What's the best way to handle a customs audit or a request for information from CBP?

If you mean a U.S. Customs and Border Protection (CBP) trade/compliance audit or a CBP Request for Information (CF-28), the best approach is to treat it as a formal compliance matter—not as an ordinary broker inquiry.

CBP’s Trade Regulatory Audit program is risk-based, and CBP can examine relevant entry and business records to determine duties, penalties, admissibility, and compliance.

A good response process

For an actual audit

For a formal audit, I'd be particularly careful about the scope and methodology. CBP audits can have targeted objectives, and Focused Assessments can be comprehensive and risk-based. U.S. Customs and Border Protection CBP regulations also contemplate an entrance conference in which the audit objectives, records requirements, sampling plan, and timing are discussed.

Don't treat the auditor as an adversary, but don't treat the audit as an informal conversation either. Cooperate, be factual, and have counsel or a knowledgeable compliance professional involved when the stakes are material.

For a CF-28 / Request for Information

A CF-28 is generally more targeted than a full audit. CBP uses requests for information to obtain documentation needed to determine issues such as admissibility and compliance. U.S. Customs and Border Protection Your response should directly answer each question asked, with supporting documents and a concise explanation where necessary.

If you tell me what kind of CBP request you received (e.g., CF-28, audit notice, summons, valuation/classification/origin inquiry) and what the issue is, I can give you a practical response checklist and, if useful, a draft response to CBP.

Handling a U.S. Customs and Border Protection (CBP) Request for Information (such as a CBP Form 28 / CF-28 ) or a formal Trade Regulatory Audit (such as a Focused Assessment) requires a precise, calm, and highly organized strategy. Missteps can turn a minor paperwork inquiry into a costly penalty or expanded audit.

The best practices for managing these interactions effectively include:

1. Acknowledge Deadlines and Request Extensions Immediately
   • A CF-28 typically gives you a strict 30-day window to respond.
   • If the information requires overseas data collection or deep record-retrieval that cannot be met in time, contact the assigned CBP officer before the deadline to formally request an extension. Never let the deadline pass in silence.
2. Assemble Your Response Team
   • Immediately bring in your licensed customs broker and a specialized customs/trade attorney.
   • Designate a single internal project manager to coordinate communication so that mixed or contradictory messages aren’t sent to CBP.
3. Pull and Audit the Complete Entry Package
   • Retrieve the exact entry paperwork in question: CBP Form 7501, commercial invoices, packing lists, bills of lading, 3461s, and any relevant certificates of origin.
   • Verify what was actually declared versus what physical or financial records show.
4. Answer Only What is Asked (No More, No Less)
   • Provide clear, factual, and direct answers to the specific questions on the notice.
   • Do not volunteer extraneous documents, unrequested entry numbers, or speculative explanations that could open new lines of inquiry. Ensure your documents are cross-referenced accurately.
5. Evaluate the Need for a Prior Disclosure
   • If gathering facts reveals systemic errors or underpayments of duties that extend past the specific entries requested by CBP, consult counsel immediately regarding a Prior Disclosure . Disclosing an error voluntarily before CBP discovers it drastically mitigates potential penalties.
6. Maintain a Buffer on Submission
   • Aim to submit your package 2 to 5 days before the hard deadline . This accounts for any electronic portal glitches, delivery delays, or last-minute questions from your legal counsel.

If you've received a notice, tell me:

• Are you dealing with a CF-28 (Request for Information) , a CF-29 (Notice of Action) , or a formal Audit/Focused Assessment?
• What core issue is CBP probing (classification, valuation, or country of origin)?

I can help you map out the next specific steps for your situation.

Handling a Customs and Border Protection (CBP) audit or a Request for Information (such as a CBP Form 28 / Request for Information or a formal Focused Assessment audit) requires a cool head, absolute precision, and a strategic approach. What you provide—and how you provide it—shapes whether an inquiry resolves cleanly or escalates into penalties or a CBP Form 29 / Notice of Action.

