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

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.

Handling a customs audit or a CBP (U.S. Customs and Border Protection) request for information is usually about being responsive, accurate, organized, and strategic. The wrong approach is to treat it like a routine customer-service inquiry; CBP requests can affect duties, penalties, admissibility, and future scrutiny. CBP’s Trade Regulatory Audit program uses risk-based reviews to assess compliance with trade laws and importer controls.

1. Confirm exactly what CBP is asking for

First, identify:

• The type of request: - A U.S. Customs and Border Protection Form 28 Request for Information
• A Regulatory Audit notice
• A summons or formal demand
• A focused compliance review
• The issue being examined: - Classification (HTS codes)
• Valuation
• Country of origin
• Marking
• Free trade agreement claims
• Antidumping/countervailing duties
• Forced labor compliance
• Recordkeeping

Do not assume CBP only cares about the specific entry numbers listed; requests can uncover broader compliance issues.

2. Preserve records immediately

Put a hold on relevant records and collect:

• Commercial invoices
• Packing lists
• Bills of lading
• Purchase orders and contracts
• Supplier communications
• Classification analyses
• Rulings or broker instructions
• Entry summaries (CBP Form 7501)
• Import databases and broker reports
• Valuation worksheets
• Country-of-origin documentation
• Supply-chain records

CBP has authority to examine relevant records during inquiries, compliance assessments, audits, and investigations.

3. Bring in the right people early

Depending on the issue, involve:

• Customs counsel
• Your customs broker
• Trade compliance staff
• Finance/accounting
• Procurement and supply-chain teams
• The business owners responsible for imports

A common mistake is allowing one person who handles entries to answer questions about company-wide processes without review.

4. Respond completely—but don’t speculate

Good responses:

• Answer the question asked.
• Provide supporting documents.
• Explain processes clearly.
• Identify uncertainties and offer to investigate.

Avoid:

• Guessing at facts.
• Volunteering unrelated explanations.
• Creating inconsistent explanations across submissions.
• Blaming a broker without verifying facts.

CBP’s “reasonable care” framework places responsibility on importers to provide accurate information and exercise appropriate diligence in import transactions.

5. Review for possible errors before submitting

A CBP inquiry can be an opportunity to identify and correct problems. Before responding, review:

• Past entries for the same product
• Similar suppliers or SKUs
• Classification decisions
• Duty payments
• Valuation treatment (assists, royalties, assists, commissions)
• Origin claims

If you discover a systemic error, discuss options with trade counsel before making admissions or filings.

6. Treat deadlines seriously

If the deadline is unrealistic:

• Request an extension promptly.
• Explain why additional time is needed.
• Provide partial information if appropriate.

Ignoring a request or missing deadlines can create unnecessary problems.

7. For an actual audit, prepare for the process

CBP audits generally include structured steps such as notice, an entrance conference, examination of records, a closing conference, and a written report. Legal Information Institute Prepare:

• A point person for CBP communications
• A document repository
• Process maps showing how imports are handled
• Internal control descriptions
• A list of known compliance risks and corrective actions

8. After the response or audit

Create a remediation plan:

• Fix incorrect master data
• Update classification databases
• Train employees
• Improve broker instructions
• Document procedures
• Perform periodic internal reviews

A strong post-audit response can reduce the likelihood of repeat issues.

If you are dealing with a specific CBP Form 28, audit notice, or questionnaire, the best approach can vary significantly depending on whether the issue is classification, valuation, origin, forced labor, or another trade area. I can help you map out a response strategy if you share the type of request and the topic CBP identified.

Handling a Request for Information (such as a CBP Form 28 / CF-28 ) or an official customs audit (such as a Focused Assessment or Quick Response Audit ) from U.S. Customs and Border Protection requires a calm, structured, and highly strategic approach . Mishandling these inquiries can lead to delayed entries, increased duty assessments, severe penalties, or broader investigations.

