Customs Holds and Exams on Ocean Cargo: Why They Happen and How Good Data Prevents Them


By GDZ Computer Services · Updated 2026-10-21 · 8 min read · Blog › U.S. Customs and compliance

CBP holds ocean cargo for two broad reasons: it wants to look at the cargo, or it cannot trust the data describing it. You cannot control the first, but you can control the second, and the second is where most avoidable delays come from. This guide explains the hold and exam codes CBP sends, the data problems behind them, and a practical checklist for carriers and NVOCCs.

Key takeaways
  • CBP tells carriers about holds and exams through disposition codes such as 1H, 3H, 7H, 2Q and 6H.
  • Vague cargo descriptions, wrong shipper or consignee data and missing ISF filings are the data problems carriers can actually prevent.
  • CBP may examine any imported shipment, and the importer bears the cost of preparing cargo for examination.
  • Cargo that is not entered in time can be ordered to General Order, adding storage costs and paperwork.
  • Seeing CBP status on the bill of lading record, not in a separate inbox, is what lets a team react the same day.

Holds, exams and Do Not Load: the vocabulary

When CBP acts on a bill of lading, ACE sends the carrier or NVOCC a status message with a disposition code. CAMIR Ocean Appendix D lists them. These are the ones operations teams see most often when cargo stops moving:

CodeName in CBP's listWhat it means in practice
1AEntered: intensive examination requiredAn entry has been filed and CBP will examine the cargo before release.
7H / 7INII exam ordered / removedA non-intrusive inspection (for example, an X-ray scan) has been ordered and the cargo is held until it is removed.
1HCBP hold placed at port of dischargeRelease is denied until CBP removes the hold.
3HOther Government Agency hold placed at port of dischargeAnother agency, posted through CBP, must clear the cargo first.
2O / 2QISF hold, no ISF on file / Do Not Load, no ISF on fileThe bill arrived without a matching Importer Security Filing.
6H / 6IDo Not Load / Okay to LoadInvalid cargo description, shipper or consignee; the cargo should not be loaded until the hold is removed.
1SOrdered to General OrderThe lay order expired with the cargo still not fully entered or released.
Code names from CBP's CAMIR Ocean Appendix D, Disposition Codes (January 2026).

Notice that the codes come in pairs: a hold placed and a hold removed. Cargo is only clear when every hold on the bill has its matching removal and a release has been posted.

Why CBP stops cargo in the first place

CBP describes its approach to cargo examination as risk-based: it uses intelligence from a number of sources to identify high-risk shipments and focus inspection resources on them, and it uses non-intrusive inspection technology to examine cargo without slowing trade. Its work with members of the Customs Trade Partnership Against Terrorism (CTPAT) is meant to let it examine cargo more selectively.

Targeting runs on data. The manifest and the Importer Security Filing are the first information CBP sees about a shipment, long before the vessel arrives. Under 19 CFR 4.7, the carrier's cargo declaration is due 24 hours before lading at the foreign port, and under 19 CFR 149.2, most ISF elements are due by the same point. When that data is vague or inconsistent, the shipment is harder to assess, and harder-to-assess shipments get a closer look.

The data problems that cause avoidable holds

Some exams are random or intelligence-driven, and no amount of good paperwork prevents them. But a large share of the holds operations teams deal with trace back to data the carrier or NVOCC controls:

  • Vague cargo descriptions. 19 CFR 4.7a says generic descriptions such as "FAK", "general cargo" and "STC" are not acceptable. Since September 27, 2025, ACE automatically rejects filings with insufficient descriptions (error 548), and CBP can place invalid-description holds.
  • Wrong parties. At the house bill level, the shipper should be the foreign vendor, supplier or manufacturer, and the consignee the party receiving the cargo in the United States, not the NVOCC or forwarder.
  • Missing or late ISF. CBP's disposition list includes ISF holds and Do Not Load messages for bills received with no ISF on file or with an ISF compliance issue. CBP's tips for importers warn that failing to meet ISF requirements could result in penalties, increased inspections and delay of cargo.
  • Wrong quantities. The manifested quantity must be the lowest external packaging unit. A container with 10 pallets of 200 cartons is manifested as 200 cartons, per 4.7a.
  • Container and seal mismatches. Container and seal numbers are required on containerized shipments, and CBP's code list includes a master/house container mismatch status.

