How to Handle CBP Holds and Examinations Without Disrupting Your Supply Chain

Introduction

In today’s global trade environment, disruptions to your supply chain can come from many directions. One of the less-visible but highly impactful issues is when shipments are placed on hold or subject to physical examination by the U.S. Customs and Border Protection (CBP). While such actions are part of maintaining border security and trade compliance, they can also create unexpected delays, extra costs, and logistical challenges. The good news is that importers and supply-chain managers can put in place robust strategies to minimize disruptions, reduce risk, and respond swiftly when a hold or exam occurs. In this blog we’ll walk you through why holds/exams occur, their impacts on your supply chain, best-practice preventive actions, reactive handling tips, and a short case-study to illustrate how it plays out in real life.

Why Holds and Examinations Happen

What are the holds/exams?

CBP can place a shipment on a hold (preventing its release) or initiate an examination (physical or non-intrusive inspection) of the cargo. U.S. Customs and Border Protection+3Flexport+3Iffusa+3

For example:

• A Manifest Hold: when CBP wants to verify the manifest or submitted data. Pangea Network+2Scarbrough Global+2
• A PGA Hold (Participating Government Agency): e.g., Food and Drug Administration (FDA), United States Department of Agriculture (USDA) may require additional checks. Flexport+1
• An Examination (non‐intrusive or physical): such as X-ray (VACIS/NII), tailgate inspection, or a full “intensive exam.” DeWitt Move Worldwide+1

Why are they triggered?

CBP uses risk-based targeting (secret algorithmic + manual) and draws on data such as origin country, commodity type, HS classification/valuation, importer history, shipper/forwarder history, and cargo documentation. Flexport+2DeWitt Move Worldwide+2

Some key triggers:

• New importer or unfamiliar supply-chain partner. Iffusa+1
• High risk country of origin or flagged commodity. DeWitt Move Worldwide+1
• Incomplete or inconsistent documentation (e.g., valuation, HTS code, packing list). Laufer+1
• Shipments consolidated with others where another party may trigger a flag. DeWitt Move Worldwide+1

What is the supply chain impact?

When a hold or exam occurs:

• The shipment may be delayed (days to weeks) before release. Flexport+1
• Extra costs may accrue: examination fees, drayage, storage/demurrage, repacking, etc. DeWitt Move Worldwide+1
• Inventory/planning disruptions: just‐in‐time (JIT) systems may be particularly vulnerable.
• As one customs broker noted on Reddit:
• “That’s one of the downsides to just-in-time inventory management… I’ve had to go back and explain that our broker is not at fault.” Reddit
• Reputational/risk profile implications: repeated holds may flag you as higher risk, increasing future scrutiny.

Proactive Strategies to Minimise Disruption

To reduce the likelihood and impact of holds/exams, consider these best practices:

1. Build a reliable compliance profile

• Choose vendors, shippers, forwarders, brokers with strong track records. A “clean” supply-chain history helps. DeWitt Move Worldwide+1
• If eligible, consider joining the Customs‑Trade Partnership Against Terrorism (C-TPAT): importers certified as low-risk gain fewer exams. Wikipedia+1
• Use a continuous entry bond, if applicable. Scarbrough Global

2. Ensure documentation and data accuracy

• File paperwork in a timely manner (ISF for ocean, manifest data, etc.). Flexport
• Validate HTS codes, valuations, descriptions, origin. Inconsistencies increase risk. Laufer+1
• Avoid high‐risk consolidations unless necessary. Smaller less‐controlled LCL shipments often get flagged. DeWitt Move Worldwide+1

3. Optimize your supply-chain buffer and planning

• Recognise that holds may happen , build some buffer into your lead times.
• Maintain safety stock for critical items so one hold doesn’t halt production/shipping.
• Diversify routing and origin/shipping modes if possible , avoid “single point of failure”.

4. Engage your logistics and customs team early

• Have a strong forwarder/customs broker like Stile, who monitors holds and can act quickly.
• Establish internal SOPs: when you receive a hold notification, who acts? How is internal communication handled? (As one broker said: “We do it as soon as we see the exam has posted.”) Reddit
• Consider pre‐filing or pre-submission of supporting documentation for high-risk commodities or PGAs.

