CBP Form 4647: Notice to Mark and/or Redeliver Explained

Key Points

• CBP Form 4647, Notice to Mark and/or Redeliver, is CBP's order that goods or their containers are not legally marked with country of origin and must be marked, redelivered, exported or destroyed under 19 CFR 134.51.
• The importer has 30 days from the date of the notice to respond, a period CBP may extend for good cause.
• Ignoring CBP Form 4647 exposes the importer to a liquidated damages claim equal to the entered value of the unmarked goods under the bond conditions at 19 CFR 113.62(d) and (e), plus the 10 percent marking duty at 19 CFR 134.2 assessed at liquidation.
• Certifying marking that was never done is a false statement that can draw 19 U.S.C. 1592 exposure, so the certificate must match reality and be supported by samples.
• As of September 2026 brokers track CBP Form 4647 status through ES-013 and relay deadlines to the importer; confirm current filing channels and timelines with CBP before acting.

On this page

1. What CBP Form 4647 is and where it comes from
2. At a glance
3. When is CBP Form 4647 issued in the entry lifecycle?
4. What are the importer's options under CBP Form 4647?
5. How is CBP Form 4647 transmitted and tracked?
6. What does it cost to ignore CBP Form 4647?
7. How CBP Form 4647 relates to other CBP forms
8. Frequently asked questions
9. What importers and brokers should do
10. Key references

CBP Form 4647, Notice to Mark and/or Redeliver, is CBP's written notice that imported articles or their containers are not marked with the country of origin as required by 19 U.S.C. 1304, ordering the importer to mark the goods under CBP supervision, or to redeliver, export or destroy them. It is issued by the Center of Excellence and Expertise or the port after examination, often after the merchandise has already been released, and it sits at the post-release stage of the entry lifecycle, before liquidation. The importer of record is responsible for responding, and the customs broker typically receives, tracks and relays the notice.

The links in this article go to the primary documents: the regulations, the statute and the official CBP pages themselves. Read the source.

At a glance

• Full name: CBP Form 4647, Notice to Mark and/or Redeliver.
• Who prepares or uses it: CBP (the Center or the port) issues it; the importer of record responds, usually through the customs broker.
• When in the lifecycle: after examination, commonly after release and before liquidation.
• System or channel: on the paper form or its electronic equivalent through ACE Forms; broker status tracking through ES-013.
• Governing authority: 19 U.S.C. 1304 and 19 CFR part 134, specifically 19 CFR 134.51 through 134.54.
• Response window: 30 days from the date of the notice, extendable for good cause.
• Financial exposure: liquidated damages equal to the entered value of the unmarked goods; the 10 percent marking duty under 19 CFR 134.2.
• Related terms: CBP Form 5955A, CBP Form 6084, CBP Form 7553, CBP Form 4455.

What CBP Form 4647 is and where it comes from

CBP Form 4647 exists because 19 U.S.C. 1304 requires that every article of foreign origin imported into the United States be marked legibly, indelibly and permanently, in a conspicuous place, with the English name of the country of origin, so the ultimate purchaser can read it. When a CBP officer or import specialist examines merchandise and finds that the articles or their containers are not legally marked, 19 CFR 134.51 directs that the importer be notified and that the merchandise be marked, redelivered, exported or destroyed. CBP Form 4647 is the vehicle for that notification.

The regulation does not treat marking as a discretionary label preference. CBP Form 4647 is an order with a deadline attached and a bond behind it. The related sections fill in the mechanics: 19 CFR 134.52 covers certified marking of articles when CBP allows certification in lieu of supervision, 19 CFR 134.53 addresses articles released from CBP custody, and 19 CFR 134.54 addresses articles released and then not marked, exported or destroyed as required.

When is CBP Form 4647 issued in the entry lifecycle?

CBP Form 4647 is issued after examination, which in practice means it often arrives after the shipment has already been released and moved to the importer's warehouse or a distribution center. That timing is the source of most of the operational pain: the goods are no longer sitting at the port, they may have been broken into smaller lots, and some may already be in the hands of customers.