Our companion articles on ISF 10+2 for NVOCCs and correcting a rejected ACE manifest go deeper on the first three.

Exams: what happens and who pays

CBP's guidance for importers is direct: under 19 U.S.C. 1467, CBP has the right to examine any shipment imported into the United States, and under 19 CFR 151.6 the importer bears any expense involved in preparing the merchandise for examination. CBP says it does not charge for the exam itself, but a selected shipment is generally moved to a Centralized Examination Station (CES), a privately operated facility that bills for its services. Transport to and from the exam site and storage add to the cost, and household effects are not exempt.

An NII exam (code 7H) is a scan; an intensive exam (code 1A) means the cargo is physically examined. Either way the container is not going anywhere until the exam is finished and every hold is removed. For an NVOCC, the practical job is communication: tell the consignee quickly, coordinate with the customs broker, and keep the bill record up to date so nobody releases cargo early.

CBP's importer tips also remind importers that the importer of record is ultimately responsible for the correctness of the entry documentation presented to CBP, even when a customs broker files it. Clean manifest and house bill data make the broker's job easier.

Other agency holds and General Order

Not every hold is a CBP decision. Code 3H marks a hold for another government agency, posted through CBP. The cargo cannot be released until that agency is satisfied and the hold is removed, so the customs broker and the importer usually need to work directly with the agency involved.

General Order is the other trap. CBP's disposition list includes an advisory two days before a lay order expires (pending eligible General Order) and an "Ordered to General Order" advisory when the discrepancy between the manifested and entered quantities has not been resolved by the end of the lay order. Cargo sent to a General Order warehouse costs more and takes longer to recover. Watching those advisories, and chasing the consignee or broker before they turn into an order, is cheap insurance.

A prevention checklist for carriers and NVOCCs

  1. Require a precise cargo description or 6-digit HTS number at booking, not at manifest time. Use CBP's list of unacceptable and acceptable descriptions as the house standard.
  2. Capture the real foreign shipper and U.S. consignee on every house bill, with full names and addresses.
  3. Confirm the ISF has been filed before the cargo is laden, and match the ISF to the bill of lading.
  4. Manifest the lowest external packaging unit, never "1 container."
  5. Check container and seal numbers against the equipment interchange and stuffing records before transmitting.
  6. Review every CBP status message the day it arrives and assign an owner to each hold.
  7. Track lay order advisories so cargo is entered before it can be ordered to General Order.
  8. Log every correction and its cause; repeated similar errors are what CBP may treat as negligence.

Seeing the hold where the work happens

Holds become expensive when nobody notices them. A disposition code sitting in an EDI mailbox does not help the person answering the consignee's call. The status should appear on the shipment itself, next to the bill of lading, the container and the invoice.

That is the design behind the ACE module in GDZ-ISIS: it uploads the manifest from the bills of lading already in the system and tracks CBP approvals, holds and inspections, along with in-bond cargo, General Order and Customs releases. If your team is still checking cargo status across several screens, schedule a demo and see it on one record.

Frequently asked questions

What is a Do Not Load message from CBP?

It is a disposition code telling the carrier the cargo should not be loaded for the U.S. CAMIR Ocean Appendix D includes Do Not Load codes for no ISF on file (2Q), an ISF compliance issue (2R), and an invalid cargo description, shipper or consignee (6H). Each has a matching removal code.

Who pays for a CBP container exam?

CBP says it does not charge for cargo examinations, but under 19 CFR 151.6 the importer bears the expense of preparing the merchandise for examination. That typically includes Centralized Examination Station fees, drayage and storage.

Can good paperwork prevent a customs exam?

Not always. CBP may examine any shipment, and some exams are random or intelligence-driven. Accurate descriptions, correct parties and a timely ISF do prevent the data-related holds and rejections that are within your control.

What is an NII exam?

A non-intrusive inspection, such as a scan, that lets CBP examine cargo without unloading it. In ACE ocean status messages, code 7H means an NII exam has been ordered and the cargo is held; 7I means it has been removed.

What does General Order mean for ocean cargo?

It means cargo that was not entered and released in time can be moved to a General Order warehouse. CBP sends an advisory two days before the lay order expires and another when the cargo is ordered to General Order, so watch for both.

Sources

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