CBP Form 28 & Form 29

Annkaren Wambui
Jul 9
4 min read

Updated: Jul 13

🔐CBP Form 28 & Form 29: What Every Importer Should Do Before Customs Comes Knocking

Summary: Receiving a CBP Form 28 (Request for Information) or CBP Form 29 (Notice of Action) can be one of the most stressful moments for any importer. Yet these notices are becoming increasingly common as U.S. Customs and Border Protection (CBP) continues to strengthen enforcement and expects importers to demonstrate Reasonable Care throughout the import process. This PRO report explains what Forms 28 and 29 are, why they are issued, how they differ, and the practical steps businesses should take to respond confidently, reduce compliance risk, and prepare for future customs audits.

CBP officer monitors import compliance dashboards beside a giant CBP Form 28 Request for Information in a modern office. — *CBP Form 28 & 29*

When CBP Sends You a Letter…

Few customs documents create as much anxiety as a CBP Form 28. For many importers, receiving one raises immediate questions.

"Have we done something wrong?"

"Are we being audited?"

"What happens if we cannot answer?"

The reality is more nuanced.

A Form 28 does not automatically mean CBP believes you have violated customs law.

However, it does indicate that Customs wants additional information before accepting the declaration as filed.

Increasingly, Form 28 requests are becoming part of CBP's normal risk-based compliance strategy.

What Is a CBP Form 28?

Infographic comparing CBP Form 28 and Form 29, with blue and gold panels, icons, and compliance warnings on a dark background. — *CBP Form 28 vs. Form 29 comparison*

CBP Form 28 is officially called a Request for Information (CF28).

It allows Customs to request supporting evidence before making a final decision regarding an import declaration.

Typical requests include:

Commercial invoices
Purchase orders
Bills of Materials
Technical specifications
Product photographs
Manufacturing information
HTS classification justification
Country of origin evidence
Valuation support
Supplier relationships

Failure to respond adequately may lead directly to a CBP Form 29.

Understanding CBP's "Reasonable Care" Standard

One of the most important concepts in U.S. customs law is Reasonable Care.

Under 19 U.S.C. §1484, importers not customs brokers are legally responsible for exercising reasonable care when entering merchandise into the United States.

Reasonable Care means businesses should be able to demonstrate that they have taken appropriate steps to ensure:

✔ Correct tariff classification

✔ Accurate customs valuation

✔ Correct country of origin

✔ Complete customs documentation

✔ Proper record keeping

✔ Appropriate internal controls

Submitting inaccurate information simply because "the broker handled it" is not considered a defence.

Why Are More Form 28s Being Issued?

Customs intelligence center with analysts at laptops facing data dashboards, charts, world maps, and compliance alerts in a dark office. — *Why the increased CBP Scrutiny?*

Several factors are driving increased CBP scrutiny.

These include:

AI-powered risk targeting
More sophisticated customs data analytics
Tariff evasion investigations
Forced labour enforcement
Country of origin verification
Section 301 reviews
AD/CVD enforcement
Valuation verification

Today's customs audits increasingly begin with data rather than physical inspections.

The Anatomy of a Real Form 28

The redacted example accompanying this report demonstrates the level of detail CBP may request.

Among other things, Customs requested:

invoices
purchase orders
fibre composition
Bills of Materials
technical diagrams
manufacturer information
proof of payment
importer relationships
HTS classification analysis
CBP rulings supporting classification

This illustrates an important point:

CBP is no longer interested only in the customs declaration.

It increasingly wants to understand how the importer reached the declaration.

What Should You Do If You Receive a Form 28?

Business team in a dark office reviews customs compliance dashboards, with a harbor at sunset and an American flag in the background — *What we recommend you should do after receiving form 28.*

Our recommendations:

1. Never Ignore It

Missing the response deadline can escalate matters quickly.

2. Coordinate Internally

Legal, procurement, engineering, logistics and finance may all hold relevant information.

3. Verify Before Responding

Do not simply resend existing documentation.

Ensure it actually supports the declaration.

4. Review the Entire Entry

Sometimes the issue extends beyond the specific question raised.

5. Seek Professional Advice

Complex classification, valuation or origin questions may require specialist customs expertise.

Form 28 Today. Form 29 Tomorrow?

If CBP remains unsatisfied after reviewing the Form 28 response, the agency may issue CBP Form 29 (Notice of Action).

Possible outcomes include:

classification changes
additional duties
denied preferential treatment
valuation adjustments
liquidation changes

The quality of the Form 28 response often determines what happens next.

PRO Compliance Checklist

Before CBP asks...

Ask yourself.

☐ Can we justify every HS Code?

☐ Can we explain our valuation?

☐ Can we prove origin?

☐ Do we retain supporting documents?

☐ Could we demonstrate Reasonable Care today?

If the answer to any of these questions is "no", now is the time to strengthen your compliance programme; not after receiving a Form 28.

Key Takeaways

A Form 28 is a request for evidence, not necessarily an allegation of wrongdoing.
Importers remain legally responsible under the Reasonable Care standard.
Strong documentation is your best defence.
AI and customs data analytics are increasing CBP scrutiny.
Preparing before Customs asks is significantly less costly than responding after enforcement begins.

Sources

U.S. Customs and Border Protection – CBP Form 28 (Request for Information)
U.S. Customs and Border Protection – CBP Form 29 (Notice of Action)
19 U.S.C. §1484 – Entry of Merchandise; Importer Responsibility and Reasonable Care
CBP Reasonable Care Checklist for Importers

📥 Download the Official CBP Form 28

To complement this PRO report, we have included a redacted example of a CBP Form 28 – Request for Information, illustrating the types of documentation and explanations Customs may require during an import review.

Studying real-world examples can help importers strengthen internal controls, improve record keeping, and prepare more effectively for future CBP enquiries.

Download the sample Form 28 below.

Need Help Responding to a CBP Form 28?

At Customs Manager Ltd, we help businesses strengthen U.S. customs compliance through:

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Author

Ann Karen | Head of Growth

Updated: July 2026

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