Customs Holds & Exams:
What Triggers Them

When CBP holds a container, the bill of lading status changes and your freight forwarder gets the notice. You see "1H" or "MET" or "X-ray" or "intensive" and rarely an explanation. Different holds mean different waiting periods, different costs, and different things you can do to resolve them.

The five exam types you will see

Exam Type	Code	Duration	Cost Range
VACIS X-ray	X	1 to 3 days	$200 to $400
Manifest Exam Tail	MET	3 to 7 days	$500 to $900
Partial Intensive	3H	5 to 10 days	$800 to $1,500
Full Intensive	1H	7 to 14 days	$1,500 to $3,000
CET (Centralized Exam Team)	CET	10 to 21 days	$2,000 to $4,500

The buyer pays for the exam. The bill goes to your customs broker, who passes it through. Costs include CET facility fees, drayage to and from the exam site, container handling, and lumper fees for unloading and reloading.

VACIS X-ray (lightest hold)

VACIS (Vehicle and Cargo Inspection System) is a non-intrusive gamma-ray scan of the entire container. The container is driven through a portal and CBP officers review the image. No unloading happens.

What triggers it: random targeting, manifest details that flag a profile, or anomalies CBP wants to look at without unloading.

Outcome: most VACIS exams clear within 1 to 3 days with no further action. About 15% escalate to a physical exam if the X-ray shows anomalies.

MET (Manifest Exam Tail)

The Manifest Exam Tail is a paperwork review. CBP holds the container in a yard or terminal while they verify the manifest, ISF, commercial invoice, and packing list against what they expect to see.

What triggers it: ISF discrepancies, late ISF filings, manifest data that does not match commercial documents, suspect shipper patterns.

What to do: respond to broker requests for documentation immediately. The faster CBP gets clean docs, the faster the hold lifts. Common requests: bill of lading copies, additional commercial invoices, country of origin proof.

Partial Intensive (3H)

3H is a partial physical exam. The container is moved to a Centralized Exam Site (CES) where some, but not all, of the cargo is unloaded for inspection.

What triggers it: targeted product categories (electronics, textiles, dual-use goods), past compliance issues, agent intelligence on the shipper or consignee.

What to do: be prepared to provide product samples, manufacturer documentation, and detailed bills of materials if requested. Get a customs broker who is local to the port; they can walk over to the CES and resolve issues faster.

Full Intensive (1H)

The container is moved to a CES and fully unloaded. Every box is opened, contents are inspected, and items can be sampled for lab testing. This is the most disruptive and expensive type of hold short of CET.

What triggers it: high-risk shipper profiles, prior ADD/CVD evasion, suspected IP infringement (counterfeits), suspected Section 301 evasion (origin laundering), agriculture/food safety issues, or random targeting based on CBP risk algorithms.

What to do: provide everything CBP asks for. Stonewalling extends the hold dramatically. If CBP suspects counterfeits, the goods can be seized and the importer can face penalties or criminal referral.

CET (Centralized Exam Team)

CET is a specialized inspection at a designated facility with the expertise to inspect specific categories: agricultural products, antiquities, dual-use items, certain chemicals, controlled substances precursors. CET holds run the longest, sometimes coordinated with FDA, USDA, or EPA.

What triggers it: importing goods within CET-monitored categories, or items that require specialty inspection.

Holds that are not exams

Beyond physical exams, CBP can also issue:

• Manifest holds: paperwork-only, often resolved within hours once the missing doc lands
• OGA (Other Government Agency) holds: FDA, USDA, FCC, EPA, etc. Each agency has its own process
• Importer Security Filing holds: ISF was late, missing, or has bad data. See our ISF 10+2 guide
• Liens and storage holds: not CBP. The terminal or warehouse has an unpaid bill

What actually triggers a hold

CBP uses Automated Targeting System (ATS) scoring based on dozens of inputs. Things that raise your risk score:

• New importer with no track record
• Shipper with prior violations
• HTS codes in high-enforcement categories (textiles, footwear, electronics with IP concerns)
• Low declared values that look unrealistic for the category
• Vague product descriptions on the commercial invoice
• Origin jurisdictions known for Section 301 evasion (origin transshipments)
• Late or amended ISF filings
• Manifest data that does not match other documents

How to lower your hold rate

You cannot avoid random exams. You can drop your overall hold rate by:

1. File ISF on time, every time. ISF must be filed at least 24 hours before the cargo is loaded onto the vessel.
2. Use precise product descriptions. "Plastic items" gets you held. "LED light strips, 5050 SMD, 12V, 30 LEDs per meter" does not.
3. Classify HTS codes correctly. Get a written ruling from your broker if the classification is unclear.
4. Use C-TPAT (Customs Trade Partnership Against Terrorism) certified supply chain. C-TPAT importers get reduced exam rates and front-of-line treatment.
5. Avoid suspect shippers and consignees. If your supplier has been sanctioned or had goods seized, expect more scrutiny.
6. Document origin claims thoroughly. If you are claiming Vietnam or Mexico origin to avoid Section 301, have manufacturing records ready.

What it costs you when held

Beyond the exam fee, every day a container sits accruing fees:

• Demurrage at the terminal: $100 to $300 per day after free time
• Detention if you have a container chassis on hire: $50 to $150 per day
• Storage at the CES if a 1H exam: included in exam fee for first 5 days, then daily
• Drayage costs to move to and from CES

A 14-day 1H exam on a 40 ft container can total $2,500 to $5,500 in exam fees plus demurrage. That is on top of any lost-sales cost from the delayed inventory.

What we do when our clients get hit

If a client of ours gets held, our broker partner notifies us within hours of the hold posting in ACE. We pull the CBP request immediately, gather the requested docs from the client, and respond within the same business day. We track 1H exam resolution times of about 8 days on average vs the industry 10 to 14.

The single biggest variable is response speed on documentation requests. The fastest brokers respond same-day. Slow brokers can add 3 to 5 days just on document turnaround.

Bottom line

CBP holds happen. The goal is not to avoid all exams (you cannot) but to minimize the avoidable ones and resolve the unavoidable ones quickly. Clean paperwork, precise product descriptions, on-time ISF, accurate HTS classification, and a responsive customs broker do most of the work.

Further reading

• ISF 10+2 filing guide
• CBP Form 5106 complete filing guide
• Import duties from China to the USA
• NVOCC vs freight forwarder