller, and wants to see that the manufacturer exists, at that address, making that product.

**What it is worth.** Invoice says one number. Wire says another. A Hong Kong company sits in the middle. Somebody mentioned "first sale" and nobody has the paper for it. CBP wants the money trail to match the invoice trail, end to end.

**Where it is from.** China on the old entries. Cambodia or Vietnam on the new ones. Same owner, same product. CBP is asking whether the origin moved or only the letterhead did, and the legal test is whether a real transformation happened in the second country, not whether a box was opened there.

**How it is classified.** Finished goods declared as parts. A high-duty article filed under a neighbouring heading. Or the product simply isn't what the factory told you it was. CBP wants the bill of materials and what the thing actually is.

If you cannot tell which one you're in, bring the letter to the call. That is the first ten minutes.

*Source: DOJ/DHS Trade Fraud Guide, July 2026, pp.5–6, 19–21.*

 Because the law doesn't ask the factory. It asks you.

## Why the answer is still yours, even if your supplier helps

The importer of record must use reasonable care to give CBP accurate information, and is liable for misstatements even when a broker prepared them. A US court has already ruled that relying on the exporter and the broker does not remove that duty. You cannot contract it away. That's not our opinion. It's *United States v. Golden Ship Trading*, and the government cites it in its own guide.

So when the factory sends what factories usually send, it means well, but it doesn't answer CBP's question. The usual offers:

**"We are the factory"** on letterhead that doesn't match the licence. **WeChat screenshots of** someone saying yes. A certificate with a chop from a company that isn't the one on your PI. **A Hong Kong invoice for** a Guangdong factory. "Now we ship from Cambodia" with no second building anyone can visit. A price list instead of the wires that match the entry.

CBP isn't asking for a story. It's asking for records, and most of them already exist.

*Source: DOJ/DHS Trade Fraud Guide, July 2026, p.3 (19 U.S.C. §1484(a)(1); U.S. v. Golden Ship Trading Co., 2001).*

 Ordinary business records that already exist in China, matched to the question:

## What does CBP actually want to see?

For who made it: the manufacturer's business licence; the production address; production orders or records for your goods; who in that factory cuts, sews, machines and packs, and which company on your paperwork only sells.

**For what it's worth:** the contract or PO; every invoice in the chain, including the one between the trading company and the factory; the wire transfers, matched line by line to those invoices; the payment terms; and, if anyone said "first sale," the paper for every sale in the sequence.

**For where it's from:** where each input came from; what was done to it, where, by whom; whether the second building exists and what actually happens inside it. A dated photograph of your product being made at the address you're claiming is worth more than a stack of certificates.

**For classification:** the bill of materials, mapped to the tariff heading; what the product is made of and how; specifications and, where relevant, a sample.

Every one of those is held by a company in China. Most suppliers will share them once someone sits down with them face to face and explains what CBP needs and why. A few can't, and it's better to find that out before the next order than at the port.

*Source: DOJ/DHS Trade Fraud Guide, July 2026, pp.5–6; CBP Forced Labor Enforcement Operational Guidance, June 2026, Appendix E pp.56–57*

 Answer a CF-28 with records. Left unanswered, it can become a CF-29, with CBP working from its own numbers.

## What if the answer is late or incomplete?

Where one does, Section 592 of the Tariff Act sets penalties by level of care: negligence, gross negligence or fraud. Before any penalty, CBP sends a pre-penalty notice, and that is the time to show your evidence. A file built early is what you would show.

If the question is origin or classification and the product falls under an antidumping or countervailing duty order, those duties apply as well. The government's guide notes they can be high, in some cases above 600 per cent of declared value.

US law also expects importers to keep entry records for five years (19 U.S.C. § 1508), so a file you build now keeps working for you.

None of this is a reason to panic. It's a reason not to wait: the letter you're holding is the easiest stage to answer.

