A customs exam is CBP’s physical or image-based inspection of an import shipment, and under 19 U.S.C. 1467 CBP may examine any shipment entering the United States, whether or not the entry data looks clean. Most containers are released without one. The ones that are selected leave the normal flow: they are scanned, opened at the door, or trucked to a privately run exam facility and unloaded, and the importer pays for every move, every hour of labor and every day of storage that follows.
This guide is about cargo examinations, the container exams that hold up freight. It is not about the CBP broker license exam, which shares the search term. It covers the three exam types, the ACE hold codes that tell you which one you drew, who bills you for what, where demurrage starts to bite, and the data and program choices that lower the odds of selection. For the full sequence from arrival to release, see our guide to the customs clearance process.
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Exam Types: VACIS and NII Scans, Tailgate Exams and Intensive Exams
CBP runs three levels of container exam, and each level costs the importer more time and money than the one before it. The level is set by CBP, not requested by the importer, and a lighter exam can be escalated to a heavier one if the officer sees something that does not match the entry.
| Exam level | What CBP does | ACE signal | Where it happens | Typical cost drivers |
|---|---|---|---|---|
| NII / VACIS | Images the sealed container | 7H selected, 7I finished | Scanner at or near the terminal | Drayage to and from the scanner, terminal moves, added storage days |
| Tailgate | Opens the doors and inspects cargo near the door | Exam or hold posted against the bill | Terminal or exam facility | Labor to open and reseal, drayage, storage |
| Intensive | Devans and inspects the cargo | 1A entered, 1B completed; 4A override; 1X transfer for exam | Centralized examination station (CES) | Drayage to the CES, devanning and reloading labor, CES storage, terminal and carrier charges while waiting |
Non-intrusive inspection (VACIS, X-ray and gamma-ray)
A non-intrusive inspection images the sealed container with large-scale X-ray or gamma-ray equipment. CBP describes these systems as letting officers examine sea containers, trucks and rail cars for contraband without physically opening or unloading them. The trade still calls this a VACIS exam, after one of the early gamma-ray systems. In ACE, a bill selected for an NII exam receives disposition code 7H, and code 7I posts when the NII exam is finished.
An NII exam is the cheapest outcome. The container usually only needs to be moved to the scanner and back. If the image shows a density anomaly, an undeclared void or cargo that does not match the declared commodity, the officer can order a tailgate or intensive exam on the same box.
Tailgate exam
A tailgate exam is the trade’s name for a partial physical inspection: the officer breaks the seal, opens the container doors and looks at, counts or pulls cartons near the door without fully unloading. It checks whether marking, packaging and visible contents match the invoice and packing list. It needs labor at the terminal or at an exam facility, and it ends with a new seal that should be recorded on the delivery paperwork.
Intensive exam
An intensive exam is a full or near-full devanning at a centralized examination station. ACE signals it with disposition code 1A (entered, intensive examination required, cargo not released) and later 1B (intensive examination completed, released). Code 4A overrides an earlier general release to intensive, which is why a container that showed released can still be pulled back. 19 CFR 151.2 sets the minimum sampling for physical exams at one package in every ten, with port directors allowed to examine fewer, but not less than one package per invoice, when packages are uniform.
How Containers Are Selected and What Each Hold Code Means
Selection comes from CBP’s targeting of the ISF, the manifest and the entry, from random compliance sampling, and from enforcement teams working the port, and the hold code tells you which track you are on. A clean entry can still be selected. A CES transfer under disposition code 1X, for example, is defined in CBP’s ACE disposition code list as an enforcement or compliance exam that may be generated independently of cargo selectivity and may be unrelated to the entry information.
The codes that matter most to an importer tracking a box are posted to the bill of lading in ACE and passed to the carrier and the broker:
- 1C, entered and released, general examination: the entry is released, but the cargo must still be held if any other hold sits on the bill.
- 1A and 1B: intensive exam required, then completed.
- 4A: override to intensive, issued after a release, which subtracts the released quantity from the bill.