• 1. Acknowledge deadlines immediately - A CBP Form 28 typically gives you 30 days to respond. If overseas suppliers, ERP data extractions, or complex technical write-ups mean you cannot meet the deadline, contact the import specialist or auditor before the due date to request an extension. Always get the extension approval confirmed in writing.
• 1. Establish a single point of contact - Designate one internal lead (usually your compliance manager, customs broker, or trade counsel) to manage all communication. Do not let random employees field direct calls or emails from CBP auditors, as inconsistent statements create massive risk.
• 1. Answer only what is asked, but answer it completely - Provide clear, direct explanations mapped precisely to each question on the notice. Do not leave questions blank, but do not dump unrequested data or unrelated shipping entries that invite extra scrutiny.
• 1. Gather tightly correlated documentation - Pull commercial invoices, purchase orders, packing lists, bills of lading, proof of payment/reconciliation, product specification sheets, and material composition breakdowns. If classification or valuation is questioned, back your argument with official cross-rulings, binding classification rulings, or Court of International Trade precedents.
• 1. Organize with an executive cover letter - Structure your submission with a professional cover letter summarizing your core compliance position, index the exhibits clearly, and present technical facts in plain language.
• 1. Evaluate a Prior Disclosure if you uncover errors - If gathering data reveals that you actually made a systemic error or underpaid duties, consult legal counsel immediately about filing a CBP Prior Disclosure . Doing this proactively drastically mitigates potential penalties compared to CBP finding the discrepancy themselves.

To tailor this strategy, let me know:

• Are you responding to a CF-28 (Request for Information) , a CF-29 (Notice of Action) , or a formal Trade Regulatory Audit / Focused Assessment?
• What is the core issue CBP is targeting (e.g., valuation, HTS classification, country of origin/markings, or anti-dumping duties)?

The safest approach is to treat a CBP audit or CBP Form 28 (Request for Information) as a formal regulatory matter—not as an ordinary customer-service inquiry. CBP has broad authority to examine records to verify entries, duties, admissibility, classification, valuation, and compliance.

Recommended playbook

1. Preserve everything immediately. Put a hold on routine destruction of potentially relevant records, including entry files, commercial invoices, purchase orders, payment records, packing lists, bills of lading, broker communications, classification/origin analyses, product specifications, and relevant emails.
2. Identify exactly what CBP is asking. Determine:

• Which entries and dates are covered
• The specific questions/issues
• The requested documents
• The response deadline
• The CBP office and investigator/auditor handling the matter

Don't assume a request for a few documents means CBP is limiting its review to those documents. 3. Bring in experienced customs counsel early. This is particularly important if the request touches classification, valuation, country of origin, preferential trade programs, antidumping/countervailing duties, Section 301/232 or other trade remedies, or potentially inaccurate prior entries. 4. Reconcile the requested information against your actual entries. Don't simply pull documents and send them. Compare the underlying facts against what was actually declared to CBP. Look for discrepancies in:

• HTS classification
• Customs value
• Assists/royalties
• Country of origin
• Related-party pricing
• Quantity and description
• Free-trade-agreement claims
• Special/additional tariff provisions

5. Answer completely and accurately—but don't speculate. If you don't know an answer, investigate it rather than guessing. If a requested document doesn't exist, say so and explain what records you do have. CBP's recordkeeping rules cover information normally kept in the ordinary course of business and impose production requirements.
6. Coordinate internally. Ideally, have one person or small team control communications with CBP. Make sure your customs broker, purchasing team, logistics group, finance department, and overseas suppliers aren't independently sending inconsistent explanations.
7. Document your methodology. Keep an internal record of what you searched, which systems and people you consulted, what documents you produced, and how you reached substantive conclusions. This becomes particularly valuable if CBP later challenges an entry.
8. Investigate whether you have a voluntary disclosure issue. If the review uncovers prior entries that may have been materially incorrect and resulted in underpayment, have customs counsel assess promptly whether a prior disclosure or another corrective mechanism is appropriate. Don't make a disclosure simply because CBP asked a question; the strategy depends heavily on what CBP already knows and the nature of the error.
9. Meet the deadline—or formally request more time. If the requested production cannot reasonably be completed by the deadline, communicate with the CBP contact before the deadline and request an extension. Don't silently miss it.
10. Keep the response professional and narrowly responsive. Avoid argumentative explanations, unsupported theories, or unnecessary admissions. A good response typically has a cover letter followed by a clearly indexed production addressing each request.

