CBP Form 28: Request for Information Explained for Importers

Key Points

• CBP Form 28, Request for Information, is CBP's written request for documents or facts it needs to appraise or classify goods already entered; it is not an audit notice and not a penalty notice.
• A CBP Form 28 normally carries a 30-day response window and is delivered and answered through ACE Forms in the ACE Portal.
• A late, thin, or inconsistent answer to a CBP Form 28 commonly produces a CBP Form 29, Notice of Action, with a rate advance or value change at liquidation.
• The importer of record owns the response; the broker coordinates gathering invoices, contracts, specifications, and origin proof.
• Treat every CBP Form 28 as audit groundwork, because CBP's records access authority under 19 U.S.C. 1509 stands behind the request; confirm current timing and portal procedures with CBP before acting.

On this page

1. What CBP Form 28 is
2. At a glance
3. Where CBP Form 28 sits in the entry lifecycle
4. Who is responsible for answering CBP Form 28
5. How CBP Form 28 is delivered and answered in ACE
6. What goes wrong with CBP Form 28 and what it costs
7. How CBP Form 28 relates to other CBP forms
8. Frequently asked questions
9. What importers and brokers should do
10. Key references

CBP Form 28, Request for Information, is U.S. Customs and Border Protection's written request to an importer or its broker for documents or facts CBP needs to appraise or classify entered goods. It is issued by the Center of Excellence and Expertise handling the importer's account, normally after the entry summary has been filed and before the entry liquidates, and it is delivered and answered through ACE Forms in the ACE Portal. A CBP Form 28 is an information request, not an audit, a summons, or a penalty action, but the answer shapes what CBP does next.

The links in this article go to the primary documents: the CBP form and guidance pages, the statute, and the official tariff schedule themselves. Read the source. Information here is current as of September 2026, and readers should confirm current status and procedures with CBP before acting.

At a glance

• Full name: CBP Form 28, Request for Information.
• Who prepares or uses it: CBP issues it; the importer of record answers, usually with the customs broker coordinating the response.
• When in the lifecycle: after entry summary, usually before liquidation.
• Response window: 30 days as stated on the form; confirm the date printed on your specific CBP Form 28.
• System or channel: ACE Forms in the ACE Portal (Receive and Respond to CBP Forms, October 2025); the ES-013 CBP Form 28, 29, 4647 Status Report tracks open items.
• Governing authority: CBP's records and information authority under 19 U.S.C. 1509; issued by the Center.
• Related terms: CBP Form 29, Notice of Action; CBP Form 19, Protest; CBP Form 3461, Entry/Immediate Delivery.

Where does CBP Form 28 sit in the entry lifecycle?

CBP Form 28 arrives after the goods are long released and the entry summary is on file, which is exactly why it catches importers off guard. The release step happened earlier, through CBP Form 3461, Entry/Immediate Delivery, the release request asking CBP to release imported cargo from custody before the entry summary, now transmitted electronically as ACE Cargo Release data. See our explainer on CBP Form 3461 for that stage. By the time a CBP Form 28 issues, the entry is in the Center's hands and the open question is whether the declared classification, value, or origin will stand at liquidation.

Because a CBP Form 28 usually precedes liquidation, the response is the importer's best and cheapest opportunity to put the record straight. Once liquidation occurs on terms the importer disputes, the path shifts to protest, which is slower and more formal.

Why the Center sends a CBP Form 28

A CBP Form 28 is typically driven by something the Center cannot resolve from the entry data alone: a classification that does not match the product description, a value that looks low against comparable entries, a claim of preferential or non-preferential origin that needs supporting proof, or an assist, royalty, or related-party pricing question. The request names the documents CBP wants, which commonly include commercial invoices, purchase contracts, product specifications, bills of materials, and origin evidence.

Who is responsible for answering CBP Form 28?

Responsibility for a CBP Form 28 sits with the importer of record, even when the broker receives the notice first and drafts the reply. The importer holds the underlying commercial records, the engineering specifications, and the supplier correspondence that CBP is actually asking for, and the importer is the party whose duty liability moves if CBP changes classification or value. The broker's job is coordination: confirming the request is routed to the right person inside the importer, assembling the package, checking that the answer is internally consistent with what was declared, and transmitting on time.

Where the importer identity on the entry is wrong or stale, a CBP Form 28 can also surface the need to update records through CBP Form 5106, Create/Update Importer Identity Form, which registers or updates an importer of record or ultimate consignee identity in ACE. Duty exposure raised by a CBP Form 28 ultimately runs against the obligations secured by CBP Form 301, Customs Bond, the surety bond, single transaction or continuous, that secures duties, taxes, fees, and compliance obligations to CBP.

How is CBP Form 28 delivered and answered in ACE?

CBP Form 28 is delivered and answered through ACE Forms in the ACE Portal, the electronic channel CBP describes in its Receive and Respond to CBP Forms guidance dated October 2025. Portal users with the right account role receive the request, view the documents CBP wants, upload the response, and see the status of each open item. Importers who have never provisioned ACE Portal access should do so before a CBP Form 28 lands, because provisioning takes time the 30-day window does not give back.

The ES-013 CBP Form 28, 29, 4647 Status Report in ACE lets account holders track open and closed requests across their entries. Compliance teams should pull ES-013 on a routine cycle rather than relying on someone noticing an email, since a CBP Form 28 that sits unread still runs its clock.

