CBP detained my shipment from China. What to do before you send the factory's letter.
A held shipment is worrying. It is also manageable, and there is an honest way through it. CBP wants to see who made your goods, where, from what, and who got paid.
For a good supplier, most of that proof already exists, in the factory, mostly in Chinese. The factory may offer an English certificate first. It means well, but a certificate is not the file. The records behind it are, and your broker can't collect them from the port.
Here is how to tell what kind of hold this is, how long you have, and what to do today. Then, if you want it, what we do.
What kind of hold is this?
An exam hold.
A detention notice.
A UFLPA detention.
CBP detained my shipment from China. What to do before you send the factory's letter.
A held shipment is worrying. It is also manageable, and there is an honest way through it. CBP wants to see who made your goods, where, from what, and who got paid.
For a good supplier, most of that proof already exists, in the factory, mostly in Chinese. The factory may offer an English certificate first. It means well, but a certificate is not the file. The records behind it are, and your broker can't collect them from the port.
Here is how to tell what kind of hold this is, how long you have, and what to do today. Then, if you want it, what we do.
A Withhold Release Order or a Finding.
A CF-28 or CF-29.
A redelivery demand.
How long do I have?
| Where you are | The clock | Source |
|---|---|---|
| Exam hold | CBP has 5 working days to release or detain | 19 U.S.C. §1499(c)(1) |
| Detention notice (general) | The date printed on the notice | The notice |
| UFLPA detention (potential input) | 30 days; up to two 30-day extensions, max 90, at the Port Director's discretion | CBP Operational Guidance, pp.36–37 |
| UFLPA (direct input) / CAATSA | 180 days | Same |
| WRO | 3 months to prove admissibility or export | Same |
| Finding | 30 days to petition; otherwise forfeit | Same |
| Redelivery demand | 30 days | Same, p.38 |
| CF-28 / CF-29 | The date on the letter | The letter |
Every clock runs from CBP's date, not the day you read it. The importer pays port storage while the goods are held, so an early start helps. Extensions can be requested and the Port Director decides, so plan on the first date.
Source: as marked. Storage: CBP UFLPA Enforcement FAQs (cbp.gov).
What should I do today?
In this order. None of it requires us.
1. Save everything. The notice. The entry number. The bill of lading. The 7501. The commercial invoice. Every email from CBP and from your broker, with dates. One folder.
2. Write down four things from the notice. Which authority it cites. Which port. The entry number. The name and contact of the CBP officer or import specialist.
3. Call your broker and ask three questions. Is this an exam, a detention, or an exclusion? Exactly what did CBP ask for? Read me the words. What's the date? Your broker will file the response. The records behind it come from your supplier in China.
4. If the notice cites forced labour, contact the CBP officer named on it. CBP's own guidance says to open that dialogue immediately. For other detentions, your broker usually does this. Ask them if they have.
5. Keep CBP contact with you and your broker. Ask the factory politely not to write to CBP, even just to explain. The entry is yours, so the answer should come from you and your broker, with the factory's records behind it.
6. Send records, not a certificate. The factory will probably offer one, and it usually means well. But it's a document the factory wrote about itself. CBP asks for the business records behind it.
7. Get your supplier's legal Chinese name and the factory's address. From the business licence, not the PI. If the name on your invoice is a trading company and the goods were made somewhere else, you've found CBP's question.
8. Follow your own money. Pull the wires. Which entity, which country, which account. If the money and the invoice disagree, that's the second question.
By the end of the day you should know which kind of hold this is, what CBP asked for in its own words, and whether your paperwork names the company that actually made the goods. That's enough to decide the next move, with us or without us.
Source: DOJ/DHS Trade Fraud Guide, July 2026, pp.3–5; CBP Forced Labor Enforcement Operational Guidance, June 2026
Why CBP asks, and what it means for your supplier
The rules behind a hold have good reasons. Keep forced labor out of the products people buy. Stop goods being routed through a third country to hide where they were made. Make sure honest factories aren't undercut by ones that cut corners. The result is better, safer products.
Here's what we see in the factories: most suppliers are good. They just haven't been asked for this before, and nobody has explained what CBP wants or why. Once someone sits down with them face to face and walks through it, most say yes. A few can't, and it's far better to find that out before the next order than at the port.
What is CBP actually asking for?
Whatever the notice cites, the file has the same shape. Ordinary business records that connect:
- the goods to a real manufacturer, at a real address
- that manufacturer to its inputs, and those inputs to a place and a party
- the money to the invoices
- the movement to the bills of lading
If the trail stops at the trading company, the file is incomplete. CBP's forced-labour guidance says that missing production information for even one supplier in the chain makes the submission insufficient. That is a good guide for every other kind of hold too.
Source: CBP Forced Labor Enforcement Operational Guidance, June 2026, Appendix B pp.49–50, Appendix E pp.56–57; DOJ/DHS Trade Fraud Guide, July 2026, pp.5–6.
Who made it, what it's worth, where it's from
Forced labour in the chain
Origin moved to a third country
What fails?
CBP isn't asking for a story. It's asking for records, and most of them already exist.
Why is the factory's letter the wrong first move?
The importer of record must use reasonable care on every entry and is liable for misstatements even when the broker prepared them.
A US court has already ruled that relying on the exporter and the broker doesn't remove that duty. So the factory's English letter, however well meant, doesn't answer CBP. It comes from a company that isn't the importer. The factory's real help is the records behind the letter.
Source: DOJ/DHS Trade Fraud Guide, July 2026, p.3 (19 U.S.C. §1484(a)(1); U.S. v. Golden Ship Trading Co.).
What we do, and what we don't
We get the China-side evidence. On site, in Chinese.
What we are not.
No notice yet?
Frequently Asked Questions
CBP holding a China shipment?
Bring the notice. Say the port and the entry number. We tell you which kind of hold this is, whether a factory-side file can be built in the time you have, and what it costs. If it can't, we'll say so, and you'll know before the clock runs out instead of after.
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Where we are
Hong Kong, Guangzhou, Foshan, Shenzhen, Yiwu and Jinan.