One important distinction

A CBP Form 28 is not necessarily the same thing as a full-blown CBP audit. A Form 28 can be directed at a particular entry or issue, while a regulatory audit can be considerably broader. CBP's regulations define an audit broadly as an examination/review of required records for purposes including determining entry correctness, duty liability, penalties, and compliance.

If you're currently holding a CBP Form 28 or audit notice, I can also walk you through it line-by-line and help you build a response/production checklist. If you paste the request here (redacting company names, entry numbers, and other sensitive information), I can help identify what CBP is really asking and where the legal/compliance risks are.

If you mean a U.S. Customs and Border Protection (CBP) audit or a CBP Form 28 Request for Information, the best approach is to treat it as a formal compliance matter—not simply a paperwork request.

CBP's Trade Regulatory Audit program uses risk-based audits, and the importer of record remains responsible for exercising “reasonable care” in classification, valuation, admissibility, and other entry requirements.

A practical approach

1. Identify exactly what CBP is asking for.

• Determine whether it's a Form 28, audit notice, focused assessment, detention inquiry, or another request.
• Note the specific entries, products, time period, and response deadline.
• Don't volunteer unrelated information before understanding the scope.

2. Preserve everything. Immediately place a hold on destruction/deletion of potentially relevant records. Customs records generally must be retained for five years from the entry date or relevant activity, subject to exceptions.
3. Bring in the right people early. For a significant audit, involve:

• your customs/trade-compliance team,
• customs broker,
• finance/accounts payable,
• purchasing/supply-chain personnel,
• and, if there's meaningful exposure, experienced customs counsel.

Remember that using a customs broker doesn't transfer ultimate compliance responsibility away from the importer. CBP Help Center 4. Reconcile CBP's data against your own. Build an entry-by-entry analysis covering, as applicable:

• HTS classification
• customs value
• country of origin
• assists and additions to value
• tariff preference claims
• antidumping/countervailing duties
• Section 301/232 or other special tariffs
• exclusions
• PGA requirements
• marking
• forced-labor/admissibility issues
• broker instructions and entry summaries.

5. Don't guess. If you don't know an answer, investigate it rather than giving CBP an unsupported answer. CBP specifically expects importers to provide sufficient information for it to determine whether merchandise is properly entered and admissible.
6. Make your response organized and traceable. A good response usually has:

• a short cover letter,
• numbered responses corresponding to CBP's questions,
• clearly labeled attachments,
• an explanation of methodology where appropriate,
• and a list of anything that is genuinely unavailable.

Avoid dumping thousands of pages on CBP without explaining what each document establishes. 7. Look for systemic problems—not just the entries CBP identified. If CBP finds one classification or valuation problem, ask whether the same issue affected other entries. A voluntary internal review can help you quantify exposure and determine whether corrections, prior disclosures, or other remedial action should be considered. 8. Be particularly careful if there's potential penalty exposure. If the issue involves material underpayment, false statements, valuation manipulation, origin problems, evasion, forced labor, or potentially intentional conduct, get customs counsel involved before making substantive admissions. The consequences can extend well beyond simply paying additional duty. 9. Document the remediation. If you discover a problem, don't just fix historical entries. Document:

• what went wrong,
• how far it extends,
• why it happened,
• what corrective action you're taking,
• who owns the control,
• and how you'll test that it stays fixed.

That's particularly important because CBP's audit program can examine an importer's internal controls as well as individual transactions.

One important distinction

A routine CBP information request and a formal audit deserve different levels of response. A narrow Form 28 concerning one classification issue may be handled relatively simply. A Trade Regulatory Audit or Focused Assessment can involve much broader examination of records, processes, and internal controls.

If you have an actual CBP letter/Form 28, you can paste the text here (redacting company names, importer numbers, addresses, etc.), and I can walk through what CBP is asking, what documents you should gather, potential red flags, and how I would structure the response.

Handling a Request for Information (RFI) or an audit from U.S. Customs and Border Protection (CBP)—whether it is a targeted Quick Response Assessment (QRA) or a full-scale Focused Assessment (FA)—requires a calm, organized, and strategic approach. Demonstrating "reasonable care" and transparent internal controls from the start can significantly alter the outcome.

