What Happens When a US Customs Shipment Is Held or Examined?

Quick Answer: Held or Examined? What It Means and What to Do First

Cargo held in customs is not cargo lost. If you just got word that your US shipment is “held” or “examined,” that notice isn’t a verdict. It’s the start of a process that runs on a clock, in a fixed order, and every day you spend guessing costs money.

Most importers miss this. Three completely different situations hide behind the word “held.” Different owner, different timeline, different price tag:

1. A CBP hold pauses release while CBP reviews entry data, documents, admissibility or a risk flag. Some holds clear after the filing broker supplies or corrects information; others lead to a physical exam.
2. A CBP exam means US Customs and Border Protection wants to physically look at your cargo. That can be a quick X-ray (VACIS), or a full container emptied by hand at a Centralized Examination Station (an intensive exam). Budget anywhere from $150 to $5,000+, and add storage charges for every day you wait.
3. A PGA hold comes from another agency (FDA, CPSC, FCC, USDA, EPA), not CBP. Separate track, separate paperwork, and it can land on top of a CBP exam.

Your first four moves, in order:

1. Confirm the type: ask for the notice. If you bought DDP and can’t get it, ask for three fields: the exam type, the CES handling the container, and the entry number.
2. Call the right party: your broker handles entry and document problems. Your broker and forwarder coordinate an exam. A PGA hold follows that agency’s process.
3. Prepare the evidence: gather the invoice, packing list, purchase contract, payment records and product certifications. Send them through the broker who filed the entry, after confirming what value and seller were declared.
4. Start the cost clock: get the exact last free day for demurrage and detention, then prepare to pick up the container as soon as it’s released.

The rest of this guide takes them one at a time: how to tell the three apart, what each exam type costs, why the exam fee is only the first bill you’ll see, who does what in the first 48 hours, and what your options are if it escalates.

Hold vs. Exam vs. PGA Hold: Which One Are You Dealing With?

Importers lose days because they treat every “your shipment is held” message as the same problem. It isn’t. Work out which one you’ve got before you do anything else.

A CBP hold pauses release while CBP reviews the entry, supporting documents, admissibility or a targeting flag. Sometimes the issue is straightforward: an ISF filed late or with mistakes, an HTS code CBP wants to question, a missing document, or a manifest that disagrees with the packing list. But a hold can also involve valuation, origin, intellectual property, forced labor, security or product-admissibility concerns, and it may lead to a physical exam.

Watch out for a newer one. Under rules effective September 18, 2026, CBP voids Importer of Record numbers when the Form 5106 data behind them is wrong or incomplete. That comes from an August 2026 Federal Register notice (91 FR 53627), the first piece of that year’s executive order on customs enforcement to actually bite. And while your IOR number is void, you can’t file entries at all. The cargo just sits at the terminal running up storage while you sort it out, and reinstatement takes about five business days after you resubmit Form 5106 with supporting documents (CBP’s voided importer record FAQs). So if your shipment “can’t even be entered,” check this first.

A CBP exam is a physical inspection. Their targeting system flagged your container, so it’s getting scanned, opened, or emptied. You can’t talk your way out of it. All you can do is wait, hand over documents when they’re asked for, and stay on top of the cost clock. Physical exams are commonly described by what happens to the cargo: a VACIS/NII scan, a tailgate inspection, or an intensive exam at a CES. CET or A-TCET is different: it identifies an enforcement team or hold, not a standard step between tailgate and intensive. Depending on the notice and port, a CET hold may lead to a limited physical inspection or a full intensive exam.

A PGA hold is a different agency entirely. FDA wants your food facility registration. CPSC wants a children’s product certificate. FCC wants equipment authorization for anything with a radio in it. USDA wants to inspect agricultural goods. Each one holds cargo under its own authority, runs its own process, and doesn’t wait for CBP. A pallet of power banks can be stuck on a CBP valuation question while FCC certification and UN38.3 battery test reports are still outstanding. A few agencies do give you a window into the queue: CPSC’s import shipment tracking tool shows status and remaining review time if you enter the entry number with the filer code. Mostly, though, each agency clears on its own schedule.

Read the Notice, or Get Three Fields

Ask for the actual notice, not a phone summary. The title gives you the exam type. The entry number and container number identify the shipment, and the named Centralized Examination Station (CES) tells you where the box is going. At gateways such as Los Angeles/Long Beach and New York/New Jersey, the CES or carrier controls the transfer and queue.

The terminal or CES usually issues the exam notice. CBP forms such as Form 28, Form 29 and Form 6051D normally appear later, if CBP finds a problem. If you bought DDP and aren’t entitled to the original notice, don’t lose days chasing it. Get the exam type, CES and entry number instead.

