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CBP Audit Response Services | Defend Against CF-28, CF-29 & Detentions

On-the-ground audit defense in China & Vietnam: supplier affidavits, UFLPA rebuttal, valuation & classification proof, and complete CBP compliance files.

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CBP Knocks, We HELP you Answer

Immediate CBP Audit & Detention Support — CF-28, CF-29 & UFLPA Cases

 If you’ve received a CBP Form 28 (Request for Information), Form 29 (Notice of Action), detention notice, or audit letter, time is running.
Deadlines are short, penalties are severe, and incomplete responses make matters worse.
Our team in China & Vietnam gathers evidence, supplier affidavits, and legal contracts fast — so you can defend your shipment with proof, not hope.
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Asia Agent: On-the-Ground CBP Audit Response in China & Vietnam

When CBP sends a CF-28, CF-29, detention notice, or audit letter, the clock starts ticking. Asia Agent is on the ground in China & Vietnam to gather documents directly from factories, draft supplier affidavits, reconcile invoices, and deliver a full audit response file that stands up to CBP scrutiny.

Why This Matters

CBP is intensifying enforcement across:

  • Valuation

  • Classification

  • Country of Origin

  • Forced labor (UFLPA)

  • AD/CVD risks

Importers are liable for errors — even if the supplier caused them. A strong, documented response shows reasonable care, reduces penalties, prevents shipment seizure, and protects your company from long-term exposure.

What’s Included

1. Rapid Evidence Gathering

  • On-site factory verification within 1–3 business days of engagement

  • Immediate collection of production, shipping & payment records

  • Secure transfer & storage of all evidence with date stamps and version control

2. Supplier Affidavits & Legal Documentation

  • Affidavits covering origin, valuation, and classification

  • Retroactive contracts or contract upgrades with penalty clauses

  • Legal narrative drafted with local counsel in China & Vietnam

3. Classification & Valuation Review

  • HTS classification check for each SKU (including composites/essential character)

  • Cross-check against CBP binding rulings and precedent decisions

  • Valuation worksheets for assists, royalties, commissions, molds

  • Invoice-to-bank wire reconciliation to prove declared values

4. Country of Origin & AD/CVD Verification

  • Substantial transformation analysis to prove COO claims

  • AD/CVD scope screening against Department of Commerce orders

  • On-site confirmation of actual production location

  • COO Determination Memo designed to withstand CBP challenge

5. Pre-Entry Internal Audit

  • Cross-review: invoice, packing list, BL, ISF, 7501 entry summary

  • Identify & explain discrepancies before CBP finds them

  • Broker coordination to ensure filings match evidence

6. Supplier Non-Cooperation Handling

  • Direct negotiation to secure supplier compliance

  • Documentation of refusal, proving good-faith effort

  • Alternate strategies: third-party audits, alternate suppliers, or stop sourcing

7. Penalty Mitigation & Post-Case Support

  • Evidence file built to prove reasonable care

  • Advisory on penalty mitigation submissions

  • Post-audit corrective actions: contract updates, compliance refresh, prevention steps

Typical Response Timeline

  • Day 0 – Engagement & case review

  • Days 1–3 – On-site factory visit & evidence collection

  • Days 2–5 – Drafting affidavits, reconciliation worksheets, legal memos

  • Before CBP deadline – Full response file delivered to your broker or counsel

Investment

  • Typical cost: USD $9,000 – $26,000

  • Pricing depends on:

  • Urgency of deadlines

  • Supplier count

  • SKU complexity

Each case is quoted individually based on CBP deadlines and immediate needs.

Why Asia Agent

  • Speed – On-site in China & Vietnam within days

  • Legal Support – Contracts & memos prepared with licensed lawyers

  • Supplier Leverage – We negotiate, escalate, and document refusals

  • Full Coverage – Classification, valuation, origin, UFLPA, AD/CVD all addressed in one file

  • Penalty Defense – Evidence built to prove reasonable care and reduce liability

Next Step

If you have already received a CF-28, CF-29, detention notice, or audit letter, contact us immediately.

We will scope your case, contact your suppliers, and begin building the audit response file to meet CBP’s deadline.

GET STARTED
FAQs

CBP Audit Response – FAQ

You have questions—and in an active audit, time is everything.

When CBP issues a CF-28, CF-29, or detains your shipment, even compliant businesses can get caught short if they don’t respond fast with solid proof.

