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Certificate_of_Origin_CB-1024.pdfCertificate of origin · 1 pagePDF
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CBP Form 28 · CB-1024Draft matter
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19 U.S.C. § 1401aCBP valuation guidance
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CBP Form 28 · CB-1024Draft matter
Assistant
CBP Form 28 Response · CB-1024
Draft · Not filed
Export
Draft for reviewAugust 16, 2026
Response to CBP Form 28
Dear CBP Officer:
We submit this response to CBP Form 28 concerning entry CB-1024 and the merchandise described in commercial invoice INV-2026-04812. Enclosed are the commercial invoice, certificate of origin, bill of lading, and the cited valuation authorities. This draft remains subject to factual confirmation and filing review.
Origin. The invoice identifies line 3 as 500 lithium-ion cells, model 18650, with an invoice value of $14,220 and Vietnam listed as the country of manufacture1. The certificate of origin likewise identifies Vietnam for those cells2. The bill of lading shows loading in Shanghai and discharge in Long Beach3. The shipping point does not by itself establish country of origin, but the route should be reconciled with the Vietnam declaration. Before filing, the case materials should include a supplier production statement and any transshipment documents tracing the goods from Vietnam through China. If those documents do not substantiate the declaration, the origin position should be revised rather than presented conclusively.
Customs value. The invoice shows a total of $22,220 on FOB Shanghai terms, including $14,220 for line 31. Under 19 U.S.C. § 1401a4, transaction value begins with the price actually paid or payable and includes specified additions when applicable, including packing costs, selling commissions, assists, royalties or license fees, and proceeds accruing to the seller. The matter file indicates that importer-provided engineering drawings may relate to the imported cells. Before filing, confirm whether the drawings are an assist under 19 C.F.R. § 152.1035, determine their value, and apportion any dutiable amount to the affected merchandise. The FOB term should also be reconciled with the freight-collect bill of lading so international freight is neither included in dutiable value nor deducted twice. Written confirmation should address packing, commissions, royalties, proceeds, and proof of payment.
Requested disposition. Based on the materials provided, the invoice and certificate support the declared origin, subject to the additional production and transit documentation described above. The invoice provides the starting point for customs value, subject to verification of additions and freight treatment. Please accept the enclosed materials as our response and advise whether CBP requires supplier documentation, assist calculations, payment evidence, or any further explanation.
Respectfully submitted,
Acme Electronics
Trade Compliance
Invoice INV-2026-04812Certificate of OriginBill of Lading19 U.S.C. § 1401a19 C.F.R. § 152.103
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