- 1H: a CBP hold placed at the port of discharge, which denies release until removed.
- 2H: a CBPA miscellaneous hold placed at the port of discharge, which denies release until it is removed.
- 7H and 7I: selected for non-intrusive inspection, then NII exam finished.
- 1X: transfer to a CES for an enforcement or compliance exam.
What a 7H hold and a CET exam mean
A 7H hold means the bill has been selected for a non-intrusive inspection, and the container cannot leave the terminal until the scan clears and code 7I posts. A CET exam is trade shorthand for an exam run by CBP’s Anti-Terrorism Contraband Enforcement Team (A-TCET), the officers who look for narcotics, weapons, counterfeit goods and other contraband in cargo. A CET exam is enforcement-driven, so it can be ordered on top of a completed entry release and it rarely comes with an explanation.
Agency holds are a separate track. FDA, USDA and other partner agencies place their own holds, and an FDA hold or exam follows FDA’s admissibility process, not CBP’s. If you import food, drugs, devices or cosmetics, that process is handled through our FDA customs broker service.
Centralized Examination Stations and Who Pays for the Exam
CBP does not charge for a customs exam, but the importer pays for everything needed to present the cargo, because 19 CFR 151.6 puts the expense of preparing merchandise for examination and closing the packages on the importer. CBP’s own importer guidance says it plainly: in normal operations CBP does not charge for cargo examinations, the shipment will generally be moved to a centralized examination station, and the CES bills you for its services. CBP also notes that there are costs for moving the cargo to and from the exam site and for storage.
A centralized examination station is defined in 19 CFR 118.1 as a privately operated facility, not in the charge of a CBP officer, where merchandise is made available to CBP officers for physical examination. The operator is selected by the port director and works under a written agreement that runs between three and five years. Under 19 CFR 118.4, the operator must provide the people and equipment to open, present and close cargo on a first come, first served basis, must charge according to the fee schedule in its approved application, and bills users directly.
Your broker names the CES before the exam is ordered. Block 8 of the CBP Form 3461 asks for the FIRMS code of the desired devanning or centralized exam site in case the shipment is subject to an intensive exam, and the field can be left blank only where the port has a single site. Picking the CES deliberately (distance from the terminal, queue, hours, handling of your cargo type) is one of the few levers an importer has once the box is selected. Our breakdown of the CBP Form 3461 covers the rest of the release filing.
| Cost | Billed by | Paid by | Basis |
|---|---|---|---|
| CBP officer time for the exam | Not billed in normal operations | None | CBP importer guidance |
| Opening, devanning, presentation, reloading | CES operator | Importer | 19 CFR 151.6, 19 CFR 118.4(c) |
| Drayage to and from the scanner or CES | Trucker | Importer | Commercial terms |
| Terminal storage and container charges while held | Terminal operator, ocean carrier or NVOCC | Billed party under the contract | Carrier or terminal tariff, 46 CFR Part 541 billing rules |
| Storage at the CES | CES operator | Importer | Approved CES fee schedule |
Exam Timelines and Demurrage Exposure
No regulation sets how long a customs exam may take, so the real timeline depends on the exam level, the CES queue, the officer schedule and any escalation, and the importer’s exposure is the free time on the container. An NII scan is usually the shortest path because the box is not opened. A tailgate exam adds the time to open, inspect and reseal. An intensive exam adds drayage to the CES, a place in the first come, first served queue, the devanning itself, CBP’s inspection, reloading and the move back. Each hand-off can carry a day or more, and an escalation from scan to intensive restarts much of the sequence.
The clock that costs money is the carrier’s and terminal’s free time. Demurrage runs while the container sits at the terminal and detention runs while the carrier’s equipment is out of the terminal, and an exam can trigger both. The Federal Maritime Commission’s billing rule in 46 CFR Part 541 gives importers some protection: under 46 CFR 541.7, a demurrage or detention invoice must be issued within 30 calendar days from the date the charge was last incurred, or the billed party is not required to pay it. Under 46 CFR 541.8, the billed party must have at least 30 calendar days from the invoice date to request mitigation, refund or waiver, and 46 CFR 541.5 voids the obligation to pay an invoice that leaves out required information.
