CBP Form 28 Request for Information: Proving Where Your Goods Were Made, and What CBP Is Considering Next
What a CBP Form 28 Request for Information asks, how the 30 days work, who holds proof of origin, and the supply chain disclosures CBP is considering.
By Bernardo Campelo, Forbes Business Council E-Commerce Leader, Amazon SPN Certified provider, Amazon SP-API authorized partner, and Founder of PrepVia.
As of October 29, 2026, CBP Form 28, the Request for Information, is the form U.S. Customs and Border Protection says it uses when "the invoice or other documentation does not provide sufficient information for appraisement or classification, including for import compliance with trade agreements, preference treatment, or special provisions." That wording comes from CBP's latest Federal Register notice on the form, published May 8, 2026, which estimates 13,415 responses a year at about 2 hours each.
Origin can be one of those questions. In a CTPAT alert on illegal transshipping, last updated December 18, 2025, CBP wrote that it "has observed a notable increase in transshipment activity" and that it has "intensified targeting operations, increased supply chain audits," and used its Enforce and Protect Act authority against evasion schemes. Under U.S. rules, a carton that says "Made in Vietnam" can still hold a Chinese product, because work done in a second country changes the origin only if it is a substantial transformation.
The next step is still a question. On September 2, 2026, CBP published an advance notice of proposed rulemaking saying it "is considering" new disclosure requirements: more parties identified on each import, supply chain tracing technology, and the export documents foreign exporters file with their own customs authority. Nothing in it is a requirement yet, and comments are due December 1, 2026.
Most of the proof of origin sits with your supplier. A dock can read the marking on a unit, but it cannot see the factory behind it.
The 60-second version
A CBP Form 28 is a written request for information about one entry, and the form asks you to contact the CBP officer if you cannot reply within 30 days of the request date. In an alert last updated December 18, 2025, CBP reported a notable increase in transshipment and more supply chain audits. Under CBP's marking rules, origin is where the goods were made, and work in a second country counts only if it is a substantial transformation; CBP's transshipment alert says repackaging is not one. The proof sits with your supplier. A warehouse can show what arrived, how many units and how the marking reads. CBP is also considering new supply chain disclosures, including foreign export documents, with comments due December 1, 2026. A Form 29 is a separate notice, and it can come with or without a Form 28.
Every date and name below was checked on October 29, 2026 against the Federal Register, the eCFR, the U.S. Code, cbp.gov, CBP's Cargo Systems Messaging Service, reginfo.gov and regulations.gov, linked where they first appear. This is general information, not legal advice: for a live CF-28, CF-29 or EAPA matter, work with your licensed customs broker or a trade attorney.
What CBP Form 28 Is, and What It Asks
CBP describes Form 28 as a form "sent by CBP personnel to importers, exporters, producers, or their agents, as applicable, requesting additional information." The instructions on the form say everything requested "must relate to the shipment of merchandise described on the front of this form," and the header carries the entry number, the manufacturer or seller, the HTS number and a field labeled "Country of Origin/Exportation."
The regulation printed at the top of the form, 19 CFR 151.11, covers requests for samples and additional examination packages after release. The form's instructions say the reply "is required in accordance with section 509(a)" of the Tariff Act of 1930, which is 19 U.S.C. 1509, the statute that lets CBP examine records relevant to an inquiry.
| Box on the form | What it asks for |
|---|---|
| Question A | Whether you are related to the seller, and how the relationship affects the price |
| Question B | Additional costs: packing, commissions, proceeds that accrue to the seller, assists, royalties and license fees |
| Item A | The contract, or the purchase order and the seller's confirmation, with any revisions |
| Item B | Literature on what the merchandise is, how it is used and how it operates |
| Item C | A breakdown of components, materials or ingredients by weight, with their actual cost at the time of assembly |
| Item D | Samples, identified by article number and by the container marks and number |
| Item E and the officer's message | Anything else the officer needs |
Apart from the header field, the form has no question about where the goods were made. Origin questions arrive through the officer's message, and the box that helps answer them most directly, Item C, describes the factory side of the product.
A company official signs. The certification requires "an appropriate corporate/company official" to sign or endorse the reply, certifying that the information "is true and correct, and that any samples provided were taken from the shipment covered by this entry." The form notes that the signature is not required when a foreign firm completes it. And if a request for samples after release "is not promptly complied with," 19 CFR 151.11 lets CBP demand the goods back into its custody under the bond, a demand that 19 CFR 141.113 bars once liquidation of the entry has become final.
