CF-29 — Notice of Action
/ˌsiː ˈɛf ˌtwɛnti ˈnaɪn/
CBP Form 29 is a Notice of Action advising that CBP either proposes to change an entry's treatment or has already taken action, such as reclassification, revaluation, or assessment of additional duties. A proposed-action notice ordinarily provides a stated period to respond; an action-taken notice requires the importer to evaluate the available post-entry or protest remedy.
In Detail
The CF-29 is substantially more consequential than a CF-28, and it comes in two procedural forms: "Proposed Action" and "Action Has Been Taken." Where a CF-28 requests information, a CF-29 tells the importer that CBP either proposes to change an entry's treatment or has already made that change. Common CF-29 actions include: reclassifying an entry under a different HTS code; assessing additional duties based on a higher duty rate; applying a trade remedy overlay (Section 301, 232, or IEEPA) that the importer did not include; modifying the declared customs value; or changing the country of origin. A proposed-action notice gives the importer a formal opportunity to respond before the change is finalized; an action-taken notice means CBP has already implemented it, and the importer's available remedy depends on whether the entry has liquidated.
The importer's response to a proposed-action CF-29 is the most consequential step in the pre-liquidation process. A strong response includes all available evidence supporting the original classification: the product's technical specifications, GRI analysis, CROSS rulings covering the same or similar product, WCO Explanatory Notes, expert opinions, and any other legal authority relevant to the classification question. This is typically the stage at which a licensed customs broker, trade attorney, or classification specialist is engaged if they have not been already. A compelling, well-documented response can reverse or materially limit the proposed action.
Whether the CF-29 proposes a change or reflects one already taken, the importer's formal protest rights run from the entry's liquidation, not from the date of the notice itself. If the entry has not yet liquidated, a post-entry correction may still be available; once liquidation occurs, the importer has 180 days from the liquidation notice to file a CBP Protest (Form 19) challenging the determination. Missing the protest deadline forfeits the administrative remedy, leaving judicial appeal to the U.S. Court of International Trade as the only remaining avenue.
Classification Significance
A CF-29 represents CBP's first formal step toward enforcing what it believes is the correct classification. The quality of the importer's original classification documentation is most consequential at this stage — a well-reasoned, well-documented classification that CBP overrode provides the foundation for a strong CF-29 response and, if needed, a subsequent protest. A classification based on an undocumented tariff lookup is extremely difficult to defend at the CF-29 stage.
How Kanon Handles This
Kanon's Classification Support Package provides the documented classification evidence needed to respond to a CF-29. The immutable record of the determination — product attributes, the corpus version used, notes evaluated, the GRI rule applied, and CROSS rulings considered — is the evidentiary basis for the importer's response to CBP's proposed adverse action.