CF-29 Notice of Action: How to Respond Before CBP Liquidates

What is a CF-29 Notice of Action?

A CF-29 Notice of Action is the form CBP uses to tell an importer it has changed, or proposes to change, an entry summary. CBP's ACE Entry Summary Business Rules and Process Document says a Form 29 "may include a change in the classification and/or value of the imported merchandise on the entry summary and may result in a rate advance of duty."

How do you respond to a CF-29 notice of action?

Read the status first. If the action is proposed, CBP's business rules give the importer 20 days to respond through the ACE Portal, or DIS where applicable. If the action is taken and the entry has liquidated, the response is no longer a reply on the form: it is a protest under 19 CFR part 174.

TL;DR

A CF-28 asks a question. A CF-29 states a conclusion. For a compliance manager holding a CF-29 on one entry of a SKU the company imports every week, the 20-day reply decides that one entry, while the classification argument behind it decides every other entry of the same product. GingerControl is a trade compliance AI platform whose HTS Classification Researcher reasons through GRI and cites CROSS rulings during the analysis, which gives a team a way to test CBP's proposed classification inside the window, rather than after liquidation.

Last updated: October 2026

This guide uses the regulation text on eCFR and CBP's current entry summary business rules (version 12.0, December 2023) as primary sources.

How is a CF-29 different from a CF-28?

The two forms arrive through the same ACE CBP Forms module and look alike. They sit at different stages of a review. CBP's business rules describe the CF-28 as the request CBP issues "for any additional information needed," with a response time of "30 days from the date of issuance of notice" and an extension possible at CBP's discretion. The CF-29 comes after CBP has formed a view.

Bottom line: For a compliance team that has already answered a CF-28, a CF-29 means the information request has turned into a position. The 30-day information clock is gone, a 20-day action clock has started, and the reply now has to argue the classification or value, not only supply documents.

The CF-28 side of this, including how to keep records so an information request is routine, is covered in our guides to the rise in CF-28 requests and answering a CF-28 from a classification history. The penalty side starts where this post ends, in responding to a 19 USC 1592 pre-penalty notice. A CF-29 is not a penalty notice. It changes duty on an entry; it does not by itself assert culpability.

What does action proposed versus action taken mean?

The status on the form decides which remedy is open. CBP's business rules state it in two sentences: "If the action is proposed, the importer will have 20 days to respond through the ACE Portal or DIS if applicable. If the action is taken and the entry liquidated, the trade will have to protest CBP's decision."

Action proposed. CBP has a position but has not liquidated. The Center of Excellence and Expertise provides, in the business rules' words, "a written explanation on the form as to why the action was taken on the entry summary." This is the window in which a reply can change the liquidation itself.

Action taken. CBP has made the change. Once the entry liquidates, the form is a record, not an invitation to reply. The decision becomes a protestable matter: 19 CFR 174.11 lists "the classification and rate and amount of duties chargeable" and "the appraised value of merchandise" among the decisions subject to protest.

Read the explanation on the form closely in both cases. It tells you whether the dispute is classification, value, quantity, or a program claim, and each needs different evidence.

What is a rate advance under 19 CFR 152.2?

A rate advance is an increase in the duty CBP will assess on an entry, most often because it moved the goods to an HTS number with a higher rate, or raised the value. 19 CFR 152.2 is the rule that makes the CF-29 the vehicle for telling you:

"If the Center director believes that the entered rate or value of any merchandise is too low, or if he finds that the quantity imported exceeds the entered quantity, and the estimated aggregate of the increase in duties on that entry exceeds $15, he shall promptly notify the importer on Customs Form 29, or its electronic equivalent specifying the nature of the difference on the notice."

The same section sets the pace: "Liquidation shall be made promptly and shall not be withheld for a period of more than 20 days from the date of mailing of such notice unless in the judgment of the Center director there are compelling reasons that would warrant such action."

Three practical points follow from that text.