The 30 Days, the ACE Portal and CBP's Numbers
The timing language is on page 3 of the form: "If a reply cannot be made within 30 days from the date of this request or if you wish to discuss any of the questions designated for your reply, please contact the CBP officer whose name appears on the front of this form." The 30 days run from the Date of Request printed on the form, not from the day someone opens it.
Where the form lands matters for that clock. CBP's forms application in the ACE Portal lets trade users "view, respond and manage" electronic versions of Form 28, Form 29 (Notice of Action) and Form 4647 (Notice to Mark and/or Notice to Redeliver), according to CSMS #51707590. CBP delivers those forms to the importer's ACE Portal account, not the broker's. Since the April 2022 release of the forms module, brokers can get an email courtesy copy, but only when both ACE Portal accounts are set up for it, including the importer tying all its importer of record numbers to its top account, according to CSMS messages from August and October 2022. If nobody at the importer watches that account, the 30 days can pass unnoticed.
How many of these go out? CBP's paperwork estimate, unchanged since 2022, is 13,415 responses a year at about 2 hours each. In the Federal Register, CBP's latest count covers 2022, and it went down, not up: an October 2023 CBP rule reported Form 28 submissions in 2022 more than 61 percent below 2014, and CBP said it could not tell how much of that came from its Centers of Excellence and Expertise, which send one request for similar merchandise instead of one from each port.
Treat the 2 hours as a paperwork average. When a Form 28 arrives inside an evasion investigation, CBP's own estimate in its 2024 EAPA rule is "approximately 60" hours to complete and submit the response.
Why Origin Is the Question Now
CBP's alert, issued under its Customs Trade Partnership Against Terrorism (CTPAT) program, draws a distinction: "While transshipping itself is legal and common in global trade logistics, it becomes illegal when used deceptively to avoid duties, sanctions, or trade restrictions." CBP wrote that the trend is "particularly prevalent in industries subject to high antidumping and countervailing duties (AD/CVD), and tariffs on Chinese-origin goods."
Its example is a Chinese furniture maker that ships to Vietnam instead of directly to the United States. In Vietnam the product "is re-labeled as 'Made in Vietnam', and it may be lightly processed or repackaged," then goes to the United States as Vietnamese goods to avoid U.S. tariffs.
The legal test explains why that fails. Under CBP's marking regulation, 19 CFR 134.1(b), the country of origin is "the country of manufacture, production, or growth" of the article, and further work or material added in another country changes the origin only if it effects "a substantial transformation." Goods of USMCA countries follow separate marking rules in part 102. The alert says it plainly: "Repackaging the product does not mean there was substantial transformation."
Among the red flags the alert lists:
- No real change. "No substantial transformation in the transshipping country."
- Labels that don't fit the factory. "Country of origin labeling does not match manufacturing capabilities."
- Routing without a reason. "Routing through low-cost or FTA-friendly countries with no logical supply chain reason."
The alert also reminds importers that under the Customs Modernization Act of 1993 they are "legally obligated to exercise reasonable care in all Customs transactions," and tells companies to "double-check these marks to verify that goods are correctly marked before importing goods to the U.S." Before importing means at the supplier, not after the container lands.
Executive Order 14411, signed June 3, 2026, points the same way: its first section lists "rules of origin" and "origin marking" among the laws that effective customs enforcement guarantees compliance with. It also calls for maximum penalties on brokers who "fail to cooperate in a timely manner with requests for information by CBP."
Beyond the Form 28: CF-29, EAPA and Section 592
A Form 29 is a different notice with its own trigger. Under 19 CFR 152.2, when CBP "believes that the entered rate or value of any merchandise is too low," or finds that the quantity imported exceeds the quantity entered, and the estimated increase in duties on the entry exceeds $15, it notifies the importer on Form 29, the Notice of Action. Liquidation "shall not be withheld for a period of more than 20 days from the date of mailing of such notice," unless CBP sees compelling reasons. Nothing in the rule requires a Form 28 first, so a Form 29 can come with or without one.
The Enforce and Protect Act process in 19 U.S.C. 1517 applies only to "covered merchandise," which the statute defines as goods subject to an antidumping or a countervailing duty order. A tariff question that does not involve one of those orders is not an EAPA case. Inside one, the clocks are statutory:
- Opening. CBP decides whether to initiate within 15 business days of receiving an allegation or a referral from another agency.
- Interim measures. Within 90 calendar days of initiating, CBP decides whether there is a reasonable suspicion of evasion, which brings measures such as suspended liquidation.
- Determination. Within 300 calendar days of initiating, extendable by up to 60 calendar days for an extraordinarily complicated case.
- Cooperation. A party that fails to cooperate with a request for information can face an adverse inference.
