How To Read A CBP Hold Notice And Respond Fast
A CBP hold notice is not a denial — it is a request for documentation, clarification, or examination. Importers who understand the hold code and the required response timeline can usually release the shipment without penalty. Those who ignore the notice or respond late risk abandonment, destruction, or liquidated damages under 19 CFR Part 172.
Before we start: hold release criteria vary by entry, port, commodity, and country of origin. The guidance below is drawn from publicly available CBP regulations and PGA instructions. Treat this as a planning reference, not a ruling on a specific entry. Consult a licensed customs broker for your specific case.
What a hold notice actually says
CBP typically issues hold notices through the Automated Commercial Environment (ACE) or via a paper CBP Form 6051S (Entry Summary) annotation. The notice will include:
- CBP case number / tracking ID — use this in all correspondence.
- Hold code(s) — EXAM, MAIL, STAT, PGA, etc. Each code maps to a different requirement.
- Required action — submit a document, correct a value, provide a sample, or appear for inspection.
- Response deadline — usually 30 days from notice under 19 CFR Part 103, but some PGA holds have shorter windows.
- Port and exam site contact — the specific CES or CBP office controlling the shipment.
Common hold codes and what triggers them
Not every hold is a physical inspection. Many are data holds. Knowing the code tells you whether you need a broker, a lab, or a lawyer.
EXAM — Intensive physical examination
An EXAM hold means CBP has selected the container or pallet for a full physical inspection. Authority: 19 U.S.C. § 1499; 19 CFR Part 151. The shipment is sent to a CBP exam site or a contracted Centralized Examination Station (CES). Storage and demurrage accrue while the exam is pending.
Release criteria:
- No prohibited or undeclared items found during inspection, or
- Any discrepancy is resolved with the importer (e.g., correct value, correct HTS code).
Common triggers: high-risk country of origin, incomplete invoice descriptions, unverified supplier history, or random selection under CBP's cargo selectivity model.
MAIL — Manifest discrepancy
A MAIL hold is applied when CBP detects a mismatch between manifest data and the entry summary, or when the bill of lading is incomplete or late. This is typically a data problem, not a physical inspection. Release requires corrected or supplemental manifest data accepted by CBP.
STAT — Statistical / administrative hold
A STAT hold is administrative. It often means CBP needs a corrected entry summary (CBP Form 7501), a revised invoice, or proof of a valid licensing agency permit. PGA holds (FDA, USDA, CPSC) frequently attach as STAT sub-codes.
PGA holds — Partner Government Agency
FDA, USDA, and CPSC holds are initiated by those agencies inside ACE. An FDA hold may require Prior Notice confirmation, no active import alert, and valid facility registration under FSMA (21 U.S.C. § 381). A USDA hold may require phytosanitary certification or APHIS permits. Release criteria are agency-specific.
How to respond fast
Speed matters, but accuracy matters more. Do not send a corrected entry or supplemental document until you have confirmed the exact deficiency. A rushed response that still misses the mark resets the clock.
- Read the hold notice carefully. Identify every hold code and every required action. If the notice references a specific CFR section or CBP instruction, look it up before you respond.
- Gather the exact document CBP asked for. If the notice says "provide certificate of origin," do not send a commercial invoice instead.
- Respond through your broker or ACE portal before the deadline. Late responses can result in abandonment under 19 CFR Part 172 or liquidated damages.
- Document your reasonable care. Keep a record of the notice, your response, and the release confirmation. This protects you if CBP later asserts a penalty for alleged false statements or failure to exercise reasonable care (19 U.S.C. § 1592).
- Verify PGA requirements before the next shipment. If FDA or USDA caused the hold, confirm Prior Notice, facility registration, and labeling requirements for the next identical shipment so it does not repeat.
When the shipment is released — and when it is not
CBP will issue a release notice through ACE or notify your broker. If the hold is released, the shipment proceeds to its destination. If CBP does not release within the response window, the shipment may be subject to:
- Abandonment — 19 CFR Part 172 allows CBP to deem abandoned merchandise after statutory periods.
- Destruction — perishable or restricted merchandise may be destroyed at the importer's expense.
- Export — the importer may be required to export the merchandise at their own cost.
Do not assume a hold will resolve itself. Contact the port directly or through your broker and confirm release in writing.
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Disclaimer: ClearanceIQ is an independent educational platform. We are not affiliated with CBP, FDA, or USDA, and nothing on this page is legal, tax, or customs advice. Hold release criteria vary by entry, port, commodity, and country of origin. Consult a licensed customs broker for your specific shipment.