1. The threshold is per entry. $15 of estimated additional duty on one entry is enough. A small notice is not a small issue if the same product moves on many entries.
2. The clock runs from mailing. Twenty days from the date the notice was mailed or issued, not from when someone in your team opened the ACE Forms queue. Check whether your broker has a courtesy copy; CBP's business rules say one "should be provided to the broker."
3. A classification change moves more than the base rate. A different 10-digit HTS number can change which chapter 99 measures attach to the line. The cost of a rate advance is the whole tariff stack on the new number, compared with the stack on the old one, at the entry date.

How long do you have to respond, and what should you send?

Twenty days from the notice, when the action is proposed. CBP's business rules do not describe an extension for the CF-29 the way they do for the CF-28, so if you need more time, ask the issuing Center in writing at once and do not assume it is granted. Separately, 19 CFR 159.12 lets an importer request an extension of the liquidation period for good cause, including where "more time is needed to present to CBP information which will affect the pending action." That request has to be made in writing and is at the Center director's discretion.

CBP's Quick Reference Guide for modernized Forms 28, 29 and 4647 shows the mechanics: open the Form 29 in the ACE CBP Forms application, choose Respond, type the reply in the Trade Reply field, attach files through Upload Document To DIS, then Save and Send.

What goes into that reply depends on the issue CBP named. For a classification change, a reply that persuades tends to contain:

1. A product description built from facts, not the invoice line. Materials, function, how it is used, how it is sold, with specification sheets and photos.
2. The GRI path to your HTS number. Heading text and Section and Chapter Notes first under GRI 1, then any later rule you rely on, stated in order.
3. Why CBP's proposed number does not fit. Address the explanation on the form directly. A reply that restates your own position without engaging CBP's reasoning gives the reviewer nothing new.
4. Rulings, with their facts. CROSS rulings on the same or similar merchandise, cited by number, with a sentence on why the facts match. A ruling applies to its own facts, so say what is the same.
5. The classification record. When the HTS number was chosen, by whom, on what evidence. This is the reasonable care story, and it matters beyond this entry.

If the reasoning shows CBP is right, say so. Accepting a correct change on one entry is cheaper than contesting it through protest, and it tells you what to fix on the rest.

Where the dispute is legal rather than factual, 19 CFR 177.11 allows an importer to ask the field office to seek internal advice from CBP Headquarters on a current transaction "whenever a difference of opinion exists as to the interpretation or proper application of the Customs and related laws." Headquarters may decline when the time needed would hold up action and the question can be raised later in a protest, so treat it as an option to discuss with counsel, not a way to stop the clock.

What happens after a CF-29: liquidation, PSC and protest?

The CF-29 is a stop on the way to liquidation. Where it leads depends on timing.

Bottom line: For an importer whose CF-29 entry has liquidated, the remaining route is protest, and the clock is 180 days from the posted liquidation date. Check status on the day the CF-29 arrives, because the date of liquidation, not the date of the notice, starts the protest period.

The PSC row comes from CBP's Post Summary Correction page, which lists among the PSC criteria that "an entry summary cannot be under CBP review," and adds that once an entry summary is liquidated, "the filers options to correct the entry summary is to file a prior disclosure or a protest."

The protest window is set in 19 CFR 174.12(e): within 180 days after the date of notice of liquidation for entries made on or after December 18, 2004. Liquidation is posted on cbp.gov, and under 19 CFR 159.9 that posting is "deemed the legal evidence of liquidation." Our guide to checking entry liquidation status covers where to look.

A protest has required contents under 19 CFR 174.13, including "the nature of, and justification for the objection set forth distinctly and specifically." The CF-29 reply, if you sent one, becomes the first draft of that justification. Where CBP's decision is alleged to conflict with its own rulings on substantially similar merchandise, 19 CFR 174.24 sets the criteria for further review by Headquarters. CBP has two years to act on a protest under 19 CFR 174.21, and an importer can ask for accelerated disposition under 19 CFR 174.22. The full mechanics are in how to file a customs protest.

Any duty recovered through a protest is the importer's claim to make. GingerControl identifies and documents the opportunity; your licensed broker or counsel files.

How do you keep one CF-29 from becoming a pattern?

A CF-29 names one entry. The question behind it is about a product.

Quotable insight: A CF-29 is issued entry by entry, but CBP's reasoning is about a product. If CBP is right about one entry of a SKU, it is right about every entry of that SKU, liquidated or not, and every future one. The 20-day reply settles one entry; the classification argument decides the exposure across all of them. Treat the notice as a classification review of the product, not a dispute about a single bill.

