Guide on US Customs Holds and Exams

March 12, 2025
9 min
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Home Insight Guide on US Customs Holds and Exams
Written by
Atlantic Project Cargo Editorial Team

Key Takeaways

 

  • The US Customs and Border Protection (CBP) is an agency tasked with protecting the US from dangerous goods and people while facilitating legal trade and travel
  • Types of customs holds are Manifest, Commercial Enforcement, Statistical Validation, CET, and PGA
  • Types of Customs Exams are VACIS or NII Exam, Tailgate, Intensive, USDA, and FDA

Navigating US customs procedures can be complex, especially when shipments are subjected to holds or examinations. However, these inspections are crucial in ensuring compliance with trade regulations, security measures, and import laws. This guide provides an overview of US customs holds and exams, offering insights into what to expect and how to manage potential disruptions effectively.

By partnering with Atlantic Project Cargo, you do not have to worry about inspections or customs delays. We offer customs brokerage services to ensure your shipments flow easily across the border.

How CBP Safeguards Trade and Citizens

The US Customs and Border Protection (CBP) is among the largest law enforcement agencies globally. Its primary responsibility is to protect the United States from dangerous goods and individuals while also facilitating legal trade and travel.

Shipment Inspections

CBP officers utilize various tools to assess shipment risks. Additionally, a targeting system assists in determining whether cargo requires further inspection. If a shipment receives a score that alerts CBP, they may place a hold and carry out an examination.

The exact scoring details are not public, but factors likely include how often a shipper imports goods, the type of goods, and their country of origin. This information comes from shipping documents.

Customs declaration close up

Which Shipments are Chosen for Inspection and Why?

CBP selects shipments for inspection based on risk analysis and intelligence to pre-screen, assess, and examine suspicious containers.

Factors influencing selection include:

  • Incomplete or inaccurate documentation
  • Discrepancies in shipment details
  • Information from various sources that may indicate potential risks

How to Avoid Inspections

To reduce the chance of your shipment being inspected:

  • Ensure Complete and Accurate Documentation
    Provide all required paperwork accurately and in advance to your customs broker and carrier. This approach allows for the identification and correction of potential issues before the shipment reaches the border
  • Follow CBP Rules
    Understand and adhere to CBP policies and procedures, including specific entry requirements for your goods
  • Inspect Your Shipment
    Check containers carefully before shipping to ensure there are no security concerns that could trigger inspections. Using CBP’s 7-point inspection checklist can help.

You may also hire a trusted customs broker from Atlantic Project Cargo to help you prepare your shipment and avoid inspections.

Customs control zone sign on the gate

Customs Hold Types

Let’s explore what types of customs holds an importer may face.
 

Manifest Hold

It occurs when shipping details are missing or incorrect on the carrier’s manifest or the Importer Security Filing (ISF). If an importer does not have such a document or information, they should be prepared for this hold.
 

Reasons for a Manifest Hold

  • Incomplete or incorrect manifest information, e.g. mismatched details between the manifest and the actual shipment
  • Failure to submit the manifest on time to the authorities
  • Security concerns flagged by customs or border protection agencies

To resolve a Manifest Hold, the shipper or customs broker corrects the errors, provides missing information, or complies with agency requests.
 

Commercial Enforcement Hold

This hold is applied when other government agencies need to review the goods. They include the United States Department of Agriculture (USDA), the Consumer Product Safety Commission (CPSC), the Food and Drug Administration (FDA), and the Federal Communications Commission (FCC).
 

Reasons for a Commercial Enforcement Hold

  • Inaccurate or undervalued declarations, like misrepresenting the value of goods to decrease duties
  • Suspected violations of trade agreements or tariffs
  • Restricted or prohibited goods requiring special permits
  • Issues with country of origin labeling

To resolve this, review the customs notice and determine the exact issue. Then respond promptly and provide necessary documentation to avoid storage fees or shipment delays.
 

Statistical Validation Hold

It happens if statistical data submitted with the shipment, typically in the form of import/export codes or classification information, seem incorrect compared to past shipments.

Shipping containers at the port

Reasons for a Statistical Validation Hold

  • Incorrect or missing Harmonized System (HS) codes
  • If the shipment details, such as weight, quantity, or description, do not match the statistical data on file or the manifest
  • If the shipment appears inconsistent with typical trade patterns or anomalies are detected

To avoid this, ensure that all product classifications, values, and codes match the documentation and are accurate. If the hold occurs, provide any requested supporting documentation immediately.
 

CET Hold

The Customs Enforcement Team (CET) or a Customs Examination Team may hold shipments suspected of containing illegal goods, smuggling, and other contraband.
 

Reasons for a CET Hold

  • Suspicion of prohibited or restricted goods
  • Goods suspected of violating trade regulations
  • Potential counterfeit or trademark-infringing products
  • Shipments flagged under the Uyghur Forced Labor Prevention Act (UFLPA)
  • False claims to avoid tariffs or trade restrictions

If your shipment is under a CET hold, authorities may require additional documents, a physical inspection, or other verifications before releasing it.
 

