A CBP Form 28 is a formal Request for Information issued when U.S. Customs and Border Protection needs additional facts or documents to evaluate an import entry. For a DDP shipment, the importer of record must control the response even when the seller, freight forwarder, customs broker and overseas factory each hold part of the evidence. The safest approach is to identify every question, assign a document owner, reconcile the response to the filed entry and submit a complete, certified package through the channel and deadline shown on the notice.
Preserve the notice and entry file, record the response deadline, notify the importer’s customs broker and responsible compliance manager, and stop informal changes to the underlying documents. Build a question-by-question response supported by transaction records, product evidence and clear calculations. If a fact in the entry may be wrong, obtain qualified customs advice before deciding whether a correction, prior disclosure or other procedure is appropriate.
Form 28 is not the same as a cargo hold or a penalty notice. It is an information request, but the answer can influence classification, customs value, origin, trade-program eligibility, admissibility and future entries. A weak or inconsistent response may be followed by a CBP Form 29 Notice of Action .
CBP Form 28 is provided for under 19 CFR 151.11. The current form identifies the entry, merchandise, tariff item, country of origin or exportation, broker and parties, then lists the questions or items CBP wants. The form includes common requests for contracts, purchase orders, descriptive literature, component or ingredient breakdowns, samples and transaction-cost details such as packing, commissions, proceeds, assists and royalties.
The request may result from an entry review, a compliance concern, a product verification, a trade-agreement claim, a valuation question or an admissibility inquiry. It does not automatically mean CBP has decided the entry is wrong. It does mean the existing entry package did not provide enough information for the determination being made.
Under DDP, the commercial seller may coordinate freight, customs clearance and delivery, but U.S. customs responsibility follows the importer-of-record structure—not the marketing label on the quotation. The broker may have filed the entry, while the factory holds production records, the seller holds price and payment records, and the U.S. buyer holds product-use information. These records must tell one coherent story.
Settle party responsibilities using the guide to importer of record, consignee and customs broker roles . The broker can transmit or organize a response, but should not be expected to invent manufacturing facts or certify records it does not own. Likewise, a foreign seller should not answer in the importer’s name without proper coordination and authority.
Start with a matrix instead of drafting a long letter. Copy each numbered question or requested item exactly enough to preserve its meaning. Add columns for the responsible owner, the proposed answer, supporting exhibit, open issue and approval status. This structure exposes missing evidence before submission and makes the final package easier to review.
Before answering, compare the supporting records with the CBP Form 7501 or ACE entry-summary data . Confirm importer identity, manufacturer, seller, buyer, country of origin, tariff classification, entered value, quantity, duty rate and special-program indicators. A response that answers the question but conflicts with another entry field may create a new issue.
For value questions, use the DDP customs-value guide to separate international freight deductions from additions such as assists, packing, certain royalties and proceeds. Do not submit a new invoice merely because the filed invoice is inconvenient. Preserve the original record and explain any legitimate correction transparently.
A large attachment set is not necessarily a strong response. Each exhibit should have a clear source, date, transaction link and purpose. Translate relevant foreign-language records accurately. Explain codes, abbreviations and relationships between companies. If a spreadsheet calculates an allocation, include the source figures and method rather than only the result.
The current Form 28 contains a certification that the information furnished is true and correct and that any samples were taken from the covered shipment. Determine who is authorized to sign for the importer and who has personal or corporate knowledge of the response. The customs broker’s role and power of attorney should be reviewed using the customs power-of-attorney checklist .
Do not hide the inconsistency, overwrite source records or send a speculative answer. First determine the scope: one line, one entry, one supplier period or a recurring control failure. Separate facts already supported by records from conclusions that require legal or technical analysis. Ask the broker or customs counsel whether a post-summary correction, protest, prior disclosure or another procedure is available and appropriate for the entry’s status.
A Form 28 response and a corrective filing solve different problems. The response supplies requested information; a correction changes entry data through an authorized mechanism. Coordinate them so that dates, calculations and explanations agree.
No. It is a request for information, not a penalty assessment. However, the facts disclosed—or not disclosed—can affect duties, admissibility, liquidation, enforcement decisions and future entries.
A properly authorized broker may help prepare and transmit the response, but the importer must ensure that the facts and certification are accurate. Manufacturing, pricing and origin evidence often must come from the seller or producer.
No. CBP may accept the explanation or continue its review. A Form 29 may follow when CBP proposes or takes an action affecting the entry, such as a change in classification, value, quantity or duty treatment.
Do not ignore a question. Clarify the scope through the proper CBP contact and provide a precise response or explain why a request is not applicable. Qualified customs advice is appropriate where the scope is unclear.
Not automatically. Review whether the same classification, value, origin, supplier or program claim appears in open or future entries. Apply appropriate holds or corrections based on the actual risk and professional advice.
This article provides general operational information, not legal or customs advice. The importer should follow the specific notice, current CBP instructions and advice from a licensed customs broker or qualified customs counsel.
25 Sep
A practical guide to CBP Form 29 for DDP imports, covering proposed versus taken action, classification and value evidence, response planning, exposure review, liquidation and follow-up controls.
25 Sep
A practical guide to responding to CBP Form 28 in DDP imports, covering response ownership, classification, valuation and origin evidence, document controls, corrections, certification and follow-up.
21 Sep
A practical guide to U.S. customs valuation for DDP shipments, covering transaction value, international freight and duty deductions, assists, royalties, packing, commissions, related parties and supporting records.
English
Deutsch
Português
العربية
中文
