CBP Form 29: Notice of Action Explained for Importers

Key Points

• CBP Form 29, Notice of Action, is CBP's written notice that it proposes to change, or has already changed, something on your entry: classification, value, rate of duty or other appraisement element.
• A proposed action on CBP Form 29 normally carries a 20 day window to respond with evidence or argument; an action taken means CBP has decided and liquidation will follow at the changed terms.
• Missing the 20 day rebuttal window does not end your rights, but it forfeits the cheap path: after liquidation your remedy is a protest under 19 U.S.C. 1514, filed on CBP Form 19 within 180 days after liquidation under 19 CFR part 174.
• CBP Form 29 frequently follows a CBP Form 28, Request for Information, and repeated notices across entries are a signal of elevated audit and enforcement attention.
• This article is current as of September 2026; confirm current procedures and timing with CBP or the governing regulation before you act.

On this page

1. What CBP Form 29 is
2. At a glance
3. Where CBP Form 29 comes from and who issues it
4. Proposed action versus action taken: what is the difference?
5. How is CBP Form 29 delivered and answered?
6. What happens if you do not respond to CBP Form 29?
7. How CBP Form 29 interacts with other CBP forms
8. Common CBP Form 29 mistakes
9. Frequently asked questions
10. What importers and brokers should do
11. Key references

The links in this article go to the primary documents: the statute, the regulations and CBP's own form and program pages themselves. Read the source.

CBP Form 29, Notice of Action, is CBP's formal notice to an importer of record that it proposes to take, or has taken, action on an entry, such as a rate advance, a reclassification or a change in appraised value. It is issued by a CBP Center of Excellence and Expertise before liquidation, often after a CBP Form 28, Request for Information, or after the Center's own review of the entry. CBP Form 29 is not a bill, not a penalty notice and not a protest decision; it is the step that tells you the entry will liquidate differently than filed unless something changes.

At a glance

• Full name: CBP Form 29, Notice of Action (listed by CBP with the identifier ES-013).
• Who prepares or uses it: prepared and issued by CBP; received and acted on by the importer of record, usually relayed by the customs broker.
• When in the lifecycle: after entry summary filing and before liquidation.
• System or channel: issued through ACE Forms; delivery method and notification settings should be confirmed with CBP.
• Governing authority: CBP's pre-liquidation review authority; the downstream remedy sits in 19 U.S.C. 1514 and 19 CFR part 174.
• Response window: 20 days for a proposed action; an action taken carries no rebuttal window.
• Related terms: CBP Form 28, Request for Information; CBP Form 19, Protest; CBP Form 3461, Entry/Immediate Delivery; CBP Form 301, Customs Bond.

Where CBP Form 29 comes from and who issues it

CBP Form 29 is issued by the Center of Excellence and Expertise that owns your importer account, not by the port that released the cargo. The Center reviews entry summaries by industry, and a Notice of Action typically arises one of two ways: the Center asked questions on a CBP Form 28, Request for Information, which is CBP's written request to an importer or its broker for documents or facts needed to appraise or classify entered goods, and the answer did not support the entry as filed; or the Center reviewed the entry on its own and reached a different conclusion about classification, value, quantity or duty rate. Either way, CBP Form 29 is a pre-liquidation document. It exists because CBP must tell the importer before it changes the terms of an entry that has not yet liquidated.

Practically, CBP Form 29 is the moment the file stops being routine. It means a CBP officer has formed a view about your merchandise that differs from yours, and that view will become the liquidated result unless you displace it with facts.

Proposed action versus action taken: what is the difference?

CBP Form 29 arrives in two flavors, and reading which one you received is the first thing to do. A proposed action states what CBP intends to do and invites the importer to respond, normally within 20 days, with documents, argument or agreement. Nothing has been changed yet. This is the low-cost window: a clear response with commercial invoices, product specifications, ruling references or a value reconciliation can persuade the Center to drop or modify the proposal without any duty consequence.

An action taken on CBP Form 29 states that CBP has already made the change. There is no rebuttal window. The entry will liquidate at the changed classification, value or rate, and the increased duties become payable through the liquidation bill. At that point the only formal contest route is a protest.

How the 20 day window is used well

Twenty days is short when the answer depends on a factory in another time zone. Successful CBP Form 29 responses are narrow: they identify exactly which element CBP got wrong, attach the specific document that proves it, and cite the legal basis for the entered treatment. A response that restates the entry without new evidence rarely changes a proposed action.

How is CBP Form 29 delivered and answered?

CBP Form 29 is issued through ACE Forms, the same channel CBP uses for CBP Form 28, so the notice generally lands with the party set up to receive Center correspondence in ACE. That is often the broker, which is why account setup matters: if your ACE contact data is stale, the 20 day proposed-action window can burn while the notice sits unread. Importer identity data is maintained on CBP Form 5106, Create/Update Importer Identity Form, which registers or updates an importer of record or ultimate consignee identity in ACE, and keeping that record current is part of making sure notices reach a live person.

The broker's role on CBP Form 29 is to relay the notice promptly, explain what CBP is proposing in plain terms, and assemble the response. The decision to accept or contest belongs to the importer of record, because the importer carries the duty liability and the recordkeeping obligation behind the answer. Confirm current submission mechanics for responses in ACE with CBP or your assigned Center, since channels change.

