The First 10 Days of January, How to Prevent Customs Delays Before They Start

Introduction

January is when small issues become expensive fast. A missing document, a late ISF, a questionable HTS, or a Partner Government Agency requirement can turn into holds, exams, storage charges, missed deliveries, and a lot of avoidable stress. CBP also reminds the trade community that cargo may be examined as part of its enforcement and facilitation mission. Customs and Border Protection

Below is a practical 10 day plan to reduce customs delays before your first January shipment arrives.

Day 1, Validate importer responsibilities and “reasonable care”

CBP guidance emphasizes that importers are responsible for exercising reasonable care in entry, classification, value, and compliance obligations. Customs and Border Protection+1

Do this today

1. Confirm the correct Importer of Record, EIN, and broker power of attorney status for 2026 shipments.
2. Review who approves HTS, value, and country of origin internally.
3. Write down a simple escalation path: purchasing, logistics, compliance, broker, legal.

Day 2, Clean up product data before it hits a CBP screen

Most delays start with data quality issues.

Do this today

1. Create a “golden SKU list” for your top items: description, HTS, duty rate, PGA flags, country of origin, manufacturer, and valuation notes.
2. Confirm your commercial invoice descriptions are specific and consistent, not generic.
3. For any new product, collect technical specs, materials, and use case before you ship

Day 3, Recordkeeping readiness, because audits start with records

CBP recordkeeping rules require keeping records for set periods, commonly five years from the date of entry for entry related records. eCFR+2Legal Information Institute+2

Do this today

1. Make sure you can produce your entry packet quickly: invoice, packing list, arrival, classification support, value support, origin support, and PGA documents.
2. Confirm where records live and who owns them, broker, importer, or both.
3. Test one file from start to finish, like a fire drill.

Day 4, Ocean shipments, confirm ISF timing and responsibilities

CBP states ISF is required and must be submitted no later than 24 hours before cargo is laden aboard the vessel. CBP Help Center+1

Do this today

1. Verify who is filing ISF, broker, forwarder, or importer.
2. Confirm you can provide the required data elements early enough to meet the deadline.
3. Set a rule: no booking confirmation is “final” until ISF data is validated.

Day 5, Make ACE visibility part of your daily routine

ACE is where many release statuses, holds, and messages appear. CBP provides training and reference guides for ACE and instructions for managing portal accounts. Customs and Border Protection+2Customs and Border Protection+2

Do this today

1. Confirm your ACE account structure and who has access. Customs and Border Protection+1
2. Review how your team will monitor cargo release status and holds. Customs and Border Protection
3. Set up a daily exception review for new holds, document requests, and PGA messages

Day 6, Know what triggers exams, and prepare for them

CBP explains that cargo examinations are part of enforcement and facilitation, and exams can occur even when documentation looks fine. Customs and Border Protection

Do this today

1. Pre assemble a “rapid response packet” per shipment: invoice, packing list, proof of payment, product specs, manufacturer info, and any certificates.
2. Confirm your warehouse and drayage partners can react quickly if cargo is moved to an examination site.
3. If you are CTPAT certified, make sure your broker flags that status consistently, since CBP lists reduced exams and front of the line type benefits among program benefits. Customs and Border Protection+1

Day 7, Forced labor compliance, do not wait for a detention

CBP provides UFLPA operational guidance and enforcement FAQs for importers. Customs and Border Protection+1

Do this today

1. Identify products and suppliers with higher forced labor exposure.
2. Collect supply chain tracing documents before you ship.
3. Align purchasing with compliance, so vendor onboarding includes traceability expectations.

Day 8, Confirm PGA requirements early

Many delays are not purely “CBP,” they are related to other government agency requirements that can place holds and issue messages in ACE cargo release. Customs and Border Protection+1

Do this today

1. Identify whether your products touch FDA, USDA, EPA, CPSC, or other PGA requirements.
2. Verify required identifiers and data, like product codes, registrations, prior notice, or certificates, depending on the agency and commodity.
3. Make sure your commercial documents match what the PGA expects.

Day 9, Reduce penalty risk with a correction mindset

U.S. law provides for penalties for material false statements or omissions made by fraud, gross negligence, or negligence. Legal Information Institute+1

Do this today

1. Track repeat errors: HTS, value assists, origin, quantity, missing documents.
2. Fix the process, not just the entry. Add a control step for high risk SKUs.
3. Document training and corrective actions.

Day 10, Run a January shipment simulation

Do this today

1. Pick one shipment that is either moving now or will ship in early January.
2. Walk it through the full lifecycle: ISF, documents, entry filing, PGA data, release monitoring, delivery.
3. Write down every failure point you find and assign an owner.

Quick rescue plan if a shipment gets held anyway

1. Identify the hold type and what agency owns it, CBP or a PGA, using ACE and broker messaging. Customs and Border Protection+1
2. Provide a clean, complete document set fast.
3. Avoid conflicting updates, assign one person to coordinate all responses.
4. Track costs daily, storage, demurrage, detention, exam fees, and escalate early.

How S.J. Stile Associates helps

1. Pre shipment document and data review to reduce preventable holds.
2. ISF management and exception handling for ocean freight. CBP Help Center
3. ACE visibility guidance and daily release monitoring workflows. Customs and Border Protection+1
4. UFLPA readiness planning and documentation strategy. Customs and Border Protection+1
5. CTPAT aligned security and compliance support for lower risk operations. Customs and Border Protection

FAQ

1) When is ISF due for ocean shipments

CBP guidance states ISF must be submitted no later than 24 hours before the cargo is laden on the vessel. CBP Help Center+1

2) How long do we need to keep entry records

CBP recordkeeping regulations commonly require keeping entry related records for five years from the date of entry. Legal Information Institute+1

3) What does “cargo examination” mean

CBP uses cargo examinations to enforce laws and protect the supply chain, and examinations can be selected based on risk factors and targeting. Customs and Border Protection

4) Why do PGA issues cause delays

Some agencies have authority to hold shipments and exchange “may proceed” type messages through ACE cargo release workflows. Customs and Border Protection+1

5) Does CTPAT help reduce delays

CBP lists benefits that include reduced examinations and front of the line style processing for inspections. Customs and Border Protection+1

6) Where can importers learn official ACE portal procedures

CBP publishes ACE training and reference guides and ACE portal account management guidance. Customs and Border Protection+2Customs and Border Protection+2

References

https://www.cbp.gov/border-security/ports-entry/cargo-security/examination
https://www.help.cbp.gov/s/article/Article-1868
https://www.cbp.gov/document/publications/reasonable-care
https://www.cbp.gov/sites/default/files/documents/Importing%20into%20the%20U.S.pdf
https://www.ecfr.gov/current/title-19/chapter-I/part-16
https://www.law.cornell.edu/cfr/text/19/163.4
https://www.help.cbp.gov/s/article/Article1840
https://www.cbp.gov/trade/automated/training-and-reference-guides
https://www.cbp.gov/trade/automated/how-to-use-ace/portal-managing
https://www.cbp.gov/trade/automated/ace-faq
https://www.cbp.gov/trade/forced-labor/faqs-uflpa-enforcement
https://www.cbp.gov/document/guidance/uflpa-operational-guidance-importers
https://www.cbp.gov/border-security/ports-entry/cargo-security/CTPAT
https://www.help.cbp.gov/s/article/Article-1869
https://www.law.cornell.edu/uscode/text/19/1592
https://www.cbp.gov/document/publications/mitigation-guidelines-icp-fraud-gross-negligence-negligence-1592

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.

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