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What is a CBP Form 4647 (Notice to Mark or Redeliver)?

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A CBP Form 4647 is a Notice to Mark and/or Redeliver. CBP sends it when your imported goods aren't marked with their country of origin the way the law requires. It asks for the goods to be marked, brought back to CBP, or both. CBP also uses it to call back released goods that can't enter for another reason, like an FDA refusal.

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What are the deadlines on a CBP Form 4647?
WhatDeadline or result
Released goods marked, or brought back to CBPWithin 30 days of the notice, or longer if CBP allows
Goods not marked or brought back in timeLiquidated damages equal to their entered value
Unmarked goods exported or destroyed under CBP supervisionBefore the entry liquidates, or a 10% marking duty is owed
A protest of a redelivery demandWithin 180 days of the written notice (entries made on or after Dec. 18, 2004)

Source: 19 CFR 134.2, 134.51, 134.54, 174.11 and 174.12(e)

What is a CBP Form 4647 for?

Two jobs. It can require the goods to be properly marked with their country of origin. And it can require redelivery, which means bringing the goods back into CBP custody. The form names the law or rule at issue and where the goods have to go.

How long do you have to respond to a CBP Form 4647?

For goods already released, 30 days from the date of the notice, or longer if CBP allows it for good cause. If the goods aren't marked or returned by then, CBP demands liquidated damages under the importer's bond, equal to the entered value of those goods.

Say released goods entered at $10,000 are still unmarked 30 days after the notice. The demand on the bond is $10,000. A redelivery demand for another reason has its own amount, up to three times the goods' value for restricted or prohibited goods, alcohol, or FDA-refused products.

How does a marking notice get closed?

One of three ways: the goods are properly marked, or they're exported or destroyed under CBP supervision. CBP watches the marking, at the importer's cost, unless it accepts a certificate of marking backed by a sample of the marked goods.

Goods left unmarked also owe an extra duty of 10 percent of their appraised value. That's avoided only if they're exported or destroyed under CBP supervision before the entry liquidates (becomes final).

Can a CBP Form 4647 be challenged?

Yes. A demand for redelivery can be protested. For an entry made on or after December 18, 2004, the window is 180 days from the date of the written notice. The 90 days in older CBP guidance is only for entries made before that date. Once the window closes, so does the usual way to challenge the notice.

Relief from liquidated damages is a separate route: a written petition to CBP's Fines, Penalties, and Forfeitures Officer.

Who receives and answers a CBP Form 4647?

It goes to the importer of record: in the ACE Portal if the importer's account is set to get CBP forms there, and by U.S. mail if not. A customs broker can get an electronic courtesy copy.

Marking and redelivery are entry matters, so the importer and their broker handle them. After an FDA refusal, they also arrange the export or destruction of the goods with the local FDA office and the cargo office at the CBP port.

Next step

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Related

  • Why is my shipment held at U.S. customs?
  • CBP “Under Review” vs “Hold Intact” — what the status means
  • How do I respond to a customs detention notice from CBP?
  • CBP Form 28 vs Form 29 (CF-28 vs CF-29): what's the difference between the two customs notices?
  • What documents does my customs broker need?
  • Why is CBP voiding importer of record numbers? (Form 5106 accuracy, from September 18, 2026)