*Source: DOJ/DHS Trade Fraud Guide, July 2026, p.5 (Form 29), p.10 (§1592, pre-penalty notice), p.21 (AD/CVD), p.4 (19 U.S.C. §1508 retention).*

 CBP FORM 29: NOTICE OF ACTION

## What should I do if I got a CF-29 instead of a CF-28?

A CF-29 lands harder than a CF-28. CBP has stopped asking and started deciding. It's still a stage you can work through, and most of the work is the same work.

Read one line first. The notice says the action is proposed, or that it has been taken. Proposed means CBP intends to change the entry and is giving you a window to answer in writing before it does. Taken means the change is already made. Then find the response window printed on the notice and the date it counts from. Under the regulation behind the form, CBP can't put off liquidating the entry for more than 20 days after it mails the notice, unless it has compelling reasons. Ask your broker or counsel to confirm the exact deadline on your entry.

Then do what you would do for a CF-28. Use the same folder: the entry summary, the commercial invoice, the packing list, the bill of lading and the wires. Make the same call to your broker, who filed the entry and will file the reply. What changes is the aim. The notice tells you what CBP changed, and the records from the actual factory that makes your goods should point straight at that change. If it's a new tariff heading, pull the bill of materials and what the product is made of. A higher value needs the full invoice chain, with the wires that match it. And if CBP moved the origin, you have to show where the inputs came from and what was really done to them in the second country.

If the action is final, deal with the money first. The change goes into liquidation, which is CBP's final calculation of duty on the entry, and a bill follows. That bill is due within 30 days of the date it's issued. Interest on the extra duty is charged from the date your original deposit was due up to liquidation. Be honest with yourself about that number before you decide what to fight.

After liquidation, a protest is how you contest CBP's decision. For entries made on or after December 18, 2004, it has to be filed within 180 days of liquidation, on CBP Form 19 or in ACE. You can file it yourself, or your broker or attorney can. CBP can take up to two years to decide one. The records that would have answered a proposed action are the same records that give a protest a chance.

None of this is legal advice. Your broker or counsel decides how to answer and files it. Our part is the records from China that the answer stands on.

*Source: 19 CFR 152.2 (Form 29, 20 days); 19 CFR 24.3(e) and 24.3a (bills, interest); 19 CFR 174.12(e) and 174.21 (protest timing); CBP, Protests; DOJ/DHS Trade Fraud Guide, July 2026, p.5 (Form 29, liquidation).*

 CBP FORM 28: REQUEST FOR INFORMATION

## What we do and what we don't

###### We get the China-side file. On site, in Chinese.

Legal name against the PI against the bank account. The address on the licence against the factory you can walk into. Who in that factory cuts, sews, machines and packs  and who only sells. The invoices against the actual wires. Whether anything was really transformed in the second country, or only relabelled. Dated photographs. Affidavits the factory will chop. A bill of materials the factory will stand behind.

We get there by sitting with your supplier face to face, explaining what CBP is asking and why, and helping them get it right. Then the packet is assembled through Asia Agent, Chinese originals with English translations, indexed to the question CBP asked. Your broker or counsel files it.

**What we are not.** We are not US trade counsel: your broker and lawyer file the response and argue the law. We don't fix your Form 5106 or your bond; that's your broker. We never source and take no commission from any factory, which is why a factory's own supplier will tell us who they are. And a good file doesn't guarantee CBP agrees with you. It guarantees CBP is deciding on evidence instead of on your silence.

### No letter yet?

 The records CBP asks for on a CF-28 are the same records that exist whether CBP ever asks or not: the license, the wires, the production paper, the origin trail.

For a good supplier it's mostly documents that already exist, so the real cost is time and trust, not a factory rebuild. Collected before a letter, it's steady work with your supplier. Collected after, it runs against CBP's date. Our team collects them into a [Reasonable Care File](https://www.china-agent.com/reasonable-care-file?hsLang=en) for each supplier and keeps it current.