Reactive Strategies: What to Do When a Hold/Exam Happens

Even with good planning, holds and exams may still occur. Here’s how to respond effectively:

1. Immediate notification & coordination

• As soon as you or your broker receive a “hold” or exam flag, notify relevant stakeholders (supply/execution teams, sales, customer service).
• Clarify with your broker: What type of exam? (X-ray, tailgate, intensive) Where (port, CES) What are the estimated timelines and costs? Flexport+1

2. Document & information gathering

• Provide any additional documentation requested by CBP or PGAs – invoices, packing lists, certificates of origin, licenses. Pangea Network
• Track container/commodity status , consider logistics of drayage, storage, re-routing.
• Ask whether transfer to a CES (Centralized Examination Station) is required. Ship4wd+1

3. Cost management

• Understand the cost structure: examination fees, drayage, storage/demurrage. DeWitt Move Worldwide
• Decide ahead: how will you bear or pass through additional costs? Is it within your Incoterms?
• Consider whether prioritising release of cargo (e.g., paying fees promptly) can reduce exposure.

4. Mitigation and communication

• Keep your customers and internal teams informed: delays, expected resolution time, what you are doing.
• Use the incident as a learning opportunity: log what triggered the hold, how long it lasted, what cost incurred.
• After release, review what process or supply-chain step you can improve to reduce recurrence.

5. Use alternate inventory routing if possible

• If the shipment is delayed, can you source from secondary inventory or alternate supplier to avoid disruption?
• Can you split shipments in future (e.g., part air freight, part sea) to reduce JIT risk?

Case Study (Illustrative)

Scenario: A US importer receives a container of electronic parts from Country X. The container is flagged for a VACIS (X-ray) exam by CBP due to a high-value commodity from a less-common origin. The manifest hold is triggered, and the goods are held at the port terminal while the exam occurs.

What happened:

• Documentation was complete but because the origin was flagged and the importer was relatively new, the risk score went up.
• The exam took 3 days (standard for VACIS) before release. Fees were incurred for drayage and storage.
• The importer had safety stock, so production was not halted, but re‐routing of shipments had to be accelerated for the next run.

What helped reduce the impact:

• Advanced notice from broker allowed internal teams to re-prioritise urgent orders.
• The company had diversified suppliers so they temporarily used a local stock to cover the gap.
• Post-incident review revealed that future shipments from Country X would include extra documentation proactively, and ISF filings were tightened.

Result: Minimal disruption to production, moderate extra cost, improved process for future shipments.

Conclusion

Holds and examinations by CBP may feel like random events outside your control, but with the right preventive and reactive strategies you can minimise the disruption to your supply chain. Building a robust compliance profile, maintaining accurate documentation, planning buffer inventory, partnering with experienced logistics/broker teams, and having a clear SOP for what happens when a hold occurs will pay dividends. When a hold does happen, swift communication, document readiness, cost-awareness and alternate routing help ensure your business keeps moving. As the global trade environment grows more complex, anticipating this risk becomes a mark of a resilient supply chain.

How Stile Associates Can Help

When a CBP hold or examination disrupts your shipment, time and experience make all the difference. Stile Associates has been navigating U.S. Customs procedures since 1968, with licensed customs brokers and logistics professionals who manage every step of the clearance process.

We coordinate directly with CBP and Centralized Examination Stations, track your container in real time, and make sure all required documentation is delivered promptly to avoid unnecessary delays or storage fees. Our team also reviews your entry data to identify what triggered the hold, helping prevent future occurrences.

Through proactive compliance programs, C-TPAT guidance, and detailed Standard Operating Procedures (SOPs), Stile Associates helps importers maintain continuous supply-chain flow, even when inspections occur. From New York to Miami and Los Angeles, our nationwide presence ensures your cargo moves efficiently and in full compliance.

Frequently Asked Questions (FAQ)

