Executive Summary
A CF-28 (CBP Form 28, Request for Information) is the form CBP uses when the information on an entry is not sufficient to determine admissibility, value, or classification. It has long been a routine part of customs practice, but its context is changing. CBP’s targeting systems now compare entries against historical patterns, and customs brokers and practitioners report that CF-28 issuance has noticeably increased since September 2025. Because a CF-28 is often prompted by a pattern rather than a single line item, it can have implications for other, similar entries. This analysis explains what a CF-28 asks, where it sits relative to the CF-29 Notice of Action and the penalty process, how it relates to Executive Order 14411, and the considerations that tend to matter when preparing a response.

CF-28 Requests for Information: Understanding CBP’s Data-Driven Inquiries

(CF-28信息请求：理解CBP的数据驱动式问询)

1 · What a CF-28 Is—and How the Context Has Changed

The Basics

CBP Form 28 is provided for by 19 CFR 151.11. CBP personnel send it to an importer or the importer’s agent when the invoice or other documentation does not give enough information to determine admissibility, appraised value, or classification. In practice it is used to request items such as product samples, classification and valuation details, or support for a free trade agreement claim.

Several practical features are worth knowing:

• Delivery: CBP may send a CF-28 by mail, by email where an address is on file, or through the importer’s ACE portal account, and it also sends the request to the importer’s customs broker.
• Response window: the standard window is 30 days.
• It is not optional. If no response arrives in time, CBP can issue a CF-29 Notice of Action based on the information it already has.
• It is not a formal investigation. CBP has been directed not to use a CF-28 as notice of a formal investigation.

From Entry-by-Entry to Pattern-Based Review

Historically, a CF-28 was often tied to a single entry that an import specialist found unclear. Today, CBP’s targeting systems cross-reference entry data against historical filing patterns, and the White House’s August 2026 report on transshipment notes that these systems are beginning to incorporate artificial intelligence. Practitioners describe the kinds of anomalies these systems tend to surface:

• Classification inconsistencies: the same product classified differently across entries, or in a way that does not match the invoice description
• Valuation anomalies: similar goods declared at noticeably different values
• Origin inconsistencies: origin claims that do not line up with supply chain or production information
• Preference claim questions: free trade agreement claims that may not satisfy the rules of origin
• Trade remedy questions: transactions that suggest possible AD/CVD circumvention

A CBP officer reviews flagged entries and decides whether to issue a CF-28, issue a CF-29, or take another step.

What CBP’s Published Audit Figures Show

CBP does not publish CF-28 counts, so the increase in CF-28 activity rests on practitioner reports—including customs brokers and trade consultants who describe a noticeable rise since September 2025. CBP does publish audit statistics, which point in the same general direction:

Source: CBP Trade Statistics. The per-audit column is our calculation (collections divided by audits completed), not a CBP-published metric; collections in a given period can reflect findings from earlier years.

⚠️ Key Point: CF-28s are generally prompted by something in the entry data, not chosen at random—which is why the underlying question can extend beyond the single entry cited.

2 · What a CF-28 Typically Asks

A CF-28 usually maps to one of four areas.

1. Classification Does the tariff classification match what the merchandise actually is? CBP compares product descriptions, specifications, and technical characteristics with the declared classification.

2. Valuation Is the declared value complete? Common questions concern:

• Assists—materials, tools, or services supplied free or at reduced cost to the manufacturer
• Royalties—payments for patents, trademarks, or copyrights related to the goods
• Related-party pricing—whether the price reflects an arm’s-length transaction

3. Origin and Preference Does the claimed origin or trade-agreement preference hold up against production records? Areas that have drawn attention include:

• USMCA claims, which depend on rules of origin
• Section 301 exclusions, where the product must match the exclusion’s written description, not just the 10-digit tariff number
• Transshipment risk, particularly for goods routed through third countries

4. Other Compliance

• AD/CVD scope—whether the goods fall within an existing order
• Partner government agency requirements (FDA, EPA, CPSC, USDA, and others)
• Country-of-origin marking
• Forced labor due diligence under the UFLPA
• Section 232 derivative products, where metal-origin details (such as the country of smelt and cast for aluminum or melt and pour for steel) may be requested

⚠️ Key Point: The topics CBP asks about have broadened. Section 301 exclusion eligibility, Section 232 metal-origin details, and forced labor due diligence now appear in inquiries alongside the classification and valuation questions that have always been common.

Practitioners have also reported CF-28s in 2026 that relate to entries claimed in IEEPA refund (CAPE) declarations, where CBP compares the claim against entry data. This is a developing area, and the reports come from practitioners rather than from CBP.

3 · Where a CF-28 Sits in the Process

CF-28, CF-29, and the Penalty Process

The forms are related but not strictly sequential:

Audits and investigations can arise separately and are not simply a later rung on this ladder.

The Practical Distinction

A CF-28 gathers information. If the response shows the entry was correct, CBP can proceed with liquidation as filed. If CBP concludes the entry was wrong, it may issue a CF-29 proposing a change. A CF-28 is not required before a CF-29: CBP can issue a CF-29 directly, and may do so if a CF-28 goes unanswered.

Timing Considerations

Because the CF-29 window is shorter than the CF-28 window, the CF-28 stage is where the most time is generally available to assemble documentation and, if needed, evaluate options such as corrections or a prior disclosure. CBP’s authority to review entries generally extends five years.

⚠️ Key Point: A complete, well-supported CF-28 response can resolve the matter at the information-request stage. An incomplete or missing response leaves CBP to decide on the information it already has.

