Eight months isn’t a lot of time, but that’s precisely how long we had to help a brand-new independent industrial paints manufacturer build a compliance program from the ground up, after divesting from its former organization. Then, right after the dust settled, they received a CF-28 (CBP Form 28) letter. Not an ideal scenario for a business still in its infancy. 

Before that one CF-28 CBP inquiry could snowball into an avalanche of inquiries, we acted quickly, which is key when handling this type of situation. Customs and Border Protection (CBP) knows that entries are more complex, so they’re using artificial intelligence and other tech to more carefully scrutinize some of these cases. 

Here’s an overview of what happened next and what every business can learn from it. 

The Challenge 

In April 2025, the client divested from its parent company, becoming their own entity practically overnight. However, there was a window of six to eight months where the company was fully independent and had to build a compliance program from the ground up. 

Entries filed under both company names during the transition triggered a compliance alert, raising some red flags with CBP. This smaller compliance team that transferred from the parent company to this new enterprise now found themselves with a higher level of regulatory responsibility that they previously had not been accustomed to handling.  

There was a lot of risk involved here—not just from a financial standpoint, but a reputational perspective. First impressions are everything, and the last thing a new company wants is to be on customs’ radar. If you get it wrong, they take notice, and quickly. 

The Solution 

Remember those eight months of transition? They came in handy as we worked with the client to proactively build this new compliance program. So, when the CF-28 arrived, we already knew the client's products, classifications, and business activity. We weren’t starting from square one, because we already spoke the client’s language. 

Our role was twofold: acting as a strategic consultant, offering guidance and an external point of view, and employing our technical expertise, especially when USCMA knowledge was needed. The client was capable and proactive, and we simply added a layer of confidence and additional knowledge to the working partnership. 

The Approach 

The moment the CF-28 arrived, the client contacted us to review the inquiry and existing documentation. We then made sure to ask clarifying questions and established a baseline of where things stood. When it comes to these types of inquiries, you have 30 days to respond, so time is of the essence. 

We brought in the right experts from our team, who have extensive knowledge of the complexity of USMCA, to educate the client on the requirements. We took a deep dive into reviewing bill of materials, HTS classification check, USMCA compatibility assessment, and FTA documentation, revising it until it was just right. 

Then, after this thorough process of reviewing with the client, we submitted our response to customs. Shortly thereafter, we received word that customs had accepted our response and had no further inquiries at this time. 

You could say translating dense regulatory language into clear operational steps is our bread and butter. 

The Impact 

Let’s talk about the numbers: $1,500 saved, zero cascading inquiries triggered, and zero audits initiated. But in this case, the stats don’t tell the whole story. The real win is that a small compliance team at an upstart company was able to confidently handle a potentially big problem, with the help of a trusted partner in our team. 

By reaching out immediately once the letter was received, the team was able to collaborate and validate the compliance program that was built for this exact scenario. It was stress tested and passed with flying colors.  

Sometimes it’s less about the dollar signs and more about instilling the confidence in a team that they can handle whatever comes their way. We’ll always be right here as a trusted partner to assist, if needed. 

Lessons for the Industry 

This situation offers some great insights to highlight and review. 

CF-28 inquiries are rising. CBP is utilizing more advanced tools to catch errors, and entries have never been more complex. This system and process is here to stay, so be proactive, rather than reactive. 

Back up every claim. Before customs comes knocking, documentation should already be in place, especially if you're changing a classification or making a USMCA claim. Don't file first and figure it out later. Have a plan and process in place. 

Act fast. Thirty days may seem like a long lead time, but the deadline can sneak up on you if you delay or don’t have a proactive plan in place. The clients who wait two weeks to address the issue are already behind. Don’t let that be you. 

Don't panic. A CF-28 is simply an inquiry. Take a deep breath, review your plan, and respond to it thoroughly. Treat this situation as an opportunity to demonstrate a strong compliance program.  

CF-28 inquiries are on the rise, and they don't come with much warning. If you want to make sure you're prepared, or you're already navigating one, don’t hesitate to reach out. We've been here before, and we're happy to help walk you through the process.