The best practices for managing these interactions effectively include the following key steps:

1. Immediate Triage and Clock Management

• Track the deadline immediately: A CF-28 typically carries a strict 30-day response window from the date of the issuance (with a possible extension if requested early and justified). Missing this deadline triggers adverse assumptions, increased duties, or a CBP Form 29 (Notice of Action).
• Designate a single point of contact (SPOC): Route all communications through one internal coordinator (e.g., Trade Compliance Manager or Legal Counsel) and your licensed customs broker. Do not let disparate departments send piecemeal information to CBP.

2. Analyze the Scope of the Inquiry

• Determine what is being asked: Understand whether CBP is probing Classification (HTSUS), Valuation, Country of Origin , or Intellectual Property Rights.
• Scope your internal data collection: Pull the specific entry summaries, commercial invoices, packing lists, proof of payment, bills of lading, and any correspondence with suppliers tied to the targeted entries.

3. Vet the Data Before Submission

• Provide only—and exactly—what is asked: Do not volunteer extraneous documents or open up unprompted conversational threads. Answer the specific questions clearly, concisely, and factually.
• Verify accuracy: Ensure that the data you submit matches what was declared on the original entry. If there is a discrepancy, do not try to cover it up; analyze whether it points to a systemic error that needs specialized remediation.

4. Evaluate the Need for a Prior Disclosure

• Uncover systemic errors early: If gathering information for CBP reveals that you have been systematically misclassifying goods or undervaluing merchandise across multiple entries, consult legal counsel immediately about filing a Prior Disclosure.
• Mitigate penalties: Submitting a formal Prior Disclosure before CBP independently discovers the violation dramatically reduces potential financial penalties (limiting liability to lost duties rather than massive fraud or negligence penalties).

5. Engage Professionals

• Involve legal and trade experts: For formal audits (like Focused Assessments conducted by CBP Trade Regulatory Audit ), partnering with a customs attorney or a specialized international trade consultant is essential . They can manage the audit team, sit in on interviews, and negotiate findings.
• Submit through proper channels: File your response electronically via the ACE Portal / Document Imaging System (DIS) to ensure official tracking and receipt.

If you're dealing with a specific notice right now, let me know:

• Is it a CBP Form 28 (Request for Information) or a formal audit notice?
• What specific trade issue (valuation, classification, origin) is CBP focusing on?

I can provide a more tailored checklist for your situation.

Handling a U.S. Customs and Border Protection (CBP) audit or an inquiry—most commonly a CBP Form 28 (Request for Information) or CBP Form 29 (Notice of Action) —requires immediate, methodical action. Treat these inquiries not as routine paperwork, but as formal examinations of your company's "reasonable care" compliance.

1. Act Immediately and Track Deadlines

• CF-28 (Request for Information): You typically have 30 days from the issue date to respond.
• CF-29 (Notice of Action): If CBP proposes an action, you generally have 20 days to reply or challenge the finding before they unilaterally reliquidate or assess extra duties. If action is already taken, a formal protest must be filed within 180 days of liquidation.
• Request Extensions Early: If gathering foreign supplier data or technical specs will cause you to miss a deadline, formally request an extension in writing before the clock runs out.

2. Pull the Complete Entry Package

• Do not rely solely on what you think you imported. Gather the full entry package from your records or your customs broker.
• Compile the commercial invoice, packing list, bill of lading, entry summary (CBP Form 7501), entry (CBP Form 3461), and any applicable certificates of origin or partner government agency (PGA) data.

3. Involve Experts, but Retain Control

• While customs brokers are essential for pulling files, remember that the Importer of Record is legally liable for the accuracy of the response—not the broker.
• For anything complex involving tariff classification disputes, related-party valuation, Free Trade Agreement (FTA) qualification, or anti-dumping/countervailing duties (AD/CVD), consult an experienced customs attorney or trade compliance consultant before submitting a position to CBP.