1. Why did CBP place my shipment on hold?
   CBP may hold a shipment to verify documentation, confirm product classification or valuation, or conduct a random inspection for security reasons. Shipments from new importers, high-risk countries, or with incomplete paperwork are more likely to be flagged.
2. How long does a CBP exam usually take?
   It depends on the type of examination.
   • Manifest or document hold: 1–2 business days
   • X-ray (NII/VACIS) exam: 2–5 business days
   • Tailgate inspection: 3–7 business days
   • Intensive exam: 7–21 business days or longer if multiple agencies are involved.
3. Who pays for CBP exam fees?
   The importer of record is responsible for any costs related to exams, including drayage, storage, and handling at the Centralized Examination Station (CES). These charges are not covered by CBP.
4. Can I avoid CBP holds completely?
   No importer can completely avoid holds, but you can reduce the likelihood by maintaining accurate documentation, partnering with experienced brokers, and participating in CBP’s trusted trader programs like C-TPAT.
5. What happens if my shipment is selected for an intensive exam?
   The container will be moved to a CBP-designated CES facility, unloaded, inspected, and then reloaded after clearance. This process may add cost and delay, but a qualified broker can help manage coordination and minimize disruption.
6. Can CBP open my shipment without notifying me?
   Yes. CBP has legal authority to open and inspect any imported shipment. However, your customs broker will be notified when a hold or exam status is posted.
7. How can I track whether my shipment is under exam?
   Your customs broker or forwarder can check the ACE/ABI system for exam notifications. Stile Associates provides real-time status updates and email alerts as soon as a hold or release occurs.
8. How can I speed up the release after an exam?
   Ensure all commercial documents (invoice, packing list, bill of lading, certificates) are accurate and available. Pay any exam or storage fees quickly, and maintain communication with your customs broker for the fastest release.
9. What if a Participating Government Agency (PGA) is involved?
   If agencies like the FDA, USDA, or EPA are part of the review, additional documentation or lab testing may be required. This can extend release time, so it’s critical to prepare these documents in advance.
10. What should I do after my cargo is released?
    Review the incident with your broker to understand what triggered the exam, document the costs, and adjust your procedures to avoid similar issues in the future. Stile Associates provides full post-entry analysis and compliance recommendations to strengthen your import profile.    

References

1. U.S. Customs and Border Protection (CBP).
   Cargo Examination Process and Procedures.
   https://www.cbp.gov/trade
2. U.S. Department of Homeland Security.
   CBP Trade Facilitation and Cargo Security Programs.
   https://www.dhs.gov
3. Flexport.
   Customs Holds and Exams: What They Mean for Importers.
   https://www.flexport.com/help/299-customs-holds-and-exams
4. DeWitt Move Worldwide.
   Understanding U.S. Customs Exams (VACIS, Tailgate, Intensive).
   https://www.dewittmove.com/customs-exam
5. Pangea Network.
   Types of U.S. Customs Holds and Examinations Explained.
   https://pangea-network.com/types-of-customs-holds-and-exams
6. Laufer Group International (LGI).
   Understanding U.S. Customs Notifications, Actions, and Exams.
   https://lgi.laufer.com/insights
7. IFF (International Freight Forwarders).
   U.S. Customs Holds and Exams Explained.
   https://www.iffusa.com
8. Scarbrough International, Ltd.
   U.S. Customs Exams Explained – What Importers Need to Know.
   https://scarbroughglobal.com/u-s-customs-exams-explained
9. Ship4wd.
   What Is a Centralized Examination Station (CES)?
   https://ship4wd.com/resource-center/glossary/centralized-examination-station-ces
10. CBP C-TPAT (Customs-Trade Partnership Against Terrorism).
    Benefits of the C-TPAT Program.
    https://www.cbp.gov/ctpat
11. Reddit r/CustomsBroker – Weekly Discussion Topic #42: Exams and Holds (2024).
    Practical insights from licensed customs brokers on CBP exam processes.
    https://www.reddit.com/r/CustomsBroker

Why Choose Stile Associates

• Trusted since 1968: Over 55 years of experience serving U.S. importers and global clients.
• Licensed U.S. Customs Brokers: Our team understands complex CBP regulations and policy updates.
• Technology-Driven Solutions: Real-time customs data, automated alerts, and document retention tools.
• Personalized Service: Each client is assigned a dedicated account manager for direct communication and follow-up.
• Commitment to Compliance: We help you reduce risk, save time, and maintain credibility with your trade partners and CBP

Beyond our history and licensure, Stile Associates has earned quality certifications that are a direct benefit to clients. The company is C-TPAT certified, a recognition from U.S. Customs and Border Protection (CBP) of a commitment to security and compliance. This certification offers tangible benefits, including faster clearance times and a lower likelihood of physical inspections, which directly reduces delays and disruptions to the supply chain. Additionally, Stile Associates is IATA-CNS and hazardous materials certified, demonstrating a comprehensive capability to handle a wide range of specialized shipments with the utmost care and professionalism.

Final Call to Action:

Ready to take control of your shipping costs?

Let’s talk. Contact Stile Associates for a free consultation and let our experts audit your current process, to help you streamline your operations, stay compliant, and save money.

Choose Stile, Your Smartest Move in Global Trade

Whether you’re shipping across the country or across continents, Stile Associates is your strategic partner for building a smarter, more resilient supply chain.

Since 1968, we’ve been delivering peace of mind and performance. Let’s take your logistics to the next level together.

Visit us at www.stileintl.com
Or contact: stevenheid@stileintl.com

Stile Associates – Trusted. Proven. Personal.

Stile Real Time Cargo Tracking with Global Visibility.