[That's what Monthly Support is for. →](https://www.china-agent.com/monthly-support-packages?hsLang=en)

 FAQs

## Frequently Asked Questions

 

##### [What is a CF-28? CBP Form 28, Request for Information. CBP is asking the importer of record to substantiate something declared on an entry: usually who manufactured the goods, their value, their country of origin, or their classification. The form asks for a reply within 30 days from the date of the request, and the importer answers it with records.](https://www.china-agent.com/cf-28-response-china#collapse1-dnd_area-module-8)

##### [What does CBP Form 28 ask for on a China import? CBP Form 28 is the Request for Information. On a China import, it usually asks who made the goods, what they are worth, where they are from, or how they are classified. The answer is records held by the factory in China that made the goods: the business license, production records, the invoice chain, the wires and the bill of materials. The importer's customs broker files the response. China Agent collects the China-side records and does not file with CBP.](https://www.china-agent.com/cf-28-response-china#collapse2-dnd_area-module-8)

##### [What is a CF-29? CBP Form 29, Notice of Action. CBP has reached a conclusion about the entry and either proposes a change (with a short window to respond) or has already made it. It typically follows a CF-28 that was unanswered or unconvincing, and it is where additional duties are assessed.](https://www.china-agent.com/cf-28-response-china#collapse3-dnd_area-module-8)

##### [What should I do if customs sent me a CF-29? First, read whether the CF-29 (CBP Form 29, Notice of Action) says the action is proposed or has been taken. If it is proposed, answer in writing within the window printed on the notice. Under 19 CFR 152.2, liquidation cannot be withheld for more than 20 days from the date CBP mails the notice, unless CBP has compelling reasons. If the action has been taken, the change goes into liquidation and a bill follows. Either way, use the same folder you would use for a CF-28 and call your customs broker. Then point the records from China at whatever CBP changed on the entry. The importer's broker or counsel confirms the exact deadline for the entry. China Agent does not give legal advice.](https://www.china-agent.com/cf-28-response-china#collapse4-dnd_area-module-8)

##### [Can I protest a CF-29 from customs? Yes, after the entry liquidates. A protest under 19 U.S.C. 1514 is how an importer contests CBP decisions such as classification and appraised value. For entries made on or after December 18, 2004, it must be filed within 180 days of liquidation, on CBP Form 19 or in ACE. The importer can file it, or have its customs broker or attorney file it. CBP has up to two years to decide a protest. The records that support it sit with the factory in China. China Agent collects those records, and the broker or counsel files the protest. For the legal side of a protest, the importer should talk to its broker or trade counsel.](https://www.china-agent.com/cf-28-response-china#collapse5-dnd_area-module-8)

##### [How long do I have to respond to a CF-28? The form itself asks for a reply within 30 days from the date of the request, as printed in its instructions. That runs from CBP's date on the letter, not the day it reached you. If you need more time, your broker can ask the officer named on the form, and should do so before the 30 days run out.](https://www.china-agent.com/cf-28-response-china#collapse6-dnd_area-module-8)

 

##### [Can my Chinese supplier answer the CF-28 by email? A foreign firm can complete CBP Form 28 itself. The form's certification box says a company official's signature is "not required if foreign firm completes this form." Ask your broker how the reply should be sent for your entry. The entry is still yours: under 19 U.S.C. §1484 the duty of reasonable care sits with the importer of record, and a US court has ruled that reliance on the exporter and the broker does not remove it. Whoever replies, the answer should rest on the factory's ordinary business records: license, production records, invoices, wires.](https://www.china-agent.com/cf-28-response-china#collapse7-dnd_area-module-8)

##### [Can my customs broker handle this from the US? They file what you give them, and they should file the response. But they work from the US, so they can't visit the factory, match the chop to the license, or reconcile the factory's wires. The collection happens in China.](https://www.china-agent.com/cf-28-response-china#collapse8-dnd_area-module-8)