4. Provide Thorough, Targeted Evidence

• Answer every question fully; incomplete answers invite unfavorable assumptions or an automatic escalation to a CF-29.
• Support your positions with objective data: product spec sheets, material composition breakdowns, photographs, marketing catalogs, and relevant binding rulings from the CBP CROSS Database that match your product type.
• Ensure any document certifications are signed by a company officer who understands they are legally certifying the truth and correctness of the data.

5. Evaluate the Need for a Prior Disclosure

• If your internal review reveals that the questioned entry—or a broader pattern of entries—contains systemic errors or underpaid duties, talk to counsel immediately about filing a Prior Disclosure . Doing so before CBP uncovers fraud, gross negligence, or negligence can substantially mitigate or eliminate civil penalties.

To give you the most tailored strategy, tell me:

• Did you receive a CF-28 , a CF-29 , or a full Post-Entry Audit notification?
• Is the inquiry focused on classification (HTSUS), valuation , or country of origin?

If you're an importer, the best approach is to treat a CBP audit or CBP Form 28 (Request for Information) as a formal compliance matter—not as a routine paperwork request. CBP's Trade Regulatory Audit program is risk-based, and CBP can examine records to determine entry correctness, duties, taxes, fees, and compliance.

1. Don't answer piecemeal or casually

First, identify exactly:

• Who at CBP sent the request and their contact information.
• Whether this is a Form 28, an audit/Focused Assessment, an entry-specific inquiry, detention/admissibility issue, or something potentially enforcement-related.
• The specific entries, products, suppliers, HTS classifications, valuation issues, or time period involved.
• The precise deadline and requested format.

If the request could expose significant duty liability, penalties, forced-labor issues, origin problems, or possible fraud, involve customs counsel and/or a qualified customs compliance professional early, before providing substantive explanations.

2. Preserve everything

Immediately put a litigation/compliance hold on relevant records. Don't delete, overwrite, "clean up," or retroactively modify files.

CBP generally requires import records to be retained for five years from the entry or relevant activity, and records must be produced to CBP upon demand.

Pull together, as applicable:

• Entry summaries and entry packages
• Commercial invoices and packing lists
• Purchase orders and contracts
• Bills of lading/air waybills
• Proof of payment
• HTS classification analyses
• Country-of-origin documentation
• Valuation documentation
• Assist/royalty/related-party records
• Manufacturer and supplier information
• Customs broker communications and instructions
• Prior CBP rulings, protests, disclosures, or correspondence
• Internal compliance policies and training
• Product specifications and technical information

3. Build a response matrix

Don't simply dump documents on CBP. Create an internal matrix showing:

This helps prevent contradictory answers from different departments.

4. Be accurate—and don't guess

This is probably the most important practical rule.

If you don't know an answer, don't manufacture one. Say that the information is being verified and provide a supported answer when available.

CBP's "informed compliance" framework expects importers to exercise reasonable care. CBP specifically recognizes activities such as consulting customs professionals and obtaining rulings as potential components of reasonable care, although simply hiring a consultant isn't automatically enough.

Pay particular attention to answers that could implicitly establish that prior entries were wrong. A seemingly innocuous statement such as "we've always classified it this way" can create problems if the classification was never adequately supported.

5. Investigate beyond the exact samples

If CBP identifies an error in one entry, determine whether it is systemic.

For example, if CBP questions the classification of one SKU, investigate:

• Other SKUs with similar characteristics
• Other entries using the same HTS number
• Other suppliers
• Other ports
• The entire relevant period
• Whether the same broker instructions were used

The goal is to know your exposure before CBP tells you what it is.

6. Consider whether a prior disclosure is appropriate

If your internal investigation reveals a material violation—particularly involving underpaid duties, incorrect valuation, classification, origin, or other potentially significant violations—talk to customs counsel promptly about whether a prior disclosure under 19 U.S.C. § 1592 makes sense.