Sources

  • CBP — Modernized Forms (Forms 28, 29, 4647) · read 2026-09-30
  • CBP — ACE Portal: Receive and Respond to CBP Forms (October 2025 quick reference guide: Form 4647 response options; U.S. mail is the default when no Portal mode is set) · read 2026-10-28
  • govinfo — 19 CFR 134.51, Procedure when importation found not legally marked (notice on CBP Form 4647; marking, export or destruction under CBP supervision) (CFR 2024, title 19 vol. 1) · read 2026-10-28
  • govinfo — 19 CFR 134.52, Certificate of marking (CFR 2024, title 19 vol. 1) · read 2026-10-28
  • govinfo — 19 CFR 134.54, Articles released from Customs custody (30 days; liquidated damages; petition for relief) (CFR 2024, title 19 vol. 1) · read 2026-10-28
  • govinfo — 19 CFR 134.2, Additional duties (10 percent marking duty) (CFR 2024, title 19 vol. 1) · read 2026-10-28
  • govinfo — 19 CFR 141.113, Recall of merchandise released from CBP custody (demand on CBP Form 4647; FDA refusals; liquidated damages) (CFR 2024, title 19 vol. 2) · read 2026-10-28
  • govinfo — 19 CFR 174.11, Matters subject to protest (a demand for redelivery to CBP custody) (CFR 2024, title 19 vol. 2) · read 2026-10-28
  • govinfo — 19 CFR 174.12(e), Time of filing protests (180 days for entries made on or after December 18, 2004) (CFR 2024, title 19 vol. 2) · read 2026-10-28
  • FDA — Letter to the trade on the CBP–FDA refusal notification process and the CBP Form 4647 Demand for Redelivery (September 19, 2022) · read 2026-10-28

Information current as of 2026-10-10.

Legal Disclaimer+

This report is an automated, informational screening tool only. Tiana & Co. is not a licensed customs broker and does not conduct customs business. This report does not constitute legal advice, a compliance determination, or a certification of admissibility for any supplier, product, or shipment.

Verdicts in this report are produced by deterministic code, not by a language model. The explanatory paragraph accompanying each check is model-generated and checked against the cited sources before delivery. No part of this report is reviewed by a person before it is issued, so every material finding and citation should be confirmed against the underlying government source before it is relied on.

This report reflects data available as of the report date. The OFAC SDN and Consolidated lists, the other U.S. Consolidated Screening List constituents, the UFLPA Entity List, CBP withhold release orders, CPSC's eFiling list, and regulatory guidance are updated frequently and without prior notice. Users should re-screen periodically and consult qualified counsel for compliance decisions.

Name-similarity results do not establish or rule out the identity of any company. Where multiple similarly named records exist, none should be treated as confirmed without independent verification against the primary government source.

This tool is not affiliated with, endorsed by, or a substitute for U.S. Customs and Border Protection, the U.S. Department of the Treasury, the Consumer Product Safety Commission, or any other government agency. No warranty is made as to the accuracy, completeness, or currency of any finding.

Use of this report for import, procurement, sanctions-compliance, or investment decisions is at the user's own risk. Anyone with compliance obligations under UFLPA, OFAC, or CPSC regulations should consult qualified legal counsel before making a transactional decision.

Legal Disclaimer

This report is an automated, informational screening tool only. Tiana & Co. is not a licensed customs broker and does not conduct customs business. This report does not constitute legal advice, a compliance determination, or a certification of admissibility for any supplier, product, or shipment.

Verdicts in this report are produced by deterministic code, not by a language model. The explanatory paragraph accompanying each check is model-generated and checked against the cited sources before delivery. No part of this report is reviewed by a person before it is issued, so every material finding and citation should be confirmed against the underlying government source before it is relied on.

This report reflects data available as of the report date. The OFAC SDN and Consolidated lists, the other U.S. Consolidated Screening List constituents, the UFLPA Entity List, CBP withhold release orders, CPSC's eFiling list, and regulatory guidance are updated frequently and without prior notice. Users should re-screen periodically and consult qualified counsel for compliance decisions.

Name-similarity results do not establish or rule out the identity of any company. Where multiple similarly named records exist, none should be treated as confirmed without independent verification against the primary government source.

This tool is not affiliated with, endorsed by, or a substitute for U.S. Customs and Border Protection, the U.S. Department of the Treasury, the Consumer Product Safety Commission, or any other government agency. No warranty is made as to the accuracy, completeness, or currency of any finding.

Use of this report for import, procurement, sanctions-compliance, or investment decisions is at the user's own risk. Anyone with compliance obligations under UFLPA, OFAC, or CPSC regulations should consult qualified legal counsel before making a transactional decision.

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© 2026 Tiana & Co. LLC · Import Intelligence for small importers · Not a licensed customs broker. Not legal advice. Sources and retrieval dates are shown with each result.