##### [What should I bring to the 30-minute call? The CF-28, the entry summary (Form 7501), the commercial invoice, and your supplier's legal Chinese name. Don't let the factory contact CBP in the meantime.](https://www.china-agent.com/cf-28-response-china#collapse9-dnd_area-module-8)

##### [The letter is about origin and my paperwork says Cambodia or Vietnam. What now? Then it's an origin file, not a typing error. CBP is asking whether substantial transformation happened in the second country. We check both factories: what went in, what came out, and what actually happens at the second address. Goods that were only repacked or relabeled don't change origin.](https://www.china-agent.com/cf-28-response-china#collapse10-dnd_area-module-8)

##### [My supplier offered to "adjust the invoice" for customs. Should I? No. Two invoices for one transaction (a real one for payment and a lower one for CBP) is undervaluation, and the government's July 2026 Trade Fraud Guide lists it as a fraud typology with criminal cases attached. If a supplier offers this, it tells you how they handle their other paperwork.](https://www.china-agent.com/cf-28-response-china#collapse11-dnd_area-module-8)

##### [Could this turn into antidumping or countervailing duties? If the real origin or classification puts your product inside an AD/CVD order, yes, those duties can apply, and the government's guide notes they can be high. That's why an origin CF-28 is worth answering with care, even when the question sounds small.](https://www.china-agent.com/cf-28-response-china#collapse12-dnd_area-module-8)

##### [How fast can you move if the deadline is close? Live CF-28s go first. Document collection can start the day after the call. A factory visit usually takes days once the factory agrees, and most do once someone explains face to face what CBP needs and why. If one won't, that's an answer too, and it's better to know before your broker files.](https://www.china-agent.com/cf-28-response-china#collapse13-dnd_area-module-8)

##### [Do you work for the factory? No. China Agent does not find factories for you. No commission from any factory.](https://www.china-agent.com/cf-28-response-china#collapse14-dnd_area-module-8)

 

##### [Is this legal advice? No. We are not US trade counsel. We produce the China-side file. Your broker and counsel file it and argue it.](https://www.china-agent.com/cf-28-response-china#collapse15-dnd_area-module-8)

##### [I don't have a letter yet. Does this apply to me? If your supplier's legal name isn't on your invoice, if your wires don't match your invoices, or if your origin moved to a second country recently, those are the gaps to close first. Closed before a letter arrives, it's routine work with your supplier.](https://www.china-agent.com/cf-28-response-china#collapse16-dnd_area-module-8)

## Related<https://www.china-agent.com/booking?hsLang=en>

###### [UFLPA Detention: What CBP Wants and Your 30 Days](https://www.china-agent.com/uflpa-detention-documentation?hsLang=en) [CF-28 / CF-29: When CBP Questions an Entry](https://www.china-agent.com/cf-28-response-china?hsLang=en) [China Origin via Cambodia or Vietnam](https://www.china-agent.com/country-of-origin-china-vietnam?hsLang=en) [CBP Detained My Shipment from China](https://www.china-agent.com/cbp-detained-shipment-china?hsLang=en) [The Ten Things CBP Will Ask Your Supplier For](https://www.china-agent.com/blog/10-things-cbp-will-ask-you-to-produce?hsLang=en) [Monthly Support: The File, Kept Every Month](https://www.china-agent.com/monthly-support-packages?hsLang=en) [Your Own Employee in China](https://www.china-agent.com/employee-in-china?hsLang=en)