That changes the work in the 20 days. Alongside the reply:

1. List every entry of the same product. By HTS number, part number and supplier, across the open liquidation period. Split them into liquidated and unliquidated.
2. Re-run the classification on the product itself. If the reasoning supports your number, the same evidence carries the reply, the protest if one follows, and any binding ruling request you make to settle the question for future imports. If it supports CBP's number, the unliquidated entries and future entries need correcting, and the liquidated ones are a question for counsel, including whether a prior disclosure is appropriate.
3. Price the difference. Build the duty on both HTS numbers at each entry date, every layer included, and multiply across the affected entries. That is the number leadership needs, not the amount on the one notice.
4. Fix the record. Update the product's classification record with the date, the reasoning and the outcome, so the next CF-28 on this SKU is answered from the file.

A single protest can cover more than one entry under 19 CFR 174.13(b), which matters when CBP liquidates several entries of the same product on the same basis.

Where this fits in your CBP audit response workflow

Steps 2 and 3 above are where a 20-day window runs short: rebuilding the GRI path for a product, finding the CROSS rulings that match its facts, and pricing the difference across every affected entry. GingerControl's HTS Classification Researcher works through the GRI and Section and Chapter Notes, asks clarifying questions where candidate headings diverge, and cites CROSS rulings during the reasoning, producing a report a reviewer can attach. It is research that supports a classification decision; the final call benefits from professional judgment, and it does not provide legal advice. The Tariff Calculator then breaks the duty into its components for each HTS number, origin and entry date, so the rate advance has a price.

For teams that want help with the response itself, GingerControl's Trade Advisory service covers CBP audit response, including CF-28 and CF-29, alongside the importer's licensed broker or counsel. GingerControl does not file responses, protests or entries, and it does not act as importer of record.

References

1. U.S. Customs and Border Protection, ACE Entry Summary Business Rules and Process Document (Trade-External), Version 12.0, CBP Publication No. 3499-1223
   Data cited: section 1.11, CBP Form 28 and 30-day response; section 1.12, CBP Form 29, proposed versus taken action, 20-day response, courtesy copy to broker; PSC criteria in chapter 6
   Source: ACE Entry Summary Business Process (CBP)
   Published: December 2023
2. U.S. Customs and Border Protection, Quick Reference Guide, CBP Modernized Forms 28, 29, 4647, Publication No. 1726-0422
   Data cited: responding to a Form 29 in the ACE CBP Forms application
   Source: CBP Modernized Forms Quick Reference Guide (PDF)
   Published: April 2022
3. 19 CFR 152.2, Notification to importer of increased duties
   Data cited: CF-29 required where estimated increase exceeds $15; liquidation not withheld more than 20 days from mailing
   Source: 19 CFR 152.2
4. 19 CFR 159.9 and 159.12, Notice of liquidation; Extension of time for liquidation
   Data cited: posting on cbp.gov as legal evidence of liquidation; importer request for extension for good cause
   Source: 19 CFR 159.9, 19 CFR 159.12
5. 19 CFR 174.11, 174.12, 174.13, 174.21, 174.22, 174.24, Protests
   Data cited: protestable decisions; 180-day filing period; required contents and multiple entries; two-year review; accelerated disposition; criteria for further review
   Source: 19 CFR 174.11, 19 CFR 174.12, 19 CFR 174.13, 19 CFR 174.21, 19 CFR 174.22, 19 CFR 174.24
6. 19 CFR 177.11, Requests for advice by field offices
   Data cited: importer request for internal advice on a current transaction; Headquarters may decline where the question can be raised by protest
   Source: 19 CFR 177.11
7. U.S. Customs and Border Protection, Post Summary Correction
   Data cited: entry summary cannot be under CBP review; after liquidation, prior disclosure or protest
   Source: CBP Post Summary Correction
8. 28 U.S.C. 2636(a), Time for commencement of action
   Data cited: 180 days after denial of a protest to commence a civil action in the Court of International Trade
   Source: 28 U.S.C. 2636