Here is the best way to handle and navigate a CBP inquiry:

1. Immediate Initial Steps (Triage)

• Read the notice carefully: Identify what type of communication it is (an RFI, a CF-28/CF-29 form, a regulatory audit survey, or a formal Focused Assessment notice) and note the hard response deadline.
• Form a response team: Immediately assemble your internal customs/trade compliance manager, legal counsel (preferably a licensed customs attorney), and relevant operational leads (finance, logistics, purchasing).
• Request an extension early if needed: If the deadline is unrealistic given the scope of data requested, contact the assigned CBP auditor or import specialist immediately to request a reasonable extension. Do not wait until the day before the deadline.

2. Control and Scope the Information

• Answer only what is asked: Provide accurate, direct, and complete answers to the specific questions or documents requested in the RFI or audit plan. Do not volunteer extraneous or speculative information that opens up entirely new lines of inquiry.
• Conduct an internal pre-audit: Before sending records to CBP, review every document to verify accuracy. Ensure that entry documents, commercial invoices, packing lists, reconciliation files, and proof of payment match what was declared.
• Maintain a strict audit trail: Keep a meticulous log of every document and communication sent to CBP. Designate a single point of contact (usually legal counsel or the lead compliance officer) to manage all interactions with the CBP auditor.

3. Leverage "Prior Disclosure" If Errors Are Found

• Evaluate for prior disclosures: If your internal review uncovers systemic errors, underpaid duties, or incorrect classifications/valuations during the audit period, consult legal counsel immediately about filing a CBP Prior Disclosure.
• Why it matters: Submitting a formal prior disclosure before CBP discovers the violation independently or before they formally flag that specific issue can dramatically mitigate or eliminate severe monetary penalties.

4. Demonstrate "Reasonable Care" and Internal Controls

• Show your compliance program: CBP places heavy emphasis on internal controls. Provide written standard operating procedures (SOPs) that govern your classification, valuation, country of origin determination, and broker oversight.
• Highlight corrective actions: If you identify historical mistakes, show CBP that you have already implemented corrective actions and updated internal workflows to prevent future recurrence. Proactive compliance is viewed very favorably.

If you'd like, let me know:

• Is this a formal Request for Information (RFI/CF-28) or an audit notification (Focused Assessment/RASA)?
• What specific trade issue (e.g., classification, valuation, Section 301 tariffs) is CBP focusing on?

I can provide more tailored guidance on how to assemble your documentation or when to involve legal counsel.

Handling a Request for Information (RFI) or a formal audit (such as a Focused Assessment Program review) from U.S. Customs and Border Protection (CBP) requires a calm, highly organized, and strategic approach. Missteps early in the process can escalate a minor inquiry into a full-scale penalty investigation.

The best practices for handling a CBP audit or RFI are structured below:

1. Acknowledge and Assign a Point Person
   • Immediately log the date of receipt and note any statutory deadlines for response.
   • Designate a single internal point of contact—ideally a customs compliance officer, legal counsel, or a licensed customs broker—to control the flow of communication and ensure consistency.
2. Scrutinize the Scope of the Request
   • Review the specific questions or documents being demanded (e.g., entry documents, reconciliation data, HTS classifications, valuation, or country of origin).
   • Do not volunteer extraneous information or documents that were not asked for. Provide precisely what is requested, no more and no less.
3. Perform an Internal Audit and Document Review
   • Pull all requested entry packages, commercial invoices, packing lists, bills of lading, and proof of payment.
   • Audit these records internally to identify any discrepancies, misclassifications, or undervaluation before handing them over to CBP.
4. Consider a Prior Disclosure if Errors are Found
   • If your internal review uncovers material errors or unpaid duties, look into filing a Prior Disclosure under 19 U.S.C. \1592.
   • Filing a valid prior disclosure before CBP discovers the violation independently dramatically mitigates potential penalties (often limiting liability to just the loss of duties rather than massive fraud or negligence penalties).
5. Establish Open, Professional Dialogue with the Auditor
   • Contact the assigned CBP auditor or regulatory specialist to introduce your team and confirm expectations.
   • If you need more time to gather extensive records, request an extension before the original deadline passes. CBP is often reasonable if approached proactively and professionally.
6. Prepare Your Internal Personnel for Interviews
   • If CBP requests interviews, brief your staff (logistics, purchasing, finance, and customs teams) beforehand.
   • Instruct them to answer questions truthfully, concisely, and strictly within the scope of their direct responsibilities without speculating or guessing.
7. Retain Professional Counsel/Experts
   • For complex audits or high-dollar exposure (such as a multi-phased Focused Assessment), engage a customs attorney or specialized trade consultant to guide the response strategy and protect your corporate interests.