The 30 day clock in 19 CFR 134.51 runs from the date of the notice, not from the date the broker forwards it or the date the warehouse manager opens the email. CBP may extend the period for good cause, but an extension has to be requested, not assumed. Because CBP Form 4647 typically lands post-release, the practical first step is locating the merchandise before deciding which of the available responses is realistic.

What are the importer's options under CBP Form 4647?

CBP Form 4647 gives the importer a defined set of responses, and the importer must complete one of them within the 30 day window. The options are to mark the articles or containers under CBP supervision, to certify the marking where CBP permits certification with supporting samples, or to redeliver the merchandise to CBP custody, export it, or destroy it.

Marking and certification

Where CBP allows the importer to mark without an officer physically present, 19 CFR 134.52 provides for a certificate of marking, and CBP commonly asks for samples of the marked article so the Center can verify that the marking is legible, indelible, permanent and conspicuous. A certificate that overstates what was done is not a paperwork shortcut; it is a false statement, and a false certificate of marking brings 19 U.S.C. 1592 exposure for the importer and, potentially, anyone who assisted in submitting it.

Redelivery, export or destruction

If marking is impractical, the importer can redeliver the goods to CBP custody, export them, or destroy them. Redelivery means physically returning the merchandise, which is why the demand is backed by the bond conditions at 19 CFR 113.62, specifically paragraphs (d) and (e), under which the principal agrees to redeliver merchandise on CBP demand. Where the merchandise has been sold, consumed, or otherwise cannot be produced, redelivery becomes impossible and liquidated damages follow.

How is CBP Form 4647 transmitted and tracked?

CBP Form 4647 may be issued on the paper form or through its electronic equivalent in ACE Forms, and the broker normally monitors status through ES-013. Brokers should treat the ES-013 view as a working queue rather than an archive: each open CBP Form 4647 has a running 30 day deadline, a responsible importer contact, and an eventual proof-of-compliance package.

Because channels and screen names change, confirm the current transmission path and any ACE Forms behavior in the current ACE CATAIR documentation or directly with CBP before building a process around it. The substantive obligation in 19 CFR 134.51 does not change with the channel; only the plumbing does.

What does it cost to ignore CBP Form 4647?

Failing to respond to CBP Form 4647 has two distinct financial consequences that run in parallel. First, when the importer does not mark, redeliver, export or destroy as ordered, CBP demands liquidated damages equal to the entered value of the unmarked goods under the redelivery conditions of the bond at 19 CFR 113.62(d) and (e). That demand arrives as CBP Form 5955A, Notice of Penalty or Liquidated Damages Incurred and Demand for Payment, the Fines, Penalties and Forfeitures notice claiming a penalty or bond liquidated damages.

Second, the 10 percent marking duty under 19 CFR 134.2 is assessed at liquidation on articles not marked as required. That is an additional duty on the entry, and it is billed as money owed to CBP, typically on CBP Form 6084, CBP's bill form, the mailed bill for money owed to CBP such as supplemental duties, taxes, fees and interest after liquidation. CBP Form 5955A and CBP Form 6084 are different instruments: one is a claim, the other is a bill.

Layered on top, a false certificate of marking submitted in response to CBP Form 4647 creates exposure under 19 U.S.C. 1592. If an importer discovers after the fact that a certificate was inaccurate, the options for coming forward are worth reviewing; see our overview of CBP prior disclosure.

How CBP Form 4647 relates to other CBP forms

CBP Form 4647 is frequently confused with other CBP notices, and the distinctions matter because the response obligations differ. CBP Form 4647 is not CBP Form 28, a request for information, and it is not a partner government agency redelivery notice issued for a product-safety or food-safety reason. CBP Form 4647 is specifically about country of origin marking under 19 U.S.C. 1304.