Don't automatically file one just because you discover an error. The timing, facts, scope, materiality, and what CBP already knows can matter enormously.

7. Control communications

Ideally designate one person as the CBP point of contact. Internally, have legal/compliance coordinate the substantive response.

You want CBP receiving:

one coherent, documented, technically defensible answer

rather than separate explanations from purchasing, logistics, finance, the broker, and individual employees.

That doesn't mean withholding information that CBP is entitled to receive. It means making sure the information is accurate and internally consistent.

8. Use CBP's own guidance and rulings

For technical issues—especially classification, valuation, origin, or admissibility—look for applicable CBP rulings and guidance. CBP's CROSS database contains more than 220,000 searchable rulings and is continuously updated.

Also keep in mind that CBP's online Q&A forum itself says its general answers don't constitute "reasonable care."

9. If it's a serious audit, prepare for the audit—not just the document request

A formal CBP audit can involve examination of your internal controls and compliance processes, not merely individual entries. CBP describes Focused Assessments as comprehensive, risk-based audits designed to determine whether an importer represents an acceptable risk.

So prepare to explain:

• Who owns customs compliance
• How classification decisions are made
• How valuation is determined
• How origin is established
• How broker instructions are controlled
• How changes in products/suppliers are communicated
• How entries are reviewed
• How errors are detected and corrected
• What training employees receive
• How management monitors compliance

Bottom line: respond promptly, preserve records, understand the scope, investigate internally, give CBP accurate and well-supported answers, and get experienced customs counsel involved if the request could result in substantial duties, penalties, enforcement exposure, or a finding that your compliance system is deficient.

If you tell me what kind of CBP request you received (e.g., Form 28, audit notice, detention inquiry) and what issue they're asking about (classification, valuation, origin, forced labor, etc.), I can walk you through how I would handle that specific situation.

Ideally designate one person as the CBP point of contact. Internally, have legal/compliance coordinate the substantive response.

You want CBP receiving:

one coherent, documented, technically defensible answer

rather than separate explanations from purchasing, logistics, finance, the broker, and individual employees.

That doesn't mean withholding information that CBP is entitled to receive. It means making sure the information is accurate and internally consistent.

8. Use CBP's own guidance and rulings

For technical issues—especially classification, valuation, origin, or admissibility—look for applicable CBP rulings and guidance. CBP's CROSS database contains more than 220,000 searchable rulings and is continuously updated.

Also keep in mind that CBP's online Q&A forum itself says its general answers don't constitute "reasonable care."

9. If it's a serious audit, prepare for the audit—not just the document request

A formal CBP audit can involve examination of your internal controls and compliance processes, not merely individual entries. CBP describes Focused Assessments as comprehensive, risk-based audits designed to determine whether an importer represents an acceptable risk.

So prepare to explain:

The best way to handle a request for information or a formal audit from U.S. Customs and Border Protection (CBP) is to respond promptly and completely to the exact scope of the inquiry while never volunteering unsolicited information or guessing on technical details . Designate a single point of contact—such as an internal compliance officer, a customs broker , or an experienced international trade attorney—to manage all communications, maintain a strict paper trail of every interaction, and evaluate whether a Prior Disclosure is necessary to mitigate penalties if an error is uncovered.

Core Strategies for Managing CBP Inquiries

• Acknowledge and Calendar Deadlines: Respond immediately to notices like a CBP Form 28 (Request for Information) or a formal Focused Assessment (FA) audit notice. If extra time is needed to gather records, proactively request an extension before the deadline lapses.
• Limit the Information Flow: Provide precise documentation that directly answers the auditor's questions (such as entry summaries, commercial invoices, or HTS classification justifications). Do not open doors to unrelated entry periods or hand over unrequested files.
• Never Guess or Speculate: If interviewees or company representatives do not know an answer during a walkthrough or audit interview, state that the information will be researched and followed up on rather than speculating on record.
• Leverage Privilege When Needed: Involve legal counsel early. Utilizing an attorney-client relationship helps protect internal compliance self-assessments and sensitive communications under privilege.
• File a Prior Disclosure if Errors Surface: If internal reviews reveal systemic underpayment of duties or misclassifications, filing a formal disclosure before CBP discovers the discrepancy dramatically reduces potential financial penalties.