These FAQs explain how our CBP Audit Response service works, how we mobilize boots on the ground, and how we build the evidence and affidavits you need to protect your shipments and close cases quickly.

It’s our emergency service when CBP has already issued a CF-28/CF-29 or detained your shipment. We gather evidence, secure affidavits, and build a defense file within the short deadlines CBP sets.

Readiness = insurance before an audit, with contracts and reports in place.


Response = rapid action during an audit, detention, or penalty inquiry. Most clients need both, but Response is for urgent cases.

We mobilize in 24–72 hours in China or Vietnam. Our local teams visit factories, collect documents, and start drafting affidavits immediately.

 

A complete Audit Response File including:

  • Supplier affidavits & origin/value declarations

  • BOMs and HS code mapping

  • Invoices tied to payment proof

  • Photos/videos from factory visits

  • Legal narrative to demonstrate “reasonable care”

We escalate using legal tools—contracts, penalty clauses, affidavits drafted under local law. If they still resist, we document their refusal so CBP sees you acted in good faith.

 

No one but your broker or counsel can formally respond. We work behind the scenes—preparing the evidence, affidavits, and legal narrative your broker files on your behalf.

Yes. We conduct forced-labor screenings, gather upstream supplier docs, and prepare traceability files to address UFLPA-related holds.

We can still step in. Even without prior setup, we audit your supplier on-site, build affidavits, and prepare a defense file from scratch.

We fast-track factory visits, prepare the evidence, and coordinate with your broker to respond within CBP’s deadline. Every day matters—detention fees build fast.

We help you prepare supporting documents to contest or mitigate them. We also provide a legal trail showing you exercised “reasonable care.”

Yes. We prepare the full evidence packet and coordinate with your broker to file it on time.

Yes. We assign separate teams if needed. Each supplier gets its own evidence set and affidavits.

CBP can issue default penalties, duty bills, or even seize goods. Our service is designed to prevent that by meeting deadlines with complete files.

No one can guarantee CBP’s decision. But presenting a complete, verified, and well-organized file gives you the strongest possible chance.

Yes. Where possible, we backfill weak POs with retroactive contracts and affidavits signed under local law, proving you demanded compliance even before the audit.

Send us the notice and entry details. We immediately review it, deploy a team to your supplier, and start building your response file.

We focus on China and Vietnam, where most of today’s audits and detentions occur. Both hubs are fully covered with local teams and legal support.

Without a strong response, an audit can escalate into hefty retroactive duty bills, steep penalties, or even a criminal case if CBP believes there was negligence or fraud.

The ultimate benefit is that we give you the highest possible chance to avoid or reduce those outcomes. By delivering supplier affidavits, contracts, and a complete defense file on time, we show CBP you acted in good faith and exercised “reasonable care”—your strongest legal shield against fines or prosecution.

Explore Related Compliance Services

  • General Audit Preparedness
    Build a compliance file before CBP knocks. We prepare U.S. importers for Focused Assessments, valuation reviews, and customs risk management.
    ➡️ Link: /general-audit-preparedness

 

 

  • UFLPA-Specific Compliance
    CBP is detaining shipments under the Uyghur Forced Labor Prevention Act. We provide the affidavits, proof of no forced labor, and rebuttable presumption evidence you need.
    ➡️ Link: /UFLPA Compliance Services

 

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Experiences That Inspire

Discover the experiences and testimonials of our clients as they share their thoughts on collaborating with us, highlighting the exceptional service they received and the impressive outcomes they have accomplished.
 
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"From negotiating better contracts to providing legal and quality control support, Asia Agent has saved us time and money"

Olivia Martinez
SmartTech26 Gadgets
David Cohen

"The hands-on approach of Asia Agent’s team was impressive. We appreciated the weekly updates and transparent processes. "

Emma White
MyGreenLife
Emma White

"I was worried about moving production out of China, but Asia Agent made the transition stress-free.attention to detail and extensive network ensured we found reliable factories.

Jonah Bernstein
Trendy Tees
Jonah Bernstein

"Asia Agent’s expertise in managing supplier relationships and legal contracts is unmatched. They understood our needs and delivered beyond expectations. "

Priya Nair
Ur-bans Solutions
Priya Nair
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Have More Questions About Our Service?

We know that making strategic decisions about your supply chain can raise questions. Our team is here to help you fully understand how our Enhanced Supply Chain Mapping service can align with your business goals and drive your success.

 

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Our dedicated customer service representatives are ready to guide you through our offerings and answer any questions you may have.

 

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