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CBP Form 3171: Application for Unlading, Lading, Overtime

Published: October 13, 2026  ·  12 min read
CBP Form 3171: Application for Unlading, Lading, Overtime
Photo: Griffin Wooldridge / Pexels

Key Points

On this page

  1. What CBP Form 3171 is
  2. At a glance
  3. Where CBP Form 3171 comes from in the regulations
  4. Who files CBP Form 3171 and when
  5. How CBP Form 3171 is filed and approved
  6. Overtime and reimbursable services under CBP Form 3171
  7. How CBP Form 3171 relates to manifests and other CBP forms
  8. Common CBP Form 3171 problems
  9. Frequently asked questions
  10. What importers and brokers should do
  11. Key references

The links in this article go to the primary documents: the regulations, the CBP form pages, and the official tariff schedule itself. Read the source.

CBP Form 3171, Application-Permit-Special License Unlading-Lading-Overtime Services, is the request a carrier, vessel master, aircraft commander, or their agent submits to CBP for permission to unlade or lade cargo, passengers, or baggage, and for CBP officer services performed outside regular hours of business. It is filed at the port of arrival or departure, before the work happens, and its approval is what authorizes the physical movement of goods off or onto the conveyance. CBP Form 3171 is not a cargo manifest and does not report what is on board; it governs when and under whose supervision the cargo may move.

At a glance

Where CBP Form 3171 comes from in the regulations

CBP Form 3171 exists because the customs regulations forbid unlading or lading merchandise from or onto an arriving or departing conveyance without a permit, and forbid doing that work outside regular hours without a special license. For vessels, 19 CFR 4.30 sets out the permit and special license structure: the master or agent applies, the port director grants or denies, and the grant carries conditions about supervision, location, and timing. For aircraft, 19 CFR 122.38 performs the same function for cargo and baggage coming off or going onto an aircraft. CBP Form 3171 is the single application document that carries both requests, which is why its title strings together application, permit, special license, unlading, lading, and overtime services.

The separation matters in practice. A permit answers the question "may this cargo come off at all, at this place, under this supervision." A special license answers the question "may that work occur at a time when CBP is not normally on duty." One filing of CBP Form 3171 can carry both, but a carrier may need only one of them on a given day.

Who files CBP Form 3171 and when

CBP Form 3171 is filed by the party responsible for the conveyance or the cargo operation, normally the master, the aircraft commander, the carrier, the terminal or stevedore, or an agent with authority to act for them. Importers and customs brokers rarely file CBP Form 3171 themselves, but they feel its effects directly: if the port has not granted the permit or the overtime license, the container does not come off the ship, the entry sits unreleased, and the delivery appointment slips.

Timing is the whole point of the form. CBP Form 3171 has to be in front of the port before the work is to be done, with enough lead time for the port to schedule an officer. Ports publish their own cutoffs for next-day and weekend overtime requests, and those cutoffs are local practice rather than a national number, so confirm them with the port director rather than assuming a standard. Where a carrier moves cargo on the same schedule week after week, ports commonly issue term permits covering repetitive unlading or lading across a stated period, so that a single approval stands in for a stream of individual CBP Form 3171 filings. Term permit availability, duration, and conditions vary by port and by trade.

How CBP Form 3171 is filed and approved

CBP Form 3171 is submitted to the port director at the port where the unlading or lading will happen, and the approval comes back as a signed or countersigned permit on the same document. The practical filing channel differs by port: some accept the form by email to a designated port mailbox, some require it at the entry branch counter, and some use a local scheduling system. Because there is no single national electronic channel for CBP Form 3171 in the way there is for manifest filing, the right first step at a new port is to ask the port how it wants the form and who signs it. The CBP forms library at cbp.gov carries the current version of the form, and using a superseded revision is an easy way to get a filing bounced.

Approval is not automatic. The port can deny or condition CBP Form 3171 where the facility is not an approved place for unlading, where the carrier has outstanding reimbursement obligations, or where no officer is available for the requested window. A denial on the overtime leg does not usually stop daytime work; it just means the operation waits for regular hours.

Overtime and reimbursable services under CBP Form 3171

CBP Form 3171 is the trigger for reimbursable overtime: when a port approves the special license leg and an officer works outside regular hours, the applicant is responsible for reimbursing CBP for that service under 19 CFR 24.16. The party that signs the application is the party on the hook, which is why agents should be careful about signing CBP Form 3171 in their own name for a principal who has not agreed to carry the cost. Reimbursement rates, rounding, minimum call-out practice, and billing cycle all sit outside the scope of this article; confirm them in the current text of 19 CFR 24.16 and with the port's finance office.