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    "name" : "What does CBP Form 28 ask for on a China import?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "CBP Form 29, Notice of Action. CBP has reached a conclusion about the entry and either proposes a change (with a short window to respond) or has already made it. It typically follows a CF-28 that was unanswered or unconvincing, and it is where additional duties are assessed."
    },
    "name" : "What is a CF-29?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "First, read whether the CF-29 (CBP Form 29, Notice of Action) says the action is proposed or has been taken. If it is proposed, answer in writing within the window printed on the notice. Under 19 CFR 152.2, liquidation cannot be withheld for more than 20 days from the date CBP mails the notice, unless CBP has compelling reasons. If the action has been taken, the change goes into liquidation and a bill follows. Either way, use the same folder you would use for a CF-28 and call your customs broker. Then point the records from China at whatever CBP changed on the entry. The importer's broker or counsel confirms the exact deadline for the entry. China Agent does not give legal advice."
    },
    "name" : "What should I do if customs sent me a CF-29?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "Yes, after the entry liquidates. A protest under 19 U.S.C. 1514 is how an importer contests CBP decisions such as classification and appraised value. For entries made on or after December 18, 2004, it must be filed within 180 days of liquidation, on CBP Form 19 or in ACE. The importer can file it, or have its customs broker or attorney file it. CBP has up to two years to decide a protest. The records that support it sit with the factory in China. China Agent collects those records, and the broker or counsel files the protest. For the legal side of a protest, the importer should talk to its broker or trade counsel."
    },
    "name" : "Can I protest a CF-29 from customs?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "The form itself asks for a reply within 30 days from the date of the request, as printed in its instructions. That runs from CBP's date on the letter, not the day it reached you. If you need more time, your broker can ask the officer named on the form, and should do so before the 30 days run out."
    },
    "name" : "How long do I have to respond to a CF-28?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "A foreign firm can complete CBP Form 28 itself. The form's certification box says a company official's signature is \"not required if foreign firm completes this form.\" Ask your broker how the reply should be sent for your entry. The entry is still yours: under 19 U.S.C. §1484 the duty of reasonable care sits with the importer of record, and a US court has ruled that reliance on the exporter and the broker does not remove it. Whoever replies, the answer should rest on the factory's ordinary business records: license, production records, invoices, wires."
    },
    "name" : "Can my Chinese supplier answer the CF-28 by email?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "They file what you give them, and they should file the response. But they work from the US, so they can't visit the factory, match the chop to the license, or reconcile the factory's wires. The collection happens in China."
    },
    "name" : "Can my customs broker handle this from the US?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "The CF-28, the entry summary (Form 7501), the commercial invoice, and your supplier's legal Chinese name. Don't let the factory contact CBP in the meantime."
    },
    "name" : "What should I bring to the 30-minute call?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "Then it's an origin file, not a typing error. CBP is asking whether substantial transformation happened in the second country. We check both factories: what went in, what came out, and what actually happens at the second address. Goods that were only repacked or relabeled don't change origin."
    },
    "name" : "The letter is about origin and my paperwork says Cambodia or Vietnam. What now?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "No. Two invoices for one transaction (a real one for payment and a lower one for CBP) is undervaluation, and the government's July 2026 Trade Fraud Guide lists it as a fraud typology with criminal cases attached. If a supplier offers this, it tells you how they handle their other paperwork."
    },
    "name" : "My supplier offered to \"adjust the invoice\" for customs. Should I?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "If the real origin or classification puts your product inside an AD/CVD order, yes, those duties can apply, and the government's guide notes they can be high. That's why an origin CF-28 is worth answering with care, even when the question sounds small."
    },
    "name" : "Could this turn into antidumping or countervailing duties?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "Live CF-28s go first. Document collection can start the day after the call. A factory visit usually takes days once the factory agrees, and most do once someone explains face to face what CBP needs and why. If one won't, that's an answer too, and it's better to know before your broker files."
    },
    "name" : "How fast can you move if the deadline is close?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "No. China Agent does not find factories for you. No commission from any factory."
    },
    "name" : "Do you work for the factory?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "No. We are not US trade counsel. We produce the China-side file. Your broker and counsel file it and argue it."
    },
    "name" : "Is this legal advice?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "If your supplier's legal name isn't on your invoice, if your wires don't match your invoices, or if your origin moved to a second country recently, those are the gaps to close first. Closed before a letter arrives, it's routine work with your supplier."
    },
    "name" : "I don't have a letter yet. Does this apply to me?"
  } ]
}
```