CF-28 — Request for Information
CBP Form 28 (CF-28) is a formal written request from U.S. Customs and Border Protection for additional information about a shipment's HTS classification, customs value, country of origin, or other customs matter. It is not a penalty or adverse determination — it is a request for clarification, typically requiring a response within 30 days.
In Detail
The CF-28 is one of CBP's primary information-gathering tools before taking formal action on an entry. CBP officers, import specialists, and Regulatory Audit personnel issue CF-28s when they need additional documentation to evaluate the correct classification, value, or origin of an imported good. The request typically asks for product specifications, technical manuals, bills of materials, laboratory test reports, manufacturer's declarations, or other evidence that supports or clarifies the classification reported on the entry summary.
CF-28 requests are not inherently adversarial — they do not presuppose that an error has been made. CBP issues CF-28s both to verify correct classifications and to investigate potentially incorrect ones. The significance of the request depends on context: a CF-28 from a port import specialist reviewing a routine entry is different from a CF-28 issued in connection with a Focused Assessment audit. In either case, the importer's response is legally significant and should be treated seriously.
Providing a complete, accurate, and well-documented response to a CF-28 is the appropriate course of action. This means submitting the product specifications, the classification rationale, any applicable CROSS rulings, and any technical evidence that supports the heading determination. A CF-28 response that demonstrates a systematic, well-reasoned classification methodology frequently closes the matter without further CBP action. Providing incomplete, inaccurate, or misleading information in a CF-28 response can escalate the matter significantly and affect the culpability finding if penalties are later assessed.
Classification Significance
A CF-28 is an early indicator that CBP has questions about a classification or entry. The quality of the importer's classification documentation determines the quality of its CF-28 response. An importer who performed a full GRI analysis, researched CROSS, and created a Classification Support Package at the time of entry can produce a complete, compelling response. An importer who assigned the HTS code from a lookup table will struggle to document the classification basis when asked.
How Kanon Handles This
Kanon's Classification Support Package is designed to answer the questions a CF-28 typically asks. The package documents the product attributes used in classification, the corpus provisions evaluated, the GRI rule applied, and the legal citations supporting the determination — precisely the information CBP requests when it wants to understand how a classification was reached.