CF-28
Request for Information.
Answered with broker-signed facts already on the file — commercial invoice, GRI rationale, PGA packet. Not a hopeful paragraph.
Audit defense & binding rulings
A CF-28 is not a status email.
CBP Form 28 is a Request for Information. CBP Form 29 is a Notice of Action. We isolate that work from live clearance and answer with broker-signed facts already on the file. When the merchandise is novel, we research, draft, and apply for a binding CROSS ruling before the next lot sails.
Book a consultation Free Entry Audit19 U.S.C. § 1592 attaches to the importer of record.
A Request for Information answered like a status email is how CF-29s and 19 U.S.C. § 1592 exposure grow. CBP Form 28 asks for facts. CBP Form 29 is a Notice of Action — not optional theater. Novel merchandise that sails without a CROSS path is a second problem.
We isolate audit work from live clearance. We answer with broker-signed facts already in the vault. If the file cannot defend the heading, we say so before the next lot moves.
01 · The method
CF-28. CF-29. CROSS. Isolated.
CF-29
Notice of Action.
Not optional. We treat it as a legal posture on the same licensed desk, isolated from live weekly clearance when required.
Isolate
Away from live ACE.
Audit defense does not share a keyboard with today’s 3461. The live file keeps moving. The notice gets its own clock.
CROSS
Before the next lot sails.
When the merchandise is novel — a new technical textile, a mixed tech article — we research, draft, and apply for a binding ruling before the next shipment.
02 · The real cost
19 U.S.C. § 1592 is not a slow reply.
Civil penalties attach to the importer of record. A CF-29 ignored is worse than a CF-28 answered late. We will not transmit a heading we cannot stand behind — and we will not answer CBP with vibes.
The GRI path and the commercial facts sit in the vault from classification. Audit defense starts there.
03 · On the file
The facts were already in the vault.
Audit defense is desk work. Isolated from live clearance. Broker-signed. CROSS when the merchandise is novel. A licensed broker still owns the response.
04 · What we need
Send the CF-28. We will say if the vault holds.
- The notice CF-28 or CF-29 — the whole document, not a screenshot of the subject line.
- Entry number The 7501 under review.
- Commercial invoice The invoice that supported the original filing.
- Classification rationale If we filed it, it is in the vault. If not, send what you have.
- Next-lot timing When the novel article is supposed to sail again — for CROSS planning.
On the same file
The desk around the notice.
Classification
Tariff classification
GRI written before ACE — the spine of the CF-28 answer.
PSC
PSC & protests
Different instrument from CF-28. Different clock.
Entry
3461 / 7501
The original digital entry is where the facts live.
Questions we actually get
The file before the appointment.
What is a CF-28?
CBP Form 28 is a Request for Information. We answer with broker-signed facts already on the file — not a status email.
What is a CF-29?
CBP Form 29 is a Notice of Action. It is not optional. We isolate that work from live clearance and treat it as a legal posture.
When do you seek a CROSS ruling?
When the merchandise is novel and the next lot will sail on an unsettled heading. We research, draft, and apply before that lot moves.
Does § 1592 attach to the broker?
Civil penalties under 19 U.S.C. § 1592 attach to the importer of record. We will not transmit an entry we cannot defend.
The desk
Bring one CF-28 and one entry number.
A consultation returns a defense posture and a flat fee. If the vault cannot answer the notice, we will say so in the memo.