Who Can See the Hold

The broker who filed the entry sees the hold in ACE. The terminal or CES sends the exam notification to the party named on the bill of lading, often the US destination agent. If we filed the entry, we can usually get the notice quickly. If we didn’t, we may have to obtain it through that agent.

DDP buyers are often one or two handoffs away. Ask your seller to pass the request to the US broker or agent, and check the carrier and terminal tracking with the container number. A useful update should give you more than “it’s held”: you need the exam type, current location and key dates.

Customs Exam Types: Cost and Timeline

Industry guidance generally describes three primary physical exam formats: VACIS/NII, tailgate and intensive. CET or A-TCET is better understood as an enforcement-team or hold designation, not a fixed fourth level of inspection. A CET hold may result in a limited physical check or an intensive CES exam, so the operational instruction on the notice matters more than the acronym. The planning ranges below draw on published industry fee guidance from licensed brokers and forwarders. Actual invoices vary by port and CES, so treat these as planning numbers, not quotes.

Exam type	What happens	Typical fee range	Typical delay	Real-world delay
VACIS / NII	Container X-rayed at the terminal, never opened	$150–350	~1 day	1–3 days
Tailgate	Container opened at the terminal, officers look inside, minimal unloading	$300–500	1–3 days	Up to a week
Intensive (CES)	Container trucked to a Centralized Examination Station and fully devanned	$1,500–5,000+	7–14 days	3–6 weeks reported, longer with lab testing

If the notice says CET or A-TCET, do not estimate cost or delay from that acronym alone. Ask whether the operational instruction calls for a terminal check, a limited physical inspection or a full CES devanning. That instruction sets the practical cost and timeline.

The gap between the two delay columns matters more than the headline exam fee.

The “typical” column is where budgets die. Ask around and you’ll hear the same thing: intensive exams run three to six weeks in practice. At congested ports a container can wait weeks just for a slot. That official 7–14 day number covers the exam itself, not the line in front of it. Send a sample to a lab (routine for electronics, toys, cosmetics, and anything FDA or CPSC touches) and add another 10 to 14 days on top. Plan against the right-hand column. If it clears faster, good.

Misreading the exam type is a 10x mistake. Your forwarder says “it’s just an X-ray,” you pencil in $300 and one day, and then the notice turns out to say intensive examination. You’re off by roughly ten times on cost and two weeks or more on time. That’s why the last section starts with “get the notice and read the title line.” The exam type sets your cost model, your storage exposure, and what you have to tell your customer about the delivery date.

The Exam Fee Is Only the First Charge

The part that catches importers off guard: demurrage and detention keep running while your container is being examined.

Carriers say so in writing: MSC’s published US demurrage and detention conditions, for example, state that detention applies “while the container is undergoing U.S. customs examination.” The details vary by carrier — some start the detention clock from the release date when a box is held at an off-dock customs facility, and the terminal or warehouse bills storage separately. Work from the safe assumption: the clock is running. Check your own bill of lading terms, and never assume an exam pauses anything.

The numbers stack up fast. Once free time expires, demurrage at US ports usually runs $75–300 per container per day, and it climbs in tiers the longer the box sits. Per diem (detention) tends to start around $125–175 a day. A $2,000 intensive exam sounds painful on its own. Add two to five weeks of daily storage and it stops being the biggest number on the pile.

Here’s a real one, from an intensive exam we handled at the New York/New Jersey gateway. The container went to the designated CES there. The CES invoice came back at $3,514.80, and the $1,295 exam charge was one line on it. The rest was a fuel surcharge, 35 days of chassis rental at $35 a day ($1,225), a chassis stop-off fee, processing and facility fees, extra labor, a lift charge and drayage. Then the ocean carrier billed $3,060 in per diem for 17 chargeable working days after the 11 working days of free time ran out. One exam, about $6,575, roughly six weeks from gate to empty return.

That same shipment threw two more curveballs. Eleven cartons wouldn’t fit back into the container after devanning, so the CES re-palletized them, which meant sending both a container truck and an LTL truck to collect, plus a broker-signed delivery order and exchange pallets. Then the CES wouldn’t release anything until it had a Guarantee Letter covering the carrier’s accrued per diem, and only a company with an account on the CES’s own portal can issue one. We got it through the booking forwarder’s US agent. If your forwarder has no account relationship with the CES, build that into your timeline now, not on release day.

What to do with this, in order:

1. Get two dates: ask for the last free day for demurrage and the last free day for detention. The clocks may use different rules, so “11 free days” isn’t precise enough.
2. Prepare for release: line up the trucker, pickup appointment, delivery address and empty-return slot while the container is still at the CES. If cargo was re-palletized, confirm whether you need a second truck and whether the CES requires a Guarantee Letter. Ask whether your forwarder is seeking extra free time, but plan as if the answer is no. If charges approach the cargo value, calculate the cost of abandonment early; walking away doesn’t erase charges already incurred.
3. Audit the bills: in practice, you may have to pay before the cargo is released, then pursue corrections. Compare the CES invoice with the carrier’s per diem statement. Check for duplicated days, chassis billed after return, the wrong free-time date, and an exam charge repeated as “handling.”