CBP's 2024 rule says the importer alleged to have evaded "may receive a CBP Form 28 (CF-28)" or an initial request for information questionnaire. That is the 60-hour Form 28, and its clock is the one CBP sets: under 19 CFR 165.23 and 165.5, the reply is due "within the timeframe set forth by CBP in the request," and an extension has to be requested in a separate, stand-alone submission at least three business days before the deadline, except in extraordinary circumstances.
Section 592 of the Tariff Act, 19 U.S.C. 1592, is the civil penalty statute for entering goods by means of a material false statement or a material omission, through negligence, gross negligence or fraud. Each level carries a higher maximum, and a prior disclosure made before a formal investigation begins lowers it.
Floor-loaded or palletized, near PortMiami and Port Everglades, then on to Amazon by partnered LTL or FTL.
What CBP Is Considering: Heightened Import Disclosures
The September 2 notice, "Heightened Import Disclosures for Supply Chain Visibility" (91 FR 56408, docket USCBP-2026-1058), is an advance notice of proposed rulemaking. CBP says it "is considering amending its regulations" and that comments "will be used, potentially, to draft a Notice of Proposed Rulemaking." As of October 29, 2026, the rulemaking had not appeared in the federal Unified Agenda, so there is no published timetable for a proposal.
CBP says the notice lays out "proposals for implementing Section 3" of Executive Order 14411, which gave DHS 90 days, to September 1, 2026, to take steps toward requiring the documents a foreign exporter had to submit to its own customs administration. The notice was filed that day.
| Area | What the notice asks about |
|---|---|
| Foreign export documentation | Export declarations, commercial invoices, packing lists, certificates of origin, export licenses or permits, and transport documents such as bills of lading and air waybills, as filed with the foreign customs authority |
| Parties behind the import | Redefining or replacing the manufacturer identification code (MID); global business identifiers (the current test accepts D-U-N-S, GLN, LEI and the Altana ID); whether an online marketplace that facilitated the sale should be identified; whether the party the goods are ultimately meant for should be named |
| Supply chain tracing | What tracing technologies the private sector uses, whether importers should be responsible for using them, and whether CTPAT partners should be required to use enhanced tracing and make it visible to CBP |
The export documents are the ones exporters must submit "to the foreign customs authority prior to the exportation of those goods to the United States." On our reading, that is the customs office of the country the cargo leaves from, which in a transshipment is not the country of origin. CBP says it is weighing whether these documents would help it detect discrepancies "such as dual-invoicing," and asks whether importers should submit them for all goods (Question 1) and how long it takes to get them from suppliers (Question 16).
On parties, Question 33 asks whether "an online marketplace" that facilitated the sale should be identified, and Question 34 asks about naming "the party to which the merchandise is ultimately intended to be delivered, who may not be the initial recipient." Both are questions, not requirements. The notice does not mention warehouses, prep centers or fulfillment; it names third-party logistics providers only as possible export filers abroad and among the kinds of CTPAT partners.
Comments are due December 1, 2026, on regulations.gov, docket USCBP-2026-1058. If your supply chain runs through a third country, Question 16 is the one to answer with your own numbers.
Who Holds the Proof: Supplier, Importer, Warehouse
Put the form and the notice side by side and a pattern shows up: almost everything that proves origin sits upstream. Under 19 CFR 141.86, the commercial invoice has to state "the country of origin of the merchandise," along with the marks and numbers of the packages. An invoice states the origin. It does not prove it.
| Party | What it can show | What it cannot show |
|---|---|---|
| Supplier or exporter | Where and how the goods were made, the components and their cost at assembly, the export declaration and certificate of origin filed with its own customs office | What happened to the goods after they left |
| Importer of record and its broker | The entry, the invoice and purchase order, the reply in the ACE Portal, the signed certification | The factory floor, unless the supplier provides the records |
| Receiving warehouse | What arrived: carton counts against the packing list, carton marks and numbers, the origin marking as it reads, condition, discrepancies | Where or how the goods were made |
"An invoice states where a product was made. It doesn't prove it. When CBP asks, the proof sits with your supplier: what went into the product, where it was made, and what was filed to export it. A warehouse can show what arrived and how many units. It can't show where they were made."
Bernardo Campelo, Founder of PrepVia
That division also tells you when to ask: at the purchase order, not when a Form 28 arrives. CBP's alert puts the marking check before importing, and its notice asks how long export documents take to obtain.
The warehouse record still has a job. If a Form 28 asks for samples by container marks, the samples must come from the shipment covered by the entry, so the cartons need to be identifiable while the goods are still in the building. Our post on when a receiving count discrepancy becomes a post-summary correction covers what a dock record should contain.