4 · The Executive Order 14411 Context

What the Order Says

Executive Order 14411, signed June 3, 2026, directs the Department of Homeland Security to require all importers of record to maintain “good standing” with CBP. CBP is to define good standing based on the importer’s and its affiliates’ history of compliance with customs and trade laws and payment of required customs liabilities, “among other relevant considerations.” An importer not in good standing may be barred from importing or from designating a customs broker to act on its behalf.

What Is—and Is Not—Settled

• CBP has not yet published a definition of good standing, so how it will treat CF-28 and CF-29 outcomes is not established.
• The order’s specific language about timely cooperation with CBP requests for information appears in its provisions on customs brokers, who may face maximum penalties for failing to cooperate in a timely manner, failing to conduct due diligence, or repeatedly representing noncompliant clients.
• For importers, the order points to compliance history as a central factor. A record of timely, accurate responses and corrections is the kind of history that standard is likely to consider, but no published rule says so yet.

Why This Matters: the practical takeaway is not that a CF-28 response is a formal good-standing test—it is not, based on what has been published—but that compliance history is becoming more consequential, and how inquiries are handled is part of that history.

5 · Applying Results Across Similar Entries

Why a Single-Entry Response May Not Be Enough

If a CF-28 reveals that a classification, value, or origin claim was wrong, the same issue may affect other entries of the same product. CBP’s reasonable-care expectations generally imply, and practitioners commonly advise, that the result of a determination be considered for analogous entries, not just the entry cited.

Where errors are confirmed, options for correcting other entries generally include:

• Post Summary Corrections (PSCs), which are generally available within a limited window after entry and before liquidation
• Protests, generally available within 180 days after liquidation
• A prior disclosure under 19 U.S.C. § 1592(c)(4), which can substantially reduce penalty exposure compared with CBP discovering the issue first

Considerations for a Narrow Response

A response that addresses only the cited entries may leave similar entries unexamined. If CBP later identifies the same issue elsewhere, the importer could face additional duties and interest, a reasonable-care question, and a less favorable compliance record.

⚠️ Key Point: Treating a CF-28 as a possible indicator of a pattern—and checking whether similar entries are affected—is generally more efficient than discovering the pattern later.

6 · Response Considerations

Understanding the Inquiry

Questions that often help frame a response:

• What data point likely prompted the inquiry?
• Is it a one-time error or a systemic issue?
• Does the CF-28 cite one entry or several?
• Is the focus classification, valuation, origin, or another topic?

Assembling the Response

A response is generally strongest when it is complete, accurate, and supported by documents. Commonly requested items include:

• Bills of lading
• Purchase orders and commercial invoices
• Proof of payment
• Production records (for origin and classification)
• Supplier declarations and certificates of origin
• Related-party pricing documentation, where applicable

Accuracy and Consistency

CF-28 responses become part of the record if a matter later proceeds to a penalty case, so the information provided should be accurate and consistent with the importer’s positions elsewhere. An error or omission in a response can itself become an issue.

Records and Reasonable Care

• Keep relevant records, including entry files, supplier communications, and internal classification analyses (entry records are generally required to be kept for five years)
• Document the steps taken to ensure accuracy, since reasonable care is the legal standard
• Do not alter or discard documents related to an open inquiry

Where Counsel Helps

For complex, high-value, or pattern-related inquiries, many importers involve customs counsel or experienced trade compliance advisers to review the response, assess the wider exposure, and evaluate corrections or a prior disclosure.

If a CF-29 Follows

Options generally include accepting CBP’s proposed action, submitting a rebuttal, or pursuing a PSC or protest, depending on the facts.

7 · Implementation Considerations for Logistics Providers

Customs brokers, forwarders, and 3PLs often handle CF-28s on behalf of clients. Considerations that tend to help:

• Client education: many importers regard CF-28s as routine paperwork; a short explanation of the response window and the pattern question can help clients prepare
• Response protocols and logs: clear ownership, a documentation checklist, and a log of inquiries, responses, and outcomes
• Contact information: because CF-28s can arrive by mail, email, or ACE, and are also sent to the broker, keeping importer and broker contact details current helps avoid missed deadlines
• Entry data quality: consistent descriptions, values, and classifications across entries reduce the anomalies that targeting systems flag
• Remediation support: where an error is confirmed, helping clients identify analogous entries, quantify duty and interest exposure, and document corrections
• Broker-specific exposure: because Executive Order 14411 names timely cooperation with CBP information requests in connection with broker penalties, documented procedures for tracking and answering requests are worth maintaining

8 · Conclusion: A Routine Form in a More Data-Driven Setting

Key Takeaways

The Takeaway

A CF-28 remains an information request, and a complete, well-documented response is often enough to resolve it. What has changed is the setting: more entries are being compared against patterns, topics are broader, and compliance history is gaining weight under Executive Order 14411. Importers and logistics providers that keep consistent entry data, clear records, and a defined process for inquiries are generally better placed to handle a CF-28 as the routine matter it is meant to be.

If your organization would like help reviewing entry data for consistency or building a response process for CBP inquiries, our trade compliance team is available.

This analysis reflects 19 CFR 151.11, CBP’s published trade statistics through late July 2026, Executive Order 14411 (91 FR 35125), and public commentary through October 2026. CBP does not publish CF-28 or CF-29 volumes; statements about increased issuance reflect practitioner reports. Response windows and procedures are subject to CBP guidance and the facts of each case. Importers should consult customs counsel and trade compliance professionals for guidance tailored to their specific inquiries.