PGA Hold

It refers to a shipment being placed on hold by a Partner Government Agency (PGA). This means that an agency other than customs, such as the FDA, USDA, EPA, or other regulatory bodies, needs to review and clear the shipment before it can proceed.

Unlike the Commercial Enforcement hold, the PGA hold is not directly imposed by the Customs.
 

Reasons for a PGA Hold

  • The shipment requires additional checks to meet safety, health, or environmental regulations
  • Missing or incorrect paperwork, e.g. permits or certificates
  • Certain goods like pharmaceuticals, food, chemicals, or electronics need approval from relevant agencies

Provide any missing permits, certificates, or compliance reports. Then wait for processing – the agency will review and decide on clearance. If delays persist, communicate with customs or the PGA to expedite processing.

Types of Customs Exams

Customs officer opening shipping container for inspection

Extensive customs exams help verify the contents of shipments, prevent illegal activities, and protect public safety. In Customs LA and other ports, these inspections are commonly performed to ensure import compliance.

VACIS Exam (Vehicle and Cargo Inspection System)

The VACIS exam, also known as the Non-Intrusive Inspection (NII Exam) or X-ray exam, involves scanning a container through an X-ray machine upon arrival. CBP reviews the images, and if everything appears in order, the cargo is released. If not, the exam may escalate to a more detailed inspection, such as a Tailgate or Intensive exam.

Note: Shippers are responsible for covering customs exam fees and any charges related to port delays, such as storage fees. For Less than Container Load (LCL) shipments, fees are divided among importers sharing the container.

Tailgate Exam

If CBP is not satisfied with the X-ray results, the cargo moves to a Tailgate or IBET customs exam. During this inspection, CBP officers break the container seal, open the doors, and visually inspect the contents. If no issues are found, the cargo is released. If concerns remain, the shipment proceeds to the most thorough exam — the Intensive exam.

Intensive Exam

The Intensive exam is the most detailed and labor-intensive inspection. The entire container is moved to a Customs Exam Site (CES), where the cargo is offloaded, unpacked, and thoroughly inspected. If the cargo passes, it is released. This exam can take from 5 to 7 days.

There are two types of Intensive exams:

  • CET Examination (Contraband Enforcement Team Examination)
    Focuses on detecting narcotics, drugs, and weapons
  • MET Test (Manifest Examination Team Test)
    Verifies importer documents to ensure compliance with tax and copyright regulations

Note: For LCL shipments, costs are divided proportionally among importers.

Customs officer opening a container for examination

United States Department of Agriculture (USDA) Exam

The USDA places a hold on shipments containing food or wood products to ensure they are free from diseases, pests, or insect infestations. Samples may be taken for lab testing.

Food and Drug Administration (FDA) Exam

The FDA inspects food and drug imports to ensure they comply with US safety guidelines. Samples may also be taken for lab testing.

How to Handle Customs Holds and Exams

You can minimize delays and additional costs during customs clearance by understanding holds and exams and preparing accordingly.

  • Prepare and Check Documentation
    Ensure all paperwork is accurate and complete
  • Be Available
    Stay accessible to your freight forwarder or broker for any additional information requests
  • Prepare Extra Budget
    Set aside extra cash for exam fees, demurrage, per diem, chassis rentals, or other potential charges

Work with a reliable freight forwarding company like Atlantic Project Cargo to avoid delays during the import process. Our certified customs broker ensures your documents are in order, saving you time and thousands of dollars.

US Customs Disposition Codes

Disposition codes are used to indicate the final status or action taken on imported goods after they have been processed by CBP. These codes help track the outcome of the customs process and ensure compliance with regulations. You may find the full list of disposition codes here.

These codes are part of the Automated Commercial Environment (ACE) system, which streamlines the import process. They help CBP and importers track the status of goods and ensure proper handling and compliance with US trade laws.

Port worker checking information in the tablet

Conclusion

While customs holds and exams are a routine part of the import process, they can create unexpected delays and added costs. By staying informed about the different types of inspections and understanding the reasons behind them, importers can take proactive steps to minimize risks and ensure a smoother clearance process.

Custom hold a package when they decide to inspect it. This could be due to missing documentation, suspected discrepancies, or the need for a more thorough examination.

A TMF (Transportation and Manifest Feedback) hold occurs when there is an issue with the shipment’s manifest or documentation. CBP places the hold to resolve discrepancies before releasing the cargo.

A 1H hold indicates that this might be a basic hold or a standard inspection, where customs authorities need to verify the goods, their origin, or other paperwork before allowing them to clear.

A 2H hold could be related to a more detailed inspection, often involving questions about compliance with trade regulations, duties, or product classification.

Typically, a 7H hold could be more serious, possibly indicating a higher level of scrutiny, such as when the goods are flagged for potential fraud or violations, or if further documentation or validation is required.

It means the shipment has passed all required inspections and is cleared to proceed to its final destination.

A “hold port” is a place where a shipment is detained for inspection or further review. The cargo remains at the port until the issue is resolved or the exam is completed.

The time it takes for cargo to clear customs varies depending on the type of exam or hold. Delays can also occur if additional inspections by agencies like the USDA or FDA are required.