The practical controls are operational. Ask the broker to report the hold code the same day it posts, pre-book drayage to the CES the broker named, check whether the carrier has a policy on free time for CBP-held boxes, and keep the exam paper trail (hold date, exam order, release date) to support any dispute of charges that accrued while the government held the cargo. For entries through the Port of New York and New Jersey, see our customs broker in New York page.
Reducing Exam Risk Through Data Quality and CTPAT
Exam selection cannot be eliminated, because CBP keeps random and enforcement selection outside any importer’s control, but most avoidable exams trace back to data that does not line up. Targeting compares the ISF, the carrier manifest and the entry. A vague description such as “parts” or “general merchandise”, a shipper name that differs between documents, a manufacturer that does not match the origin claimed, or an HTS number that does not fit the description all raise risk scores. The first filing CBP sees is the ISF, so precise ISF filing with real manufacturer and ship-to data is the earliest place to lower that score.
Packing discipline matters at the exam itself. Cartons marked with country of origin, packing lists that state cartons per pallet and pallet positions, and an invoice description an officer can match to what is in the box shorten tailgate and intensive exams and reduce escalations. A consistent importer profile helps as well: the same importer of record, the same supplier identities and the same classification for the same SKU across entries.
The CTPAT program is the formal route to fewer exams. CBP lists the program’s benefits as a reduced number of CBP examinations, front of the line inspections, possible exemption from stratified exams and shorter wait times at the border. Membership requires a validated supply chain security program, and the benefit applies to the member’s shipments, not to the product category. Our CTPAT certification service covers the application and validation, and our licensed customs brokerage team, in business since 1989, reviews entry data against the ISF and manifest before filing.
Frequently Asked Questions
Does customs check every container?
No, CBP does not physically examine every container, but it has the legal right to examine any shipment under 19 U.S.C. 1467. Selection comes from risk targeting of ISF, manifest and entry data, from random compliance sampling and from enforcement teams. Radiation screening of arriving containers is a separate check and is not the same as a customs exam.
How long does a VACIS exam typically take?
No regulation sets a time, and a VACIS or NII exam usually takes less time than any physical exam because the container stays sealed. The delay comes from moving the box to the scanner, the scanner queue and the posting of release code 7I. If the image raises questions, CBP can escalate to a tailgate or intensive exam, which adds days.
What is a 7H hold in customs?
A 7H is the ACE disposition code that tells the carrier a bill of lading has been selected for a non-intrusive inspection. The container must stay at the terminal until the scan is complete and code 7I posts. Other holds on the same bill, such as a 1H CBP hold or an agency hold, must also be cleared before pickup.
What is a CET exam?
A CET exam is an exam ordered by CBP’s Anti-Terrorism Contraband Enforcement Team, which inspects cargo for narcotics, weapons, counterfeit goods and other contraband. It is enforcement-driven, can be ordered after a normal entry release and is usually performed at an exam station with the cargo devanned.
Who pays for a customs exam?
The importer pays for presenting the cargo, even though CBP does not charge for the officer’s exam. Under 19 CFR 151.6 the importer bears the cost of preparing merchandise for examination and closing the packages. In practice that means drayage, CES devanning and reloading fees, CES storage and terminal or carrier charges that accrue while the container is held.
Can I choose which exam station handles my container?
Yes, where the port has more than one CES. Your broker enters the FIRMS code of the preferred devanning or centralized exam site in Block 8 of CBP Form 3461 so that CBP routes an intensive exam there. If the port has only one CES, the field is not required.
Can I avoid demurrage caused by a customs exam?
Not automatically, because carrier and terminal free time keeps running during a government hold unless the contract says otherwise. Under the FMC rule in 46 CFR 541.7 a demurrage or detention invoice issued more than 30 days after the charge was last incurred does not have to be paid, and 46 CFR 541.8 gives you at least 30 days to request mitigation or waiver.