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

• Is this a CBP Form 28 (RFI) , a Form 29 (Notice of Action) , or a formal Audit/Focused Assessment?
• What specific trade issue (valuation, HTS classification, or country of origin) is CBP focusing on?

If you’re dealing with a CBP customs audit or a CBP Form 28 (Request for Information), the safest approach is to treat it as a formal compliance matter—not just a paperwork request.

1. Preserve everything immediately

Put a hold on routine destruction/deletion of potentially relevant records. CBP generally requires import records to be retained for five years, and records can include electronic business information relating to entries, valuation, classification, payments, and other import activity.

Preserve, as applicable:

• Commercial invoices, packing lists, bills of lading
• Purchase orders and payment records
• Customs broker entry data and instructions
• Classification and valuation analyses
• Country-of-origin documentation
• Supplier/manufacturer records
• Product specifications and catalogs
• Emails and internal communications concerning the imports
• Prior CBP rulings, correspondence, protests, or disclosures

2. Identify exactly what CBP is asking

Don't answer a broader question than CBP actually asked.

A Form 28 is used when CBP needs additional information to appraise merchandise, determine classification, assess duties, or otherwise perform its responsibilities.

For an audit, CBP's Trade Regulatory Audit program is risk-based and can examine particular compliance areas or, in a Focused Assessment, the importer's broader internal controls.

Make a matrix internally:

3. Don't automatically assume your broker should handle it

Your customs broker can be extremely useful, but the importer remains responsible for compliance. CBP specifically emphasizes the importer's responsibility for reasonable care, and CBP notes that a broker's involvement doesn't eliminate that responsibility.

For a routine, narrow Form 28, your customs/trade team and broker may be able to coordinate the response. But bring in experienced customs counsel promptly if the request involves potential:

• Underpayment of duties
• Misclassification or valuation problems affecting many entries
• Country-of-origin issues
• Antidumping/countervailing duties
• Forced labor
• Prior disclosures
• False statements or potentially inaccurate records
• A potential penalty under 19 U.S.C. § 1592
• A broad audit or Focused Assessment

4. Reconcile before you respond

This is one of the most important steps.

Don't simply pull the requested document and send it. Compare the underlying records against what was actually declared to CBP.

For example, if CBP asks why an item was classified under a particular HTS number, check: product → specifications → purchase records → supplier information → broker instructions → entry → duty calculation.

If you discover that previous entries may be wrong, pause before volunteering a sweeping admission. Have customs counsel evaluate the issue and whether a prior disclosure or another corrective mechanism is appropriate.

5. Be accurate, complete, and disciplined

CBP has statutory authority to examine records relevant to customs inquiries, including electronically generated or machine-readable data.

A good response should:

• Answer each question separately.
• Use the requested entry numbers and dates.
• Explain any assumptions.
• Clearly identify supporting documents.
• Distinguish facts from conclusions.
• Say when a requested record doesn't exist rather than manufacturing an answer.
• Avoid speculation.

Don't guess. "We believe..." is not a substitute for verifying the underlying facts when the answer can be established.

6. Meet the deadline—or request more time

Don't let the deadline silently pass. If you genuinely need additional time to obtain supplier records, reconstruct transactions, or have counsel review the response, communicate with the CBP contact and request an extension before the deadline.

For a formal audit, federal regulations contemplate notice and an entrance conference where CBP explains the audit objectives, records requirements, sampling methodology, and estimated schedule.

7. If it's an audit, establish a controlled process

Designate one company point of contact for CBP. Have employees route requests through that person rather than independently sending material to auditors.