Marking and Repacking: What Happens on the Dock
Every article of foreign origin, or its container, must be marked "in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container) will permit" with the English name of its country of origin, unless an exception applies, under 19 CFR 134.11. Under 19 CFR 134.41(b), the marking "must survive normal distribution and store handling."
Prep is where that rule meets the dock. Under 19 CFR 134.26, when imported articles are to be repacked into retail containers after release, such as blister packs, the importer certifies to CBP, at entry summary or in a blanket certification for a set period, that the repacking will not "obscure or conceal the country of origin marking appearing on the article," or that the new container will be marked; if the goods go to a repacker, the importer must tell it in writing. The section does not apply to a package the buyer can readily open for inspection, unless that package bears a U.S. address or other potentially misleading marking.
Packaging with a U.S. address has its own line. Under 19 CFR 134.22, containers bearing the name and address of a U.S. importer, distributor or other company must be marked near that address with a phrase such as "Contents made in France." Goods CBP finds not legally marked draw a Form 4647, the notice to mark them or return them to CBP custody.
Our reading for prep: a bundle, a poly bag or a multipack box built after import should not hide the "Made in" line unless the new package carries it. The exception is a package the buyer can readily open, as long as it shows no U.S. address or other potentially misleading marking. Put the location of the marking in the prep instructions you send.
Where a Prep Center Fits
A prep center sees the goods after customs release, when the entry has already been filed. The entry, the reply to CBP and the certifications belong to the importer of record and its licensed customs broker; our post on who the importer of record is when a 3PL takes the container walks through those roles. What a receiving warehouse can add is a dated record of what arrived.
At PrepVia, imported freight arrives at our warehouse at 8507 NW 72nd St, Miami, FL 33166. We receive, inspect and count it against the packing list, then prep it and create the inbound to Amazon. Discrepancies are reported within 24 hours of arrival, with photos, and the PrepVia app tracks expected against received units. That is a warehouse record: it shows what arrived and how many units, not where the goods were made.
PrepVia does not offer EDI or ASN transactions or lot-level recall tracking. PrepVia is Amazon SPN Certified, and our standard prep window is 24-36 hours.
Frequently Asked Questions
What is a CBP Form 28?
It is CBP's Request for Information, sent to importers, exporters, producers or their agents when the invoice or other documents do not give CBP enough to appraise or classify the goods, including for trade agreements and preference claims. Each form relates to one shipment.
How long do I have to answer a CBP Form 28?
The form asks you to contact the CBP officer named on it if you cannot reply within 30 days from the date of the request, or if you want to discuss the questions. Inside an EAPA investigation, the reply is due within the time CBP sets in the request.
Is a CBP Form 29 the next step after a Form 28?
Not necessarily. A Form 29, the Notice of Action, is CBP's notice that it believes the rate or value is too low, or that the quantity is higher than entered, when the increase in duties on the entry exceeds $15. The regulation does not require a Form 28 first, so a Form 29 can come with or without one.
Does repackaging goods in another country change their country of origin?
Not by itself. Under 19 CFR 134.1(b), work in another country changes the origin only if it is a substantial transformation, and CBP's CTPAT alert, last updated December 18, 2025, says repackaging does not mean there was one. Goods of USMCA countries follow separate rules.
Is CBP's supply chain disclosure notice a new requirement?
No. It is an advance notice of proposed rulemaking: CBP says it is considering new requirements and may use the comments to draft a proposed rule. Comments are due December 1, 2026, and as of October 29, 2026 no timetable for a proposal had been published.
Can my warehouse prove where my products were made?
No. A receiving record shows what arrived: counts, carton marks, the origin marking as it reads and the condition of the goods. Proof of where and how the goods were made comes from the supplier's records and the export documents filed with its own customs office.
Final Take
A Form 28 is a question about one entry, and when the question is origin, the answer lives at the factory. If you cannot reply within 30 days of the request date, the form asks you to contact the officer, and a company official signs the reply.
CBP's transshipment alert and its September 2026 notice point the same way: CBP wants to see past the invoice to where goods were made and how they moved. Build the supplier file at the purchase order, comment by December 1 if the export document idea would change how you source, and keep the warehouse record for what it is: proof of what arrived, not of where it was made.
How PrepVia receives imported freight →
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Related reading: who the importer of record is when a 3PL takes the container, the customs documents behind an FBA import, when a receiving discrepancy becomes a post-summary correction, three federal rules before importing through a U.S. subsidiary, CPSC eFiling and Hold Intact at the 3PL dock, the Amazon seller calendar for 2027.
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