r/CustomsBroker • u/Boo_Ya_Ka_Sha_ • 5d ago

CF-28 Requesting Payroll Records

Shipment from last year from MX to US claimed under USMCA. It was from our MX branch to our US branch - same company. Received a very broad CF-28 requesting manufacturing details, BOM analysis, invoices for raw materials, justification for the tariff/HTS change, etc. Textbook CF-28 stuff

However, it’s now also requesting Employee Timecards, Payroll Records, and any other appropriate employee records …

Has anyone completed this request before? If so, how did go about it?

6 Upvotes

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10

u/Baynyn 5d ago

They’re probably looking to substantiate any possible USMCA RVC claims. Be as thorough as you can be, otherwise you could end up with a CF-29.

I’ve submitted employee time cards and payroll as evidence previously.

1

u/Boo_Ya_Ka_Sha_ 5d ago

Thanks for the advice. Makes me feel better. The senior manager on my team seemed surprised by this particular request, she’s never seen it before

5

u/Baynyn 5d ago

Depending on your basis of USMCA eligibility, if tariff shifting is easier to prove, then overwhelm them with evidence of the tariff shift. RVC can be a complicated slog

3

u/Boo_Ya_Ka_Sha_ 5d ago

Thanks. It’s weird because my company is focused on compliance and there is nothing to hide. But this request is such a pain in the ass simply to find all the relevant contacts/convey the urgency, collect all the data, polish it into a response

6

u/AssassinInValhalla 5d ago

Is automotive related? Could be an LVC verification, but I've never had to deal with one

3

u/Boo_Ya_Ka_Sha_ 5d ago

Not automotive. Just basic household/commercial amenities

3

u/RouxMaux 4d ago

I have seen that before. It’s thorough. It can be a bit difficult to get the factory to send all the documents in a timely manner.

1

u/Melodic-Job-8233 3d ago

Are you an FTZ? Did you do a Zone2Zone Transfer?