At the outset, establish:

• Scope of the audit
• Entries/time period covered
• CBP's specific objectives
• Requested data format
• Interview participants
• Document-production process
• Meeting schedule
• Who can make substantive representations for the company

Keep a contemporaneous log of what was requested, what was produced, when it was produced, and any outstanding questions.

8. Treat the audit as a compliance investigation

The goal isn't merely to "get through" CBP's questions. CBP's stated purpose includes assessing compliance and providing informed compliance, and its audit program can identify systemic weaknesses.

If you find an actual systemic problem, investigate its scope:

one entry → one product → one supplier → one classification → entire product line → entire historical period

That distinction can dramatically affect the appropriate response.

Bottom line

Don't ignore it, don't panic, and don't respond reflexively. The ideal sequence is:

Preserve records → determine scope → involve the right internal people/counsel → reconcile the underlying transactions → prepare a precise response → submit on time → remediate any systemic problem.

If you have an actual CBP Form 28, audit notice, or information request, you can paste the text here (redacting company names, entry numbers, addresses, etc.), and I can walk through what each request is asking for, what documents would normally support it, and which parts warrant customs counsel review.

Handling a U.S. Customs and Border Protection (CBP) audit or a formal Request for Information (such as a Customs Form 28 (CF-28) ) requires a calm, precise, and strategic approach. How you respond sets the tone for CBP’s view of your compliance and can influence whether a simple inquiry escalates into a penalty notice or a formal audit (such as a Focused Assessment).

Best practices for managing a CBP information request or audit include:

• Acknowledge and respect the clock immediately : A standard CF-28 gives you 30 days from the date of issuance to respond. If gathering overseas supplier or technical data means you cannot meet this window, request a written extension from the assigned import specialist before the deadline passes.
• Pull and review the complete entry package : Gather the entry documents via your Automated Commercial Environment (ACE) portal or your licensed customs broker. This includes the entry (CF-3461), entry summary (CF-7501), commercial invoices, packing lists, bills of lading, and any relevant certificates or declarations.
• Answer narrowly and accurately : Provide the exact information CBP asks for—nothing more, nothing less. Do not volunteer unprompted narratives, speculative details, or extra documentation that could unintentionally open up new lines of inquiry or create an accidental discrepancy across other entries.
• Determine the underlying issue : Analyze why CBP is asking. Are they targeting tariff classification, related-party valuation, country of origin, or Antidumping/Countervailing Duties (AD/CVD)? Identifying the root concern lets you construct a factual, legally supported, and persuasive response.
• Involve compliance experts or legal counsel early : If the request involves complex valuation, systemic classification errors, or high-value exposure across multiple historical entries, consult an experienced customs attorney or trade compliance consultant before submitting your package.
• Assess the need for a Prior Disclosure : If preparing the response uncovers a systemic mistake or unpaid duties spanning your import history, evaluate whether filing a CBP Prior Disclosure is appropriate. Self-reporting before CBP uncovers the error independently drastically limits potential financial penalties.
• Preserve all related records : Ensure that all documentation used to formulate your response is safely archived. Remember that CBP recordkeeping rules generally require you to retain entry documentation for 5 years from the date of entry.

If you've received a specific notice like a CF-28 (Request for Information) or a CF-29 (Notice of Action) , let me know what topic CBP is focusing on (such as valuation, HTS classification, or country of origin) so I can provide more tailored guidance.

If you mean a commercial/importer customs audit or a CBP Request for Information (CBP Form 28), the best approach is to treat it as a formal compliance matter—not as an ordinary customer-service inquiry.

1. Identify exactly what CBP is asking for

Read the notice carefully and determine:

• Whether it's a CBP Form 28 (Request for Information), an audit notice, or another inquiry.
• The specific entries, products, dates, and issues involved.
• The response deadline and the CBP officer/auditor assigned.

A Form 28 generally requires the requested information and documents, and CBP says that if you cannot respond within 30 days, you should contact the officer named on the form. You should also return a copy of the form with your response.