If you'd like to narrow this down, tell me:

• Is this an informal RFI (Request for Information / Form 28) , a Notice of Action (Form 29) , or a formal audit notice?
• What specific trade issue or entry element is CBP focusing on?

I can help you outline a step-by-step response strategy for your specific situation.

If you mean a commercial-import customs audit or CBP request for documents/information, the safest approach is to treat it as a formal compliance matter—not as a routine customer-service inquiry.

Recommended approach

1. Acknowledge the request promptly. Confirm receipt, identify the CBP office/auditor, the response deadline, the entries/period involved, and exactly what information is being requested. CBP's Trade Regulatory Audit program conducts both targeted audits and broader Focused Assessments.
2. Preserve everything. Put a litigation/compliance hold on potentially relevant records and don't alter, delete, overwrite, or "clean up" historical files. CBP's recordkeeping rules cover information normally maintained in the ordinary course of business concerning importations, entries, transportation/storage, duties and fees, and related activities.
3. Bring in the right people immediately. Typically this should include:

• Your customs/trade-compliance lead
• Customs broker, as appropriate
• Finance/accounting
• Procurement/logistics
• IT/data personnel if large datasets are involved
• Experienced customs counsel, particularly if the request could result in additional duties, penalties, fraud allegations, forced-labor issues, or other enforcement.

4. Don't guess. Establish a single person responsible for communicating with CBP. Have responses reviewed internally before sending them. If you don't know an answer, it's generally better to say that you're investigating and provide a specific follow-up date than to speculate.
5. Reconcile CBP's questions against your underlying data. Don't merely gather the documents requested. Check the relevant entries against:

• Commercial invoices and purchase orders
• Classification/HTS determinations
• Customs values and assists
• Country of origin
• Related-party pricing
• Broker entry data
• Duty/tax payments
• Free-trade/preference claims
• PGA requirements
• Drawback or other special programs
• Internal policies and controls

CBP's ACE system also supports responses to requests for documents such as CBP Forms 28, 29 and 4647, and provides reporting capabilities that can be useful for an internal review. U.S. Customs and Border Protection 6. Conduct your own privileged internal assessment. If the issue appears potentially systemic, have counsel direct an internal review where appropriate. Determine the scope: How many entries are affected? What time period? Is the problem isolated or recurring? Did the company have controls that should have caught it? 7. Consider corrective action before responding. If your review uncovers underpayments or inaccurate declarations, don't simply wait for CBP to identify every problem. Depending on the circumstances, counsel should evaluate mechanisms such as post-summary corrections, prior disclosure, protests, or other corrective procedures. The right mechanism and timing depend heavily on what happened and where the matter stands procedurally. 8. Be accurate, complete, and organized. A good CBP response should make it easy for the auditor to understand:

• What was requested
• What you're providing
• What each document shows
• What remains outstanding
• Any corrections you've identified
• What corrective measures you've implemented

One important distinction

If what you received is a CBP Form 28 Request for Information, that's different from receiving a formal audit notification. Don't assume that a relatively narrow document request means CBP has limited concerns—or that you should volunteer an enormous amount of unrelated information. Start with the precise scope of the request and have counsel/compliance assess whether the response should be limited or expanded.

CBP itself describes audits as potentially ranging from targeted examinations to comprehensive Focused Assessments, so the scope can vary substantially.

If you have the actual CBP letter/Form 28 (you can paste the text or upload it), I can walk through it line-by-line and help you build a response plan, including what to provide, what to investigate internally, and what issues should be escalated to customs counsel. This is general information, not legal advice.

Handling a Request for Information (RFI) or a formal audit from U.S. Customs and Border Protection (CBP) requires a calm, structured, and highly strategic response. Missteps can turn a minor inquiry into a full-scale regulatory penalty or a focused assessment.

