US customs clearance for cargo shipped from China

The sequence, start to finish

A China-to-US container import has a fixed order of operations, and most of the delays people attribute to customs are actually a step happening late or out of order. In sequence:

1. Booking and ISF filing — ten importer data elements and two carrier elements, filed before the container is loaded in China.
2. Origin export — the container is stuffed, sealed, weighed (VGM), and cleared for export from China.
3. Ocean transit — typically 15–20 days to the West Coast and 28–35 to the East Coast via the Panama Canal.
4. Arrival notice — the carrier notifies CBP and the entry is filed, usually within a few days of arrival.
5. Entry and review — CBP matches the entry to the manifest. This is the point at which a mismatch is most likely to surface.
6. Exam or release — the container is either released, held for examination, or flagged for a more detailed review.
7. Delivery and demurrage clock — free time at the terminal is short, and the clock starts regardless of whether the entry is finished.

Two features of that sequence matter more than the rest. The demurrage clock runs independently of the clearance — it does not pause while an exam is in progress. And most problems originate at origin, in the data filed before loading, rather than in anything CBP decides at arrival.

ISF 10+2 in detail

ISF (Importer Security Filing, also known as 10+2) is a security measure that applies to cargo arriving in the US by ocean. It must be filed at least 24 hours before the container is loaded at the foreign port — in practice, before it is loaded in China. The ten elements come from the importer or buyer, and the two come from the carrier.

The importer's ten data elements are: manufacturer name and address, seller name and address, buyer name and address, ship-to name and address, container stuffing location, consolidator (if any), importer of record, buying party, country of origin, and the six-digit HTS (Harmonized Tariff Schedule) classification of the goods. The carrier's two are the vessel and voyage number, and the bill of lading number.

Two practical points that catch people out. First, the HTS code at ISF stage is a six-digit classification, not the full ten-digit US tariff line — it is a starting point, and the broker still determines the final code at entry. Second, late or missing ISF attracts penalties, and penalties are assessed per container. A missing ISF is also a reliable way to have a shipment held, and a hold costs far more than the filing ever would. We file ISF as soon as the booking is confirmed, which is why we ask for the supplier, buyer and HTS data at booking rather than at cut-off.

Entry types and the thresholds that decide them

At arrival, the broker chooses the entry type, and that choice follows from the value and the nature of the goods. This is the part of clearance most likely to change your landed cost, and the part most often left to the broker without the importer understanding it.

Two thresholds come up constantly. The $250 de minimis exemption applies to low-value informal shipments and, since recent rule changes, has been substantially narrowed for goods originating in China — many China-origin categories are no longer eligible regardless of value. And Section 301 duties are additional to the normal duty rate, are specific to Chinese goods, and are listed by HTS line. Because they are listed by classification, a code that is wrong by one digit can change the duty materially in either direction.

Tariffs, quotas and the fees on top

The duty you pay is the ordinary customs duty from the HTS line, plus any additional duties that apply to that line, plus the merchandise processing fee and the harbor maintenance fee, plus state use tax where the goods are delivered. For Chinese goods the additional duties usually mean Section 301 List tariffs, and certain steel and aluminium articles are also subject to Section 232 duties, which are quota-based and apply by product irrespective of origin.

This is also where HS classification earns its keep. Duty rate, Section 301 applicability, Section 232 applicability, quota status and marking requirements all hang off the classification. We flag the classification questions at booking because they are far cheaper to resolve then, and because a classification that is too high invites scrutiny while one that is too low creates an underpayment liability for the importer of record. Our documents guide covers the data we need from you to classify correctly.

Bonds and why the importer matters

A continuous or single entry bond is a guarantee posted with CBP that duties will be paid. It is required for formal entries and is normally issued by a surety. Freight forwarders typically post a bond on the importer's behalf as part of the clearance service, which is why the fee appears in a customs brokerage quote.

More important than the bond is who is the importer of record. The importer of record is the party that makes the formal statement to CBP: that the goods are correctly described, correctly classified, correctly valued and that duty will be paid. That statement is legal, and it is made by the importer of record, not by the broker who files it. Using your own forwarder as IOR is common and workable; the point is that somebody has to be it, and it should be a deliberate choice rather than a default.

Exams, holds and demurrage

CBP selects a portion of inbound cargo for examination. Two outcomes matter:

• VACIS exam — an X-ray or inspection of the container at a designated facility. The container is moved off-dated and must be returned, and the cost and the time are yours.
• Intensive exam — physical examination, sometimes with a notice of action that requires you to respond before release. These are more common where the classification or the declared value looks wrong.

A hold is different: it is a refusal of release pending information or compliance action, and it can last weeks. The usual triggers are a value that does not match between the invoice and the entry, an HTS code whose duty rate is implausible for the goods, a mismatch between the consignee on the bill of lading and the importer of record, missing or late ISF, or a prior compliance issue on the same importer number.

The expensive part is what happens while any of this is running. Terminal free time on US import containers is measured in days, not weeks, and demurrage and detention accrue daily from the moment the container lands. During an exam or a hold, that clock generally does not stop, so the clearance delay becomes a storage delay. This is the single strongest practical argument for filing accurately the first time: an exam costs hours, a hold costs thousands, and both are driven by data quality at origin that was under your control at booking.