Where the response is export or destruction, importers sometimes ask whether the movement can support a drawback claim. That is a separate process built on CBP Form 7553, Notice of Intent to Export, Destroy or Return Merchandise for Purposes of Drawback, the notice that lets CBP examine goods before export or destruction for a drawback claim; see our article on CBP Form 7553. Exported goods that may later come back also intersect with CBP Form 4455, Certificate of Registration, which registers identifiable goods by serial number or mark with CBP before export for duty-free return under Chapter 98, and with CBP Form 3311, Declaration for Free Entry of Returned American Products, the declaration for duty-free return of U.S.-origin goods; see CBP Form 4455.

Other forms in the same family serve unrelated functions and should not be pulled into a CBP Form 4647 response: CBP Form 3299, Declaration for Free Entry of Unaccompanied Articles, covers personal and household effects arriving separately from the traveler; CBP Form 7523, Entry and Manifest of Merchandise Free of Duty, Carrier's Certificate and Release, is a paper entry for low-value duty-free goods; CBP Form 400, ACH Debit Application, enrolls a payer in CBP's Automated Clearinghouse debit program; CBP Form 3124, Application for Customs Broker License, is the license application filed under 19 CFR part 111; and FinCEN Form 105, Report of International Transportation of Currency or Monetary Instruments, is a currency report filed with CBP, not a customs entry form.

Frequently asked questions

How long do I have to respond to CBP Form 4647?

The importer must mark, certify, redeliver, export or destroy within 30 days of the CBP Form 4647 notice under 19 CFR 134.51. CBP may extend that period for good cause, but the extension must be requested from the issuing office rather than assumed.

Can I refuse redelivery under CBP Form 4647 if the goods are already sold?

If merchandise subject to CBP Form 4647 cannot be produced, the importer cannot satisfy the redelivery demand, and CBP can claim liquidated damages equal to the entered value of the unmarked goods under 19 CFR 113.62(d) and (e). The practical response is to document what happened, respond within the window, and address the resulting claim through the Fines, Penalties and Forfeitures process.

Does responding to CBP Form 4647 avoid the marking duty?

The 10 percent marking duty under 19 CFR 134.2 applies to articles not marked as required and is assessed at liquidation, so its application depends on the facts of the entry and CBP's determination. Confirm with the issuing Center whether a completed CBP Form 4647 response resolves the marking duty on your specific entry.

Is CBP Form 4647 the same as a CBP Form 28?

No. CBP Form 4647 is an order to mark, redeliver, export or destroy unmarked merchandise under 19 CFR 134.51, while CBP Form 28 is a request for information about an entry. A CBP Form 4647 carries a redelivery obligation backed by the bond; a CBP Form 28 does not.

What importers and brokers should do

• Build a single intake point for CBP Form 4647 notices, whether they arrive on paper or through ACE Forms, and date-stamp each one against the 30 day deadline in 19 CFR 134.51.
• Locate the merchandise immediately on receipt of a CBP Form 4647 and decide early whether marking, redelivery, export or destruction is actually achievable within the window.
• Never sign a certificate of marking that the physical goods do not support; retain samples and photographs of the marked articles as the evidence file, because a false certificate creates 19 U.S.C. 1592 exposure.
• Review ES-013 on a fixed schedule so no CBP Form 4647 ages past its deadline, and request an extension from the issuing Center for good cause before the deadline rather than after it.

Key references

• 19 U.S.C. 1304: the statutory country of origin marking requirement that CBP Form 4647 enforces.
• 19 CFR 134.51: the notice to mark and redeliver procedure and the 30 day response period.
• 19 CFR part 134: the full marking regulations, including 134.2 (10 percent marking duty), 134.52, 134.53 and 134.54.
• 19 CFR 113.62: basic importation and entry bond conditions, including the redelivery conditions at paragraphs (d) and (e).
• 19 U.S.C. 1592: the penalty statute reached by a false certificate of marking.
• CBP forms library: the official source for CBP Form 4647 and related forms.