What happens if you do not respond to CBP Form 29?

If you let a proposed action on CBP Form 29 lapse, CBP proceeds. The entry liquidates as CBP described, the increased duties are billed at liquidation, and the obligation is secured by the customs bond, CBP Form 301, the surety bond, single transaction or continuous, securing duties, taxes, fees and compliance obligations to CBP. Your remaining remedy is to protest the liquidation under 19 U.S.C. 1514, filed on CBP Form 19, Protest, the form used on paper or through the ACE Protest module to contest a CBP decision, within 180 days after liquidation, under the procedures in 19 CFR part 174.

That path works, but it is slower and more expensive than answering CBP Form 29 in time. You are arguing after money has been billed, on a record CBP has already closed, with formal pleading requirements. Treat the 20 day window as the real deadline.

How CBP Form 29 interacts with other CBP forms

CBP Form 29 sits late in a chain that begins with release. The release request itself is CBP Form 3461, Entry/Immediate Delivery, now transmitted electronically as ACE Cargo Release data, and classification and value questions surface only after the entry summary. When CBP wants facts, it sends CBP Form 28; when CBP has reached a conclusion, it sends CBP Form 29; when you want to overturn the liquidated result, you file CBP Form 19.

CBP Form 29 does not appear only on ordinary consumption entries. Merchandise moved in bond on CBP Form 7512, Transportation Entry and Manifest of Goods Subject to CBP Inspection and Permit, or admitted to a foreign-trade zone on CBP Form 214, Application for Foreign-Trade Zone Admission and/or Status Designation, with zone activity permitted on CBP Form 216, Application for Foreign-Trade Zone Activity Permit, all eventually produces a consumption entry that a Center can review. Drawback is a separate world: the paper drawback claim on CBP Form 7551 and the delivery certificate on CBP Form 7552 were abolished under TFTEA, and drawback issues are handled through their own claim process rather than through CBP Form 29.

Finally, do not confuse CBP Form 29 with penalty or seizure paperwork. CBP Form 5955A and CBP Form 6084 are different instruments with different consequences; CBP Form 29 is an entry-level appraisement and classification notice.

Common CBP Form 29 mistakes

The most expensive CBP Form 29 mistake is treating a proposed action as informational. The second is answering with commercial arguments instead of legal and factual ones: CBP does not care that the reclassification hurts margin, it cares whether the goods meet the terms of the heading. The third is inconsistency, where the response to CBP Form 29 contradicts what was said in the earlier CBP Form 28 answer or in a prior ruling request, which invites a wider review.

A pattern of CBP Form 29 notices across your entries is itself a finding. Repeated rate advances on the same commodity suggest a systemic classification or valuation problem, and that is what draws audit attention. If the notice reveals errors on other unliquidated or liquidated entries, evaluate whether a prior disclosure is appropriate before CBP finds them.

Frequently asked questions

Is CBP Form 29 a bill?

No. CBP Form 29 is a notice of proposed or taken action on an entry. Any money owed arrives later as a liquidation bill once the entry liquidates at the changed classification, value or rate.

How long do I have to respond to CBP Form 29?

A proposed action on CBP Form 29 normally allows 20 days to respond. An action taken has no response window; the contest route is a protest on CBP Form 19 under 19 U.S.C. 1514 within 180 days after liquidation. Confirm the exact date printed on your notice.

Can my broker answer CBP Form 29 for me?

Yes, a broker with a valid power of attorney routinely prepares and submits CBP Form 29 responses, but the importer of record owns the position taken and the underlying records. Review the substance before it goes to CBP.

Does agreeing with CBP Form 29 create liability on past entries?

Accepting a CBP Form 29 action resolves that entry, but the same classification or valuation reasoning usually applies to identical goods entered earlier and later. Review your entry history and decide how to correct unliquidated entries and whether earlier ones need disclosure.

What importers and brokers should do

• Confirm who receives ACE Forms correspondence for your importer account and set an internal rule that a CBP Form 29 goes to the compliance owner the day it arrives.
• On receipt, read whether the CBP Form 29 is a proposed action or an action taken, calendar the 20 day date immediately, and build the response around documents rather than narrative.
• If the action is taken and you disagree, calendar 180 days after liquidation for a protest on CBP Form 19 under 19 CFR part 174 and start assembling the record now.
• Run the CBP Form 29 issue across your other entries of the same product using your tariff classification records, and fix the root cause before the next Center review.

Key references

• 19 U.S.C. 1514: the statute governing finality of CBP decisions and the right to protest a liquidation.
• 19 CFR part 174: the protest regulations, including filing procedures behind CBP Form 19.
• CBP forms library: the official source for CBP Form 29 and related forms, including the ES-013 identifier.
• CBP ACE program pages: guidance on ACE Forms, ACE Portal accounts and trade account setup.
• Harmonized Tariff Schedule of the United States: the tariff text to check when a CBP Form 29 proposes a reclassification.
• CBP Form 3461: Entry/Immediate Delivery: where the entry lifecycle that leads to a CBP Form 29 begins.