A CF-28 just arrived: how brokers rebuild the entry file in 30 days

The email usually comes from the client, not from CBP. It has a PDF attached and one line of text: "Customs sent us this. What did we file and why?"

The attachment is a CBP Form 28, a Request for Information, on an entry you transmitted last year. The entry writer who keyed it may have moved on. The packet is somewhere in a shared drive or a filing system that has been migrated once since. The form gives a date, and the clock started on that date, not on the day it reached your desk.

This post is for the person at the brokerage who has to answer the client's question: the entry writer, the licensed broker who supervised the entry, or the owner. It covers what a CF-28 is, how long you have, who answers it, and how to rebuild the file so the answer is quick and accurate.

What a CF-28 is, and what it isn't

CBP describes the form's purpose plainly. When the invoice or other documentation does not give enough information for appraisement or classification, including for trade agreement, preference or special-provision claims, CBP may ask for more using CBP Form 28. The form is sent to importers, exporters, producers or their agents, and CBP cites 19 CFR 151.11 as its authority to collect the information (Federal Register, 8 May 2026).

So a CF-28 is a question, not an accusation. It is also not optional. Trade counsel make the point that if no answer arrives in time, CBP can move ahead on the information it already has, usually by issuing a CBP Form 29 that decides the question (Torres Trade Law, secondary source). Silence doesn't pause anything. It hands the decision to the reader of an incomplete file.

The 30-day clock, and when to ask for more time

The form itself sets the timeline. It tells the recipient to contact the CBP officer named on the front of the form if a reply cannot be made within 30 days of the date of the request, or if they want to discuss any of the questions (CBP Form 28).

Three practical consequences for the desk:

• Count from the date of the request, printed on the form, not from the day the client forwarded it. A client who sat on it for a week has used a week.
• Ask early, not on day 29. If rebuilding the file or getting answers from the supplier will take longer, the named officer is the person to call. Make the request while there is still time for a "no".
• Put any extension in writing. If the officer agrees by phone, confirm the new date in an email and keep that email in the file.

Who does what

The CF-28 is addressed to the importer of record, or to an agent acting for them. The importer owns the answer: it's their entry, their goods and their liability. In practice, though, the broker usually holds the file the answer depends on: the entry summary as transmitted, the packet it was built from, and the email trail behind any judgement call.

Two rules shape how you hand that over:

• Client records are confidential. Under 19 CFR 111.24, a broker may share a client's records with that client, their surety on the entry and US government officers. Anyone else, such as a consultant the client has hired to draft the response, needs the client's written authorization, a subpoena or a court order. Get the authorization in writing before you send the file to a third party.
• The broker keeps records too. Under 19 CFR 111.23, broker records generally have to be kept for at least 5 years after the date of entry, within the customs territory of the United States.

Agree early on who sends the response to CBP. If the brokerage drafts it, the importer should still read and approve every factual statement before it goes.

How to respond to a CF-28: rebuild the file first

Work in this order. The aim is to recreate what the entry writer saw on the day they keyed it, not what the client's records say now.

1. The entry summary as transmitted. Pull the version CBP accepted, plus any rejects and resubmissions before it and any post-summary corrections after it. The CF-28 asks about what CBP has on file, so start from that.
2. The packet it was built from. The commercial invoice, the packing list and the bill of lading or air waybill, in the versions you had at the time. If the supplier sent a revised invoice after filing, keep both and note which one the entry used. For what the invoice should have shown, see what 19 CFR 141.86 requires on a commercial invoice.
3. The decision trail. Every email or note that explains a value, quantity, origin or classification choice that isn't obvious from the documents alone. This is the part most often missing: the decision was made on a phone call, or in an email thread with someone who has since left.
4. Classification notes. Any ruling, prior entry or product description the writer relied on for the HTS number.
5. What the CF-28 asks for that the broker never had. Proof of payment, supplier cost breakdowns, production records, samples. List these for the client straight away, because they take longest to collect.
6. A field-to-source map. For each field the CF-28 questions, note the document and page it came from. Without this, the response relies on memory.

If the rebuild shows the entry was wrong, not just poorly documented, the response has to deal with that. Which correction route is still available depends on where the entry stands; see PSC, protest or prior disclosure. Don't pick one without the importer and, usually, their counsel.

Recordkeeping: five years, with one exception people miss

The general rule is in 19 CFR 163.4: records required by CBP must be kept for 5 years from the date of entry, or 5 years from the activity that required the record.

Packing lists are the exception. Section 163.4 requires them only for 60 calendar days from the end of the release or conditional release period, whichever is later. If CBP has issued a demand for redelivery, the 60 days run from redelivery or the latest redelivery date in the demand.

A CF-28 on a year-old entry can therefore ask about a quantity when the one document that shows how the cartons were packed is no longer required to exist. If your office keeps the whole packet for five years, this never comes up. If it purges by document type, check what the policy does to packing lists.

When to call a customs attorney

Many CF-28s are routine: a request for a spec sheet, a proof of payment, a clarification of a description. Some aren't. Suggest the importer involves counsel before responding when:

• the questions point to value, origin or classification across many entries, not just this one;
• the rebuild shows an error that may have underpaid duty;
• the request touches antidumping or countervailing duties, a trade agreement claim, or forced-labour concerns;
• the importer is considering a prior disclosure.

The broker's job is to supply an accurate, complete file quickly. Legal strategy is the importer's call, made with their lawyer.

CF-28 vs CF-29: if the answer doesn't settle it

A CBP Form 29 is a Notice of Action. Under 19 CFR 152.2, if CBP believes the entered rate or value is too low, or the quantity is higher than entered, and the estimated increase in duty on the entry is more than $15, it must notify the importer on Form 29. Liquidation is then generally not held back for more than 20 days from the date the notice is mailed. A CF-29 marked "action proposed" is the importer's last informal chance to argue before liquidation. One marked "action taken" moves any disagreement to the protest process, which the corrections post covers (Great Lakes Customs Law, secondary source).

The file is also your supervision record

A complete, well-kept entry file does more than answer this CF-28. It shows how the licensed broker reviewed the work, which is the subject of responsible supervision and control. A file you can rebuild in an afternoon is good evidence that someone was supervising.

The slowest step is almost always the field-to-source map. EntryWrite records which page of which document each entry field came from, so that question can be answered months later without rebuilding it by hand.