CF-29 — Notice of Action
CBP Form 29 (CF-29) is a formal Notice of Action from U.S. Customs and Border Protection indicating that CBP intends to take adverse action on a customs entry — most commonly reclassification under a different HTS code, assessment of additional duties, or adjustment of declared value. Importers generally have 20 days to respond before the proposed action becomes final.
In Detail
The CF-29 is substantially more consequential than a CF-28. Where a CF-28 requests information, a CF-29 notifies the importer that CBP has reached a tentative adverse determination and intends to act on it. 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. The notice gives the importer a formal opportunity to respond before the action is finalized.
The importer's response to a CF-29 is the most consequential step in the pre-protest 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.
If the CF-29 action proceeds and CBP liquidates the entry with the adverse classification, the importer has 180 days from the date of liquidation notice to file a CBP Protest (Form 19) challenging the determination. The liquidation date — not the CF-29 date — starts the 180-day protest clock. 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.