Charges arising from CBP Form 3171 are ordinarily billed and paid at the port like other port collections. When a payment is made at the port, the payer receives CBP Form 368, Collection Receipt, which is CBP's receipt for a payment of duties, fees, penalties, or bonds and the proof of payment to keep for a later refund request, protest, or audit. Keep the CBP Form 3171 and the matching CBP Form 368 together; reconciling an overtime bill a year later without both is painful.

How CBP Form 3171 relates to manifests and other CBP forms

CBP Form 3171 sits alongside, not inside, the manifest stack, and confusing the two is the most common conceptual error. The cargo report for an arriving vessel is CBP Form 1302, Inward Cargo Declaration, the vessel cargo manifest the master files on arrival listing every bill of lading, filed electronically through ACE ocean manifest with the paper form as the fallback; see our note on CBP Form 1302. For air, the equivalent is CBP Form 7509, Air Cargo Manifest, the carrier's declaration of cargo on an arriving aircraft, now filed electronically through ACE air manifest with the paper form as the fallback, covered in our CBP Form 7509 article. At the land border the arrival document is CBP Form 7533, Inward Cargo Manifest for Vessel Under Five Tons, Ferry, Train, Car, Vehicle, etc. the manifest for cargo arriving by truck, rail, or small vessel, explained in our CBP Form 7533 article. CBP Form 3171 says nothing about what is on board; the manifest does.

Downstream, once cargo is unladed under a CBP Form 3171 permit and moves into a bonded facility, custody is recorded on CBP Form 6043, Delivery Ticket, the document recording delivery of merchandise into a bonded warehouse or container freight station under CBP supervision. The warehouse's own annual reconciliation of books against physical inventory is CBP Form 300, Bonded Warehouse Proprietor's Submission, described in our CBP Form 300 article. None of these replaces CBP Form 3171, and CBP Form 3171 replaces none of them.

Other forms in the same family answer entirely different questions and are sometimes pulled up by mistake during a search: CBP Form 3173, Application for Extension of Bond for Temporary Importation, is the request to extend the one-year TIB period in one-year increments up to three years total, filed before the current period expires, and is covered in our CBP Form 3173 article; CBP Form 4457, Certificate of Registration for Personal Effects Taken Abroad, registers serial-numbered personal items before departure so they re-enter duty free; CBP Form 434, NAFTA Certificate of Origin, is retired and was replaced on July 1, 2020 by the USMCA certification of origin, which has no prescribed form and may be any document carrying the nine required data elements; and CBP Form 6051D, Custody Receipt for Seized Property and Evidence, is CBP's receipt describing seized property and the document a notice of seizure and a petition refer back to.

Common CBP Form 3171 problems

Most CBP Form 3171 problems are scheduling and signature problems rather than legal ones. The recurring ones are worth listing plainly.

Frequently asked questions

Is CBP Form 3171 a manifest?

No. CBP Form 3171 is an application for permission to unlade or lade and for CBP services outside regular hours. The cargo report is a separate document: CBP Form 1302 for vessels, CBP Form 7509 for air, CBP Form 7533 at the land border.

Who pays for the overtime requested on CBP Form 3171?

The applicant who signs CBP Form 3171 carries the reimbursement obligation for CBP services performed outside regular hours under 19 CFR 24.16. Confirm the current rate structure and billing method in the regulation and with the port, because this article states no amounts.

Can one CBP Form 3171 cover repeated operations?

Yes, in many ports. CBP Form 3171 can support a term permit covering repetitive unlading or lading over a stated period rather than a filing per arrival. Scope, duration, and renewal conditions vary by port, so confirm with the port director.

Do customs brokers file CBP Form 3171?

Usually not. CBP Form 3171 is the carrier's or agent's filing, and brokers normally monitor it rather than prepare it. A broker who does sign CBP Form 3171 for a client should settle in advance who reimburses the overtime.

Does an approved CBP Form 3171 release the cargo?

No. An approved CBP Form 3171 permits the physical unlading or lading; entry and release are separate steps handled through the entry documents and the ACE release message.

What importers and brokers should do

Key references


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About the Author

Franz Brotzen, CustomsGenius CEO & Founder. Franz is a published researcher on U.S. trade policy. He has worked at think tanks in Washington DC and Tokyo, where his academic publications focussed on tariffs and legal compliance. Franz received his JD from Harvard Law School.

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