The best practices for managing a CBP inquiry or audit successfully include the following core steps:

Immediate Response to a CBP Request for Information (RFI) / CF-28

Managing a Formal CBP Audit

Crucial Strategic Moves

• Consider a Prior Disclosure: If your internal audit uncovers a systemic error, misclassification, or underpayment of duties before or during the CBP process, consult counsel regarding a formal Prior Disclosure . Disclosing the violation proactively dramatically mitigates statutory penalties.
• Maintain Professional Transparency: Treat the audit team with professional courtesy. Be cooperative, but firm about boundaries and timelines. If you need an extension on document production due to the sheer volume of data, request it in writing before the deadline passes.

You can review official guidelines and frameworks directly via the CBP Partnership in Responsible Trade Framework or consult a specialist through resources like the J.M. Rodgers Customs Audit Guide.

If you'd like to narrow this down, let me know:

• Is this a formal Regulatory Audit or a specific CF-28 / CF-29 inquiry?
• What core issue area (classification, valuation, country of origin, or FTA claim) is CBP targeting?

I can provide more tailored guidance for your situation.

Handling a customs audit or a request for information (RFI) from U.S. Customs and Border Protection (CBP) is best approached as a compliance project: respond promptly, control the flow of information, and make sure your records tell a consistent story. CBP Trade Regulatory Audit (TRA) uses audits and other reviews to assess compliance with trade laws and regulations, often using risk-based approaches.

1. Do not ignore the request or miss deadlines

• Confirm receipt with CBP (or your assigned auditor/import specialist).
• Calendar the response deadline immediately.
• If you need more time, request an extension before the deadline and explain why.

A late, incomplete, or inconsistent response can create more problems than the underlying issue.

2. Identify exactly what CBP is asking for

Determine whether it is:

• A routine request for documents (for example, a CBP Form 28 Request for Information).
• A focused audit.
• A broader compliance review.
• A detention-related request (such as valuation, classification, country of origin, or forced labor documentation).

For example, CBP may use requests for information to evaluate whether an importer can demonstrate admissibility of goods and compliance with applicable requirements.

3. Assemble an internal response team

Depending on the issue, involve:

• Import compliance personnel
• Customs broker(s)
• Logistics/supply chain teams
• Finance/accounting
• Legal counsel or a customs attorney (especially if there may be penalties, prior disclosures, or significant exposure)

Avoid having multiple employees respond independently to CBP.

4. Preserve and organize records

Collect relevant documents, such as:

• Commercial invoices
• Packing lists
• Purchase orders and contracts
• Bills of lading/air waybills
• Entry summaries
• Classification determinations
• Valuation support
• Country-of-origin documentation
• Supplier declarations
• Product specifications
• Internal compliance procedures
• Prior communications with CBP or brokers

CBP expects importers to exercise “reasonable care” and maintain enough documentation to support entry decisions.

5. Perform your own review before responding

Do not simply send a document dump. Check for:

• Incorrect tariff classifications
• Underreported assists or royalties
• Valuation issues
• Country-of-origin inconsistencies
• Missing records
• Broker filing errors
• Supplier documentation gaps

If you discover mistakes, evaluate whether a corrective action or prior disclosure strategy is appropriate with counsel.

6. Be accurate, complete, and consistent

Good responses:

• Answer each question directly.
• Explain processes, not just provide files.
• Identify limitations honestly.
• Include supporting documents with clear labels.

Avoid:

• Guessing.
• Speculating about facts you cannot verify.
• Providing inconsistent explanations from different departments.
• Altering records after the fact.

7. Prepare for an audit interview or site visit

If CBP schedules meetings:

• Assign one company point of contact.
• Prepare an overview of your import program.
• Review likely problem areas beforehand.
• Make sure employees understand who should answer questions.

TRA audits may examine systems, procedures, and internal controls—not just individual transactions.

8. Fix the underlying issue

A strong response often includes:

• Root-cause analysis
• Corrective actions
• Updated procedures
• Employee training
• Broker instructions
• Monitoring/testing plans

CBP generally views proactive compliance improvements more favorably than simply explaining why an error occurred.

Practical checklist

Before submitting your response, confirm:

• ✅ Deadline confirmed
• ✅ Scope of request understood
• ✅ Records preserved
• ✅ Documents reconciled against entries
• ✅ Internal stakeholders reviewed the response
• ✅ Answers are factual and consistent
• ✅ Corrective actions documented

For a significant audit, penalty exposure, valuation/classification issue, or a request involving forced labor, sanctions, or origin concerns, it is usually worth involving a customs attorney or trade compliance specialist before submitting the final response.