INTERNATIONAL TRADE LAW
CBP Form 4647: Notice to Mark or Redeliver
CBP Form 4647 is the “Notice to Mark and/or Notice to Redeliver” — the notice U.S. Customs and Border Protection issues when goods it already released turn out not to be properly marked with their country of origin under 19 U.S.C. § 1304. It does one of two things: it tells you to correctly mark or remark the goods, or it demands that you redeliver them to CBP custody, and you have 30 calendar days to respond. Ignoring it is expensive: failure to comply can trigger liquidated damages up to the full value of the goods. This article explains what the form means, your options, and the costs of getting it wrong.
It’s a close cousin of the CBP Form 28 Request for Information — both are Customs notices an importer must answer on a deadline — but Form 4647 specifically concerns country-of-origin marking.
Why You Received a Form 4647
Nearly every imported article must be marked, legibly and permanently, with its country of origin so the ultimate purchaser in the U.S. knows where it was made (19 U.S.C. § 1304). CBP issues Form 4647 when it finds released goods that are unmarked, illegibly marked, or incorrectly marked. The notice identifies the entry, the marking deficiency, and what CBP wants done about it. For how to mark correctly in the first place, see our guide to country-of-origin marking rules.
Your 30-Day Options
You have 30 days from the date of the notice. Practically, there are three responses:
| Response | What it involves |
|---|---|
| Mark / remark | Bring the goods into compliance under CBP supervision and certify proper marking |
| Redeliver | Return the goods (or their containers) to CBP custody as demanded |
| Contest | If you believe the goods were properly marked or marking is excused, respond with documentation |
If you can’t act within 30 days, contact the CBP officer named on the form before the deadline — don’t simply let it lapse.
The Costs: Marking Duty and Liquidated Damages
Two financial consequences attach to a marking failure:
- Marking duty. Goods not properly marked are subject to a 10% ad valorem marking duty under 19 U.S.C. § 1304 — 10% of the value of the merchandise — in addition to ordinary duties.
- Liquidated damages. If you fail to comply with a redelivery demand, CBP assesses liquidated damages, generally up to the value of the goods (and up to three times the value for restricted or prohibited merchandise). These are claims against your customs bond.
Beyond the dollars, a marking-compliance history can mean closer CBP scrutiny of your future entries.
How to Respond and Prevent a Repeat
Treat the notice as a deadline-driven compliance task: confirm the deficiency, decide whether marking or redelivery is feasible, document everything, and respond in writing within 30 days. To prevent the next one, fix the root cause — instruct your supplier on marking requirements before shipment, verify marking at the point of import, and confirm your country-of-origin determinations are correct. A marking problem caught at the factory costs pennies; one caught by CBP after release costs the marking duty, the compliance scramble, and potentially the value of the goods. Marking sits within CBP’s broader oversight of imports, and unresolved violations can lead to penalties.
Frequently Asked Questions
What is CBP Form 4647?
It is Customs’ Notice to Mark and/or Notice to Redeliver — issued when imported goods already released are found not to be properly marked with their country of origin under 19 U.S.C. § 1304. It directs the importer to correct the marking or redeliver the goods to CBP.
How long do I have to respond to a Form 4647?
Thirty calendar days from the date of the notice. If you need more time, contact the CBP officer named on the form before the deadline rather than missing it.
What happens if I ignore a Notice to Redeliver?
CBP can assess liquidated damages against your customs bond — generally up to the value of the goods, and up to three times the value for restricted or prohibited merchandise — plus the 10% marking duty, and your future entries may face closer scrutiny.
What is the marking duty?
A 10% ad valorem duty under 19 U.S.C. § 1304 imposed on goods that are not legally marked with their country of origin, charged in addition to any ordinary duties owed on the merchandise.
A Form 4647 is a deadline, not a suggestion. Reidel Law Firm helps importers respond to marking and redelivery notices and fix the underlying compliance gap on flat-fee terms. Get an import compliance memo.
