Asia Agent: On-the-Ground CBP Audit Response in China & Vietnam
On-the-Ground CBP Audit Response
When CBP sends a CF-28, CF-29, detention notice, or audit letter, your ability to respond depends on the documentation behind your supply chain.
Most importers rely on brokers to gather documents.
We go directly to the factory floor.
Our teams in China and Vietnam collect supplier records, verify production details, draft affidavits, reconcile invoices, and assemble a complete audit response file ready for submission to CBP.
Why This Matters
CBP enforcement is increasing across:
• valuation
• classification
• country of origin
• forced labor (UFLPA)
• AD/CVD scope risks
Importers remain legally responsible for errors, even when suppliers cause them.
A strong, documented response demonstrates reasonable care, reduces penalties, prevents shipment seizure, and limits long-term scrutiny.
What’s Included
1. Rapid Evidence Gathering
On-site factory verification within 1–3 business days
Immediate collection of production, shipping, and payment records
Secure evidence transfer with time stamps and version control
2. Supplier Affidavits & Legal Documentation
Affidavits confirming origin, valuation, and classification
Retroactive supplier contracts or upgrades with penalty clauses
Legal narrative prepared with counsel in China and Vietnam
3. Classification & Valuation Review
HTS classification review for each SKU
Cross-check against CBP rulings and precedent decisions
Valuation worksheets covering assists, molds, royalties, commissions
Invoice-to-bank-wire reconciliation to support declared values
4. Country of Origin & AD/CVD Verification
Substantial transformation analysis
AD/CVD scope screening against DOC orders
On-site confirmation of production location
Country-of-Origin Determination Memo for CBP review
5. Pre-Entry Internal Audit
Cross-review of invoice, packing list, BL, ISF, and entry summary
Identification of discrepancies before CBP does
Coordination with brokers to align filings with evidence
6. Supplier Non-Cooperation Handling
Direct negotiation with suppliers
Documentation of refusals to demonstrate importer good faith
Fallback options including third-party audits or supplier replacement
7. Penalty Mitigation & Post-Case Support
Evidence file structured to demonstrate reasonable care
Support for penalty mitigation submissions
Post-case compliance improvements to prevent recurrence
Typical Response Timeline
Day 0 — Engagement & case review
Days 1–3 — On-site factory visit and evidence collection
Days 2–5 — Affidavits, reconciliation worksheets, and legal memos drafted
Before CBP deadline — Complete response file delivered to broker or counsel
Investment
Typical case range: $9,000 – $26,000
Pricing depends on:
• urgency of CBP deadlines
• number of suppliers involved
• SKU complexity
Each case is scoped individually.
Why Asia Agent
Factory access — our teams operate directly inside supply chains in China and Vietnam
Speed — on-site factory verification within days
Legal support — contracts and memos prepared with licensed lawyers
Supplier leverage — we negotiate, escalate, and document refusals
Full coverage — classification, valuation, origin, UFLPA, and AD/CVD risks handled in one response file
Penalty defense — documentation built to demonstrate reasonable care
Next Step
Received a CF-28, CF-29, or Detention Notice?
Contact us immediately.
We will review your case, coordinate with your suppliers, and assemble the documentation needed to meet CBP’s deadline.