Under the FMC’s rules, a demurrage or detention invoice generally must be issued within 30 days of the last charge, include required data, and give you at least 30 days to request mitigation, a refund or a waiver (46 CFR part 541). Put every correction in one email and ask for a revised invoice. For a larger claim, the FMC offers an informal small-claims procedure for claims up to $50,000.

Shipping LCL? You Can Pay for Someone Else’s Exam

If your cargo ships as less-than-container-load, there’s a risk you’ve probably never been told about: when a consolidated container is examined, the examination costs are typically split pro-rata among every importer with cargo in that box, allocated by each shipment’s volume or weight.

Read that twice, because it means your cargo can be perfectly compliant and still get unloaded, delayed and billed because someone else’s freight in the same box triggered the exam. You did nothing wrong. You still get an invoice.

No Incoterm fixes this, because it’s structural. Buy FCL and your exam exposure stops at your own container and your own declarations. Buy LCL and you inherit everyone else in the box: their product categories, their paperwork habits, their luck with CBP’s targeting system. Mix low-risk general merchandise with unregistered cosmetics or uncertified electronics and the whole container becomes a better target than either shipment would be on its own.

How often does this actually happen? Not often. Most LCL shipments cross without anyone opening the container, and you can’t move the odds anyway, because the trigger is usually sitting in someone else’s cargo. So treat this as a low-probability charge you want to recognize on sight, not a risk worth redesigning your shipping around.

Which makes the useful moves small ones:

• When you pick a consolidator or NVOCC, ask once how they allocate exam and devanning charges. Not on every booking, just once, while you’re comparing partners. A straight answer (“by CBM, and we forward you the CES invoice”) tells you a lot about how they’ll handle the rest of your problems too.
• Keep your own paperwork clean, because it’s the one part of that container you control. Clear product descriptions, correct HTS codes, ISF filed on time. None of that stops a co-loader from triggering an exam, but it keeps you from being the trigger, and it gets your cargo back out of the CES quickly once the box is open.
• When a pro-rata bill does land, ask for the CES invoice and the allocation basis, then check the split against your own CBM or weight. “Your share is $800” is a claim, not proof, and this is the one moment in the whole story where five minutes of checking saves you money.

Who Acts and in What Order (The First 48 Hours)

Under FOB, you and your broker usually receive the notice directly. Under DDP, it normally reaches your seller’s US forwarder or broker first, so expect one extra handoff. If possible, get the US broker’s contact and the entry number when the shipment departs.

In the first 48 hours:

1. Confirm the lane: hold, CBP exam or PGA hold? Get the notice or the three key fields: exam type, CES and entry number.
2. Route it correctly: the broker handles entry data and documents. The broker and forwarder coordinate an exam. FDA, CPSC, FCC, USDA and other agencies follow their own process. Ask early whether samples may go to a lab.
3. Match the evidence to the entry: prepare the invoice, packing list, contract, payment records and certifications. Send them through the filing broker, not directly to CBP. Before sending payment records, confirm the value and seller shown on the entry.
4. Prepare for release: put the demurrage and detention expiry dates on your calendar. Line up pickup and empty return before CBP releases the container.
5. Settle who pays separately: US rules place examination costs on the importer (19 CFR 151.6). Under DDP, whether your seller absorbs the bill is a commercial question. Our DDP guide explains how to put that responsibility into the quote.

Send this short message on day one:

About container [number]: (1) What exam type does the notice show, and can you send a copy? (2) What’s the entry number? (3) What are the exact demurrage and detention free-time expiry dates? (4) Is FDA, CPSC, FCC, USDA or another agency also holding the shipment?

If you bought DDP service from a forwarder, send it directly to that forwarder. If DDP was included in your supplier’s sales contract, send it to the seller and ask them to pass it to their forwarder or US agent. Discuss cost responsibility separately so it doesn’t delay the operational answers.

If It Escalates: Detention, Penalties, Seizure and Forfeiture

Most exams end with release. When they don’t, four different outcomes can follow, and they aren’t stages that every case passes through.