2. Put a small response team together immediately

For a business, I'd normally involve:

• Your customs/compliance person
• The customs broker
• Finance/accounting, if valuation or assists are involved
• Purchasing/supply-chain personnel, if supplier information is relevant
• Customs counsel if there is meaningful exposure—particularly potential penalties, prior inaccurate declarations, valuation problems, forced-labor concerns, or possible fraud

Don't assume the broker can handle everything. CBP specifically notes that ultimate compliance responsibility remains with the importer even when a broker assists.

3. Preserve records before investigating too aggressively

Put a hold on routine destruction of potentially relevant records. Gather the underlying documentation, including as applicable:

• Commercial invoices and purchase orders
• Bills of lading/air waybills
• Entry summaries and entry packages
• Broker instructions and communications
• HTS classification analyses/rulings
• Country-of-origin documentation
• Valuation records, assists, royalties and transfer-pricing information
• Supplier/manufacturer records
• Contracts and payment records
• Product specifications and samples
• Internal customs policies and prior compliance reviews

For an audit, CBP's Trade Regulatory Audit program is risk-based and may examine both particular compliance issues and, depending on the audit, the importer's internal controls.

4. Reconcile the facts before answering

This is probably the most important step.

Don't simply give CBP whatever documents happen to be readily available. First determine whether the documents tell a consistent story and whether the original entries were actually correct.

For example, if CBP asks about classification, compare the declared HTS numbers against the actual product specifications. If it asks about value, reconcile the declared value to purchase orders, invoices, payments, assists, royalties, and related-party arrangements.

The underlying principle is reasonable care: CBP places responsibility on importers to provide accurate information and exercise appropriate diligence in their import operations.

5. Be accurate, complete, and narrowly responsive

Don't guess.

If you don't know an answer, investigate it. If the records don't establish something, say so rather than filling the gap with an assumption.

At the same time, don't volunteer speculative explanations or unrelated information. A good response usually maps each CBP question → answer → supporting document.

6. If you discover an error, address it strategically

Finding an error during the response process doesn't necessarily mean you should hide it or ignore it. But you also shouldn't casually characterize something as a "violation" before counsel has evaluated the facts.

For significant discrepancies, have customs counsel assess:

• Potential duty exposure
• Penalty exposure
• Whether prior entries need correction
• Whether a prior disclosure or other remedial procedure is appropriate
• Whether the issue affects other products, suppliers, or historical entries

This is especially important if the problem appears systematic rather than isolated.

7. For a full audit, prepare for the process, not just the questions

CBP describes its audits as compliance-driven and risk-based.

You should therefore be prepared to explain how your import compliance system works, not merely produce documents. That can include:

• Who determines classification
• How origin is established
• Who determines customs value
• How broker instructions are created and reviewed
• How changes to products/suppliers are communicated
• How you monitor regulatory changes
• How you identify and correct errors
• What internal testing/auditing you perform

CBP's own audit-preparation materials emphasize reliable procedures for maintaining and producing entry documentation and understanding the supply chain.

8. Keep communications professional and controlled

Designate one person as the primary CBP contact. Keep a written log of:

• Every request
• Documents supplied
• Dates of submissions
• Questions asked by CBP
• Your responses
• Outstanding issues
• Extensions or agreements concerning deadlines

Avoid having five different employees independently responding to CBP.

A practical rule of thumb

Don't ignore it, don't improvise, and don't conceal an error.

A strong response process is:

Receive → preserve → understand scope → investigate → reconcile → obtain legal/compliance review where appropriate → respond completely and accurately → remediate any identified problem.

If you tell me whether this is (1) a CBP Form 28, (2) a formal CBP audit/Focused Assessment, (3) a detained shipment, or (4) an inquiry involving a specific issue such as classification, valuation, country of origin, or forced labor, I can explain the appropriate response strategy and what CBP is likely looking for.