Cost structure / standard tiers
Agency holds generate both direct exam fees and indirect demurrage exposure, since the demurrage clock continues to run during the hold.
| Hold Type | Typical Duration | Direct Cost |
|---|---|---|
| Document review only (no exam) | 1-3 business days | $0 direct fee, but demurrage clock continues |
| Physical exam at CES | 3-7 business days (incl. drayage to/from CES) | $300-800 (CES drayage + exam handling fees) |
| Lab sampling (FDA) | 5-10+ business days | $200-500 lab fee, plus demurrage during wait |
| Demurrage during hold (any type) | Accrues per terminal tariff | $150-400/day after free time |
| Re-export/destruction (failed review) | Case-dependent | Full cargo value loss + disposal fees |
Because demurrage continues during agency holds, the indirect cost of a multi-day hold often exceeds the direct exam fees themselves.
Risk mitigation / operational guidance
For commodities historically subject to FDA/USDA review, ensure required prior notices (FDA Prior Notice for food shipments) and certificates (such as phytosanitary certificates) are filed before vessel arrival, since missing documentation is a common trigger for holds that proper filing would avoid. Request free-time extensions from the carrier proactively when a hold is identified, citing the regulatory hold as the cause — some carriers grant goodwill extensions for documented government-caused delays, though this requires proactive request and supporting documentation. Work with a customs broker experienced in the specific commodity category, since brokers familiar with FDA/USDA filing nuances for a given product type can often prevent holds that generic filings trigger. If a CES exam is required, request priority scheduling where available and track the container's CES drayage status closely, since this leg often adds more delay than the exam itself.