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.
What is a CF-28, and what is a 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.
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.
How long do I have?
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.
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
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.
Why can't my supplier just answer this?
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).
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
What if the answer is late or incomplete?
Most CF-28s don't get this far. 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).
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?
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 for each supplier and keeps it current.
Frequently Asked Questions
CBP sent a CF-28?
Bring the letter. In 30 minutes we'll tell you what has to come from the factory, and how we'd ask for it.
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