• Detention: CBP or a partner agency needs more information or suspects the goods may not be admissible. Common triggers include missing licenses or certifications, unresolved value or origin questions, possible forced-labor links, safety concerns, or lab testing. A Form 6051D detention notice means CBP is still deciding; it doesn’t by itself mean the goods will be seized.
• Civil penalty or liquidated damages: Money can be assessed even if the cargo is eventually released. Under 19 U.S.C. 1592, materially false statements or omissions caused by negligence, gross negligence or fraud can lead to civil penalties. Typical examples are undervaluation, misclassification, false country of origin or manufacturer, and hiding goods subject to antidumping or countervailing duties. A bond breach, such as certain filing failures, may produce liquidated damages instead. CBP lists these common trade violations.
• Seizure: CBP takes legal custody of the goods when it believes the merchandise itself is prohibited or was introduced contrary to law. Counterfeit goods, concealed or smuggled merchandise, prohibited items, and serious evasion or health-and-safety violations are common triggers. A classification or valuation mistake doesn’t automatically mean seizure; many cases end with extra duties, a correction or a penalty instead.
• Forfeiture: Seizure is the start of the property case. Forfeiture is the permanent loss of the goods after the administrative or court process, or when nobody successfully contests the seizure. The goods may then be destroyed, sold or otherwise disposed of by the government.

The path is not always exam → detention → penalty → seizure → forfeiture. CBP can release the cargo and assess a penalty later, or seize prohibited goods without first issuing a monetary penalty.

If you receive a seizure, penalty or liquidated-damages notice, the case normally goes to the Fines, Penalties and Forfeitures (FP&F) office. Follow the deadline printed on the notice; seizure petitions are commonly due within 30 days and can be filed through CBP’s ePetition platform. A separate protest may be available for certain CBP decisions, generally within 180 days of liquidation.

If you bought DDP, first identify the Importer of Record and the party named in the notice. If your forwarder or seller’s entity is the importer, you may not be the party entitled to petition. For a low-value shipment, legal fees can exceed the cargo value; for meaningful cargo, duty or penalty exposure, involve an experienced broker or customs attorney immediately. Do not re-route, re-label or re-declare cargo that has already been flagged.

How to Reduce the Odds Next Time

You can’t opt out of exams, but the odds aren’t random either. Three levers:

• Know your product’s risk tier. CBP and its partner agencies publish where enforcement is concentrated: UFLPA high-priority sectors (as of 2025 that list includes steel, aluminum, PVC, seafood and lithium), Section 232 steel and aluminum, anything under an antidumping or countervailing duty order, and regulated categories like food, cosmetics, toys and electronics. High-tier products get examined more, at every port. If you ship sensitive goods, keep the certifications packed and ready (FCC authorization, UN38.3 reports, FDA registrations) instead of scrambling for them after a hold.
• Keep your data clean. Accurate IOR and Form 5106 records, declared values that agree with each other, correct HTS codes, ISF filed on time. These are the triggers entirely inside your control, so don’t hand them over for free.
• Hedge anything with a deadline, at your own scale. Splitting an order across two containers is a big shipper’s move and it costs real freight, so for most importers the practical version is smaller: don’t quote your customer a date built on best-case transit, keep a buffer in what you promise, and for the few shipments that genuinely can’t slip (trade show samples, a seasonal restock, a Q4 FBA replenishment) send that part earlier or by air instead of betting the date on a single ocean container. Splitting doesn’t lower your odds of being examined either. It caps the damage when it happens.

Prevention is a topic of its own. Our import documents guide covers the paperwork side, from specific invoice descriptions to line-level HTS and clean ISF data, and our China to USA shipping guide covers product compliance by category.

FAQ

How long does a customs exam take?

VACIS often clears in 1–3 days, tailgate in several days, and intensive exams in 3–6 weeks once queue time is included. If the notice says CET or A-TCET, ask what physical inspection has actually been ordered—the acronym alone does not set the timeline. Lab testing can add another 10–14 days.

Who pays under DDP?

US rules charge the Importer of Record. Under a properly structured DDP shipment, that’s usually the seller’s setup, but the contract still needs to say who absorbs the bill. See our DDP guide.

What’s the difference between a hold and an exam?

A hold pauses release while CBP reviews entry data, documents, admissibility or a risk flag; some holds clear without a physical inspection. An exam means CBP physically inspects the cargo. A PGA hold from FDA, CPSC or another agency can run alongside either one.

What are VACIS, CET and intensive exams?

VACIS/NII is an X-ray. An intensive exam sends the container to a CES for a full devanning. CET or A-TCET is an enforcement-team or hold designation, not one fixed physical exam type; it may lead to a limited inspection or an intensive exam depending on the operational instructions.

Can a forwarder speed up an exam?

We can keep documents, transport and pickup moving, but we can’t cancel a CBP exam or move the container ahead of the CES queue.

Does free time stop during an exam?

Usually not. Check the bill of lading and get the exact demurrage and detention expiry dates. Audit the final invoice under the FMC billing rules.

What about DHL, UPS or FedEx shipments?

The same value, classification and PGA questions apply, but the courier acts as broker and requests information through its own system.

What do tracking codes such as 1H or 1I mean?

They’re operational hold and release codes, not exam types. Ask the filing broker what is held and why.