Building a response package

Answer exactly what the CBP Form 28 asks, in the order asked, with a short cover narrative that explains what each attachment proves. Send the commercial documents that support the declared classification and value: invoices, contracts and purchase orders, specifications or technical data sheets, production records, and origin documentation. If a document does not exist, say so plainly and explain what does exist instead. Silence on a requested item reads as a gap.

What goes wrong with a CBP Form 28 and what does it cost?

The most expensive failure with a CBP Form 28 is no answer at all, followed closely by an answer that contradicts the entry as filed. When CBP receives nothing useful, it decides on the information it has, and the usual result is CBP Form 29, Notice of Action: CBP's notice that it proposes or has taken action on an entry, such as a rate advance, reclassification, or value change. That is not a bill, penalty notice, or protest decision, but it changes the duty owed at liquidation. Our companion pieces on answering a CBP Form 28 and on CBP Form 29 options go deeper on each step.

The second failure is treating a CBP Form 28 as a one-entry problem. A classification or valuation issue that CBP flags on one entry almost always exists across a product line and across prior entries, which is why experienced compliance managers treat every CBP Form 28 as audit groundwork and interest. CBP's authority to examine records under 19 U.S.C. 1509 is the backdrop to the request. If the review of your own records shows the declared treatment was wrong, evaluate whether a prior disclosure is appropriate before CBP broadens its look.

A third failure is answering fast but sloppily: mismatched part numbers, invoices that do not tie to the entry lines, or a classification argument with no reference to the tariff text. Check the language of the relevant headings in the Harmonized Tariff Schedule and quote it.

How does CBP Form 28 relate to other CBP forms?

CBP Form 28 is the first move in a sequence that can run through several other forms. If CBP acts, it issues CBP Form 29, Notice of Action. If the importer disagrees with the eventual decision at liquidation, the route is CBP Form 19, Protest, filed on paper or through the ACE Protest module to contest a CBP decision under 19 U.S.C. 1514 on liquidation, classification, value, or rate; a protest is not the same as a post summary correction.

CBP Form 28 can touch entries that moved or were stored under other regimes. In-bond movements filed on CBP Form 7512, Transportation Entry and Manifest of Goods Subject to CBP Inspection and Permit, now electronic, may be part of the history CBP asks about. Foreign-trade zone importers may need admission records from CBP Form 214, Application for Foreign-Trade Zone Admission and/or Status Designation, which elects zone status, or activity records from CBP Form 216, Application for Foreign-Trade Zone Activity Permit, which requests CBP approval to manipulate, manufacture, exhibit, or destroy merchandise inside a zone. Drawback claimants should note that CBP Form 7551, Drawback Entry, and CBP Form 7552, Delivery Certificate for Purposes of Drawback, were abolished under TFTEA drawback, with claims now filed electronically in ACE and transfers documented by records rather than certificates; a CBP Form 28 on an underlying import can still unsettle a drawback position built on it.

Frequently asked questions

Is a CBP Form 28 an audit?

No. A CBP Form 28 is a Request for Information about specific entered goods, not a Focused Assessment notice, a summons, or a penalty proceeding. It is still prudent to treat a CBP Form 28 as audit groundwork, because the answer tells CBP how well the importer's records and processes hold up.

How long do I have to respond to a CBP Form 28?

A CBP Form 28 states a 30-day response window. Read the date on the specific form you received and confirm timing with the issuing Center if the deadline is unclear or unworkable.

What happens if I ignore a CBP Form 28?

If a CBP Form 28 goes unanswered, CBP decides on the information it already has, which commonly means a CBP Form 29, Notice of Action, proposing or taking a rate advance, reclassification, or value change that flows through to liquidation.

Can I ask for more time on a CBP Form 28?

Importers routinely contact the issuing Center when records take longer to assemble than the CBP Form 28 window allows. Whether an extension is granted and how to request it should be confirmed directly with the Center identified on the form.

Where do I file the response to a CBP Form 28?

Responses to a CBP Form 28 are submitted through ACE Forms in the ACE Portal, following CBP's Receive and Respond to CBP Forms guidance of October 2025. Use the ES-013 CBP Form 28, 29, 4647 Status Report to confirm the item shows as answered.

What importers and brokers should do

• Provision ACE Portal access and assign named owners for ACE Forms now, so a CBP Form 28 is seen the day it issues rather than the week before the deadline expires.
• Run the ES-013 CBP Form 28, 29, 4647 Status Report on a fixed schedule and reconcile it against your broker's notifications.
• Build a standing response template: cover narrative, tariff text citation, invoices, contracts, specifications, and origin proof, with a named reviewer who checks the answer against the entry as filed.
• When a CBP Form 28 exposes an issue across a product line, quantify the exposure on prior entries and decide on corrective action before liquidation closes the cheapest options; our duty calculator and 2026 tariff code overview can help size the difference between competing classifications.

Key references

• CBP forms library: official source for CBP Form 28, Request for Information, and related CBP forms.
• 19 U.S.C. 1509: CBP's authority to examine records and require information from importers.
• ACE and Automated Systems: CBP's ACE Portal pages, including Receive and Respond to CBP Forms guidance (October 2025) and ACE reports such as ES-013.
• Harmonized Tariff Schedule of the United States: the tariff text to cite when defending a classification in a CBP Form 28 response.
• Electronic Code of Federal Regulations: current text of the customs regulations governing entry, appraisement, and liquidation.