Increased Scrutiny Is Coming: What CF-28s and CF-29s Mean for Importers

U.S. Customs and Border Protection has increased scrutiny across import entries—and the questions are arriving after cargo clears, not before.

For importers, that timing matters. By the time a notice lands in your inbox, the entry has already been filed. The documentation is either ready or it isn’t. The classification is either supportable or it isn’t.

Two notices define most of this enforcement activity: the CF-28 and the CF-29. Understanding what they mean—and how to respond—is no longer optional.

A CF-28 is a Request for Information. CBP uses it when officers need more detail about an entry—such as classification, value, country of origin, or supporting documentation.

A CF-29 is a Notice of Action. That means CBP is proposing or taking action on an entry, often involving a change to classification, value, marking, or duty assessment.

For importers, the message is simple: compliance must be ready before the notice arrives. Please ensure you have all supporting documentation available and provide a thorough, detailed response to CBP’s request. Do not take this inquiry lightly, as it could lead to further scrutiny by CBP, including additional investigations or a potential audit. It is important that your response is accurate, complete, and supported by appropriate documentation to avoid raising additional concerns.

Why CBP Is Asking More Questions 

On June 3, 2026, President Trump signed the “Strengthening Customs Enforcement” Executive Order. This move directs CBP to increase penalties for repeat offenders, establish a 50% penalty floor, require minimum domestic assets or higher bond coverage for Importers of Record (IORs), and restrict foreign IORs.

This move will drive CBP to increase scrutiny, enforce enhanced vetting for customs brokers, and ramp up the issuance of requests for documentation and auditing.

CBP expects importers to use “reasonable care” when declaring accurate and timely entry data. CBP’s own informed compliance guidance makes clear that importers are responsible for providing correct information and maintaining reliable procedures.

This isn’t a new policy—it’s an accelerating trend. CBP’s modernization efforts, including more advanced data validation tools within ACE, mean that inconsistencies in entry data are being flagged faster and more systematically than ever before.

The importers most at risk are those who treat compliance as a clearance step rather than an ongoing discipline.

Common triggers for increased scrutiny include:

• Classification questions: CBP may ask why a specific HTS code was used and request product details, specifications, or prior rulings.
• Valuation concerns: CBP may review assists, royalties, related-party pricing, or invoice discrepancies.
• Country of origin verification: CBP may request production records, supplier documents, or manufacturing details.
• PGA requirements: Entries involving FDA, USDA, EPA, CPSC, or other agencies may face additional review.

What to Do When a CF-28 Arrives

A CF-28 should not be treated as routine paperwork. The response can shape what CBP does next.

A CF-28 response that raises more questions than it answers can escalate quickly—from an information request to a formal notice of action. The response you submit sets the tone for everything that follows.

Importers should:

• Act quickly: Review the request immediately and confirm the deadline with your broker.
• Gather complete evidence: Include invoices, product literature and pictures, manufacturing records, bills of materials, and origin support where relevant.
• Avoid partial answers: Incomplete or inconsistent responses may require further review.
• Coordinate with your customs broker: Ensure the response is accurate, organized, and aligned with the original entry.

What to Do When a CF-29 Arrives

A CF-29 means CBP is moving from questions to action.

If CBP changes the entry, importers may need to evaluate whether to accept the change or challenge it. CBP states that importers, brokers, or attorneys may contest certain CBP decisions by filing a protest within 180 days of liquidation. That window sounds generous—but organizing documentation, evaluating duty impact, and building a protest argument takes time. Starting that process late creates unnecessary risk.

Importers should:

• Review the action carefully: Identify exactly what CBP changed and why.
• Calculate the duty impact: Determine whether additional duties, fees, or penalties may apply.
• Preserve supporting records: Keep the documents needed for protest or future review.
• Discuss next steps with qualified professionals: Including your customs broker and, where needed, customs counsel.

How to Prepare Before CBP Calls

The best CF-28 or CF-29 strategy starts before the notice is issued.

Importers can reduce risk by:

• Auditing classifications: Confirm HTS codes are supported by product data and current guidance. If using more than one broker, ensure they are using the same HTS code for your products. Review your parts database from your broker at least once a year.
• Reviewing valuation practices: Especially related-party pricing, assists, discounts, and royalties.
• Mapping supply chains: Know where goods are made, not just where they ship from.
• Maintaining documentation: Keep records organized and accessible—not reconstructed under deadline pressure.
• Using available CBP guidance: CBP publishes informed compliance materials on classification, valuation, origin, and other trade topics.

One Step Further: A Proactive Compliance Review

The importers least disrupted by CF-28s and CF-29s share one thing in common: they didn’t wait for CBP to find problems first.

A proactive compliance review typically covers:

• Entry sampling: Reviewing a cross-section of recent entries for classification accuracy and valuation support.
• Documentation gaps: Identifying where supporting records are missing or inconsistent.
• Supplier verification: Confirming that country-of-origin documentation is complete and defensible.
• PGA exposure mapping: Understanding which agencies affect your product categories and whether requirements are being met consistently.

This isn’t about finding everything that’s wrong. It’s about knowing where the risks are before CBP does.

At Western Overseas, post-entry review is part of how we approach every client relationship—not a separate service triggered only when CBP sends a notice. From entry classification and valuation review to ISF filings, surety bonds, and PGA coordination, compliance is built into the process from the start.

Compliance Is the New Advantage

A CBP notice does not have to become a crisis.

But it does require discipline, documentation, and a clear response plan—before the notice arrives, not after.

At Western Overseas, we’ve worked with importers navigating CF-28s and CF-29s across a wide range of product categories, trade lanes, and compliance challenges. With decades of customs brokerage experience, full-service locations at major U.S. gateways, and teams that stay involved from entry to resolution, we help clients respond with confidence rather than scrambling for records.

The importers who handle enforcement activity best aren’t the ones who got lucky. They’re the ones who built the right compliance habits before CBP came calling.

Don’t Wait for the Notice

If your company is seeing more CBP questions—or wants to make sure it’s ready before they start—now is the time to strengthen your compliance process.

Contact Western Overseas to review your import compliance program before CBP sends the first question. We’ll help you evaluate classification support, documentation readiness, and post-entry procedures so enforcement activity doesn’t catch you off guard.