CBP Exam / Inspection
5H holds, exam triggers, and how to respond when a container is flagged.
Overview
The 5H code (Entry Processing Hold) in CBP's Automated Commercial Environment has become, since early 2026, the most aggressive document-freeze mechanism CBP applies to China-to-US cross-border e-commerce and B2B trade. Unlike a physical Intensive Exam or a non-intrusive VACIS scan, 5H is a paperwork freeze first: CBP's Fast Doc Review unit cross-checks 100% of entry data through an AI-driven system before any physical inspection happens. Once a container is flagged 5H, it's frozen at the port — no pickup, no transfer — and if the documentation doesn't clear review, CBP can issue a forced Return Order or destruction notice within 30 days, with very little room for appeal. In the first half of 2026, the 5H flag rate at LA/Long Beach spiked above 30% at times and has since spread to ports including New York and Savannah.
Timeline
| Milestone | Window | Why it matters |
|---|---|---|
| Document submission window | 2-5 days | Broker must resupply genuine commercial invoice, packing list, purchase contract, even payment proof to support declared value — respond within 24 hours or demurrage starts stacking |
| CBP document review | 2-4 days | Fast Doc Review cross-checks submitted data; roughly 30% of fully consistent, well-documented cases clear directly to release (5I) |
| Escalation to physical exam | 3-7+ days if review fails | Container moves to a Centralized Examination Station (CES) for a 5-20% open-container spot-check |
| Release or forced-return decision | Within 30 days (statutory cap) | Even a released container typically carries $1,000-3,000 in combined demurrage, detention, and exam fees |
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Featured Guides
Trigger 1 — Undervaluation
CBP's pricing database now cross-references online and wholesale pricing; declaring more than roughly 30% below market or factory cost triggers an automatic flag
Trigger 2 — Vague HS classification
Misreporting HS codes to dodge anti-dumping duty, or vague invoice descriptions like "daily necessities" instead of precise product detail
Trigger 3 — IP infringement risk
The system is highly sensitive to brand marks and design patents; suspected counterfeits get held pending proof of authorization
Trigger 4 — Missing compliance certificates
Categories requiring FDA/FCC/CPSC/CPC certification, or wood packaging without IPPC fumigation marks, get held if documentation isn't filed with the entry
Trigger 5 — Importer/bond fraud
The crackdown target for shared-IOR "buy-in" clearance — shell companies, no real business address, abnormal EIN, or multiple unrelated sellers sharing one continuous bond
Prep Checklist
- ✓Stop using a shared broker IOR/bond ("buy-in" clearance) — it's the single biggest 5H trigger in 2026
- ✓Set up your own independent compliance entity: get your own EIN and a Continuous or Single Bond, and clear as your own Importer of Record
- ✓Keep the "three documents" mirror-consistent — B/L, commercial invoice, and packing list must match exactly on description, gross/net weight, and carton count
- ✓Declare values inside a defensible range and keep payment records on hand to prove it if challenged — don't follow a broker's lowball suggestion
- ✓Have FDA/FCC/CPSC/CPC certificates and IPPC wood-packaging marks ready before the entry is filed, not after a hold
Related Wiki
Customs Examination Types: VACIS, Tailgate, and Intensive Exams
The main types of CBP cargo examinations, the cost and time tiers for each, and how to manage shipments selected for exam.
Customs Bonds Explained: Single Entry vs. Continuous Bonds
What a US customs bond is, when single-entry vs. continuous bonds apply, and typical bond cost ranges by import volume.
Freight Forwarder vs. NVOCC: What's the Difference?
How freight forwarder and NVOCC roles differ in ocean shipping, and the fee structures and accountability each model implies.
What Is Demurrage? A Shipper's Guide to Container Storage Fees
What demurrage is, how it differs from detention and per diem, and the daily rate tiers shippers should plan around at West Coast ports.
What is Detention in Shipping? Fee Structure & Container Return Guidelines
Detention (per diem) fees explained: how daily rates accumulate outside port gates, and how to ensure timely empty container returns.
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FAQ
Same mechanism — the order just gets flipped in conversation. The actual CBP system code is 5H (Entry Processing Hold); standardize on that to avoid confusion with other hold codes.