CBP Exams: What Importers and Forwarders Need to Know
A CBP exam can hold your cargo for days, generate CES fees, and trigger demurrage charges that accumulate quickly. How your broker coordinates the response makes a significant difference in how much it costs and how long it takes.
Written by Mauricio Larenas, Licensed U.S. Customs Broker, CHB #42750
· 5 min read
A CBP examination can delay cargo by days or longer and generate unexpected costs. Understanding the exam types, why they happen, and how to respond helps importers and forwarders manage the process effectively.
When CBP selects cargo for examination, the shipment is held at the port until the exam is completed and the results are reviewed. For time-sensitive cargo, this is a serious operational issue. Understanding the exam process — why it happens, what to expect, and how to respond — is essential knowledge for anyone involved in importing goods into the United States.
A CBP examination can hold cargo for days, generate CES fees of several hundred to over a thousand dollars, and trigger demurrage charges that accumulate the longer the container sits. The exam itself cannot be disputed or avoided — but coordinating quickly and correctly minimizes cost and delay.
Types of CBP Exams
CBP uses several examination types with varying levels of intensity and cost:
- VACIS / NII|X-ray or gamma-ray scan of the container. No unloading required. Least disruptive. Often resolved within hours.
- Tailgate Exam|CBP inspects the rear of the container, typically without full unloading.
- Intensive Exam (CET)|Full unloading at a Centralized Examination Station (CES). Most time-consuming and expensive. CES fees charged to the importer.
- Document Examination|CBP requests and reviews import documents — invoice, packing list, bill of lading. No physical cargo inspection.
Why Cargo Gets Selected
CBP's targeting is a combination of automated risk-scoring and random selection. Factors that increase exam likelihood include:
- First-time importer with no prior U.S. import history
- New trade lane or supplier relationship
- Commodity types with high rates of AD/CVD evasion or undervaluation
- Incomplete or inconsistent ISF data
- Intelligence-driven targeting based on supply chain risk profiles
Exam Response Checklist
When cargo is flagged for exam, timing determines how much the hold costs. Follow these steps immediately:
- Notify your customs broker immediately — confirm exam type and next steps
- Gather all supporting documents: commercial invoice, packing list, bill of lading, permits
- For document exams: respond to CBP document requests without delay — every day of delay extends the hold
- For intensive exams: arrange drayage to the CES as quickly as possible to minimize demurrage
- Do not contact CBP directly to dispute the exam selection — coordinate through your broker
- Track free time at the port terminal and move the container before demurrage begins
- Keep all parties informed — shipper, consignee, trucker, and any warehouse or 3PL involved
Managing the Cost
CES fees for intensive exams are the responsibility of the importer of record and are generally not covered by the carrier or forwarder — though specific arrangements may vary by contract. These fees typically range from several hundred to over a thousand dollars depending on container size and exam complexity. In addition, if the container is delayed past free time at the port, demurrage charges accumulate daily.
Cargo Currently on Hold or Seeing High Exam Rates?
Frequently Asked Questions
How long does a CBP exam take?
An NII (X-ray scan) can be completed within hours. A document exam typically resolves within 1 to 3 business days depending on how quickly documentation is provided. An intensive exam (CET) can take 3 to 7 business days or longer depending on CES scheduling and container availability at the examination station.
Who pays for CES intensive exam fees?
The importer of record is generally responsible for CES examination fees. These fees are charged by the exam station and are not typically covered by the carrier, freight forwarder, or NVOCC — though specific arrangements may vary by contract. The importer may also be responsible for drayage costs to move the container to the CES.
Can CBP exam rates be reduced over time?
Importers enrolled in CBP's Trusted Trader programs such as CTPAT (Customs-Trade Partnership Against Terrorism) generally receive lower exam rates. Consistent ISF accuracy, accurate entry documentation, and an established import history with no compliance issues also reduce exam risk over time.
Can I dispute a CBP exam?
The exam selection itself cannot be disputed — CBP has broad authority to examine cargo. However, if an exam results in a CBP finding you believe is incorrect — such as a misclassification finding or a hold based on incorrect information — a protest can be filed through your licensed customs broker within 180 days of the relevant CBP decision.