A CBP exam hold means Customs has selected your shipment for inspection and it can’t be released until the exam is done. Exams range from an X-ray or gamma-ray scan of the closed container to an intensive exam at a Centralized Examination Station. Your customs broker handles CBP; the importer pays the exam costs.
A CBP exam hold is a government inspection, not a paperwork glitch, and the only people who can resolve it are CBP and the importer’s side of the entry. Imported cargo has long been subject to physical examination by the U.S. government to verify it complies with U.S. laws and regulations,[1] and federal law lets customs officers inspect, examine and search merchandise unladen from an arriving vessel whether or not it has already been inspected.[2] What you control is how quickly your team responds, how well the costs are contained, and what happens to the freight once it is released.
In this guide
Who Does What During a CBP Exam
Most of the confusion around exam holds comes from people calling the wrong party. The importer of record carries the legal responsibility; CBP notes that even when you use a broker, you, the importer of record, are “ultimately responsible for the correctness of the entry documentation presented to CBP and all applicable duties, taxes and fees.”[3]
| Party | Role during an exam |
|---|---|
| CBP | Selects the shipment, performs the exam and decides on release. |
| Importer of record | Legally responsible for the entry and the duties; bears the cost of the exam.[3] |
| Customs broker | Files the entry for the importer, receives hold and exam notices, and is the importer’s point of contact with CBP. |
| Centralized Examination Station (CES) | A privately operated facility where merchandise is made available to CBP officers for physical examination.[4] It unloads and reloads the shipment and bills for those services.[3] |
| Trucker | Moves the container to and from the exam site when the exam requires it. |
| Ocean carrier / terminal | Holds the equipment and bills demurrage or detention under their tariff. |
| Warehouse | No role with CBP. Takes over only after release: receiving, rebuilding, storing and shipping the freight. |
Talk to your broker, not the warehouse
Questions about why a box was selected, what documents CBP wants, or when release will come go through your customs broker. A warehouse or trucker can’t speed up an exam, and anyone promising to “get it released” who isn’t your licensed broker should be treated with caution.
The Three Exam Levels: X-ray, Tailgate and Intensive
The trade uses a few informal names for the escalating levels of exam. The names below are industry shorthand rather than formal CBP categories, but they match what importers actually experience.
1. Non-intrusive (X-ray or gamma-ray) exam, often called a “VACIS”
CBP’s non-intrusive inspection (NII) technology includes large-scale X-ray and gamma-ray imaging systems that let officers examine sea containers, trucks and rail cars for contraband “without physically opening or unloading them.”[5] “VACIS” is the trade name of one family of imaging systems, and many brokers and truckers use it as a catch-all for any container scan. The box stays sealed, which makes this the least disruptive outcome, though it still requires the container to be brought to the scanner.
2. Tailgate exam
In trade usage, a tailgate exam means officers open the container doors, look at the cargo visible from the rear and may pull some cartons to check them against the entry. The freight is not fully unloaded. If the officers are satisfied the entry can be released; if not, the shipment can be escalated to an intensive exam.
3. Intensive exam at a CES
For an intensive exam the container is moved to a Centralized Examination Station, where the merchandise is presented to CBP officers.[4] The CES must provide the personnel and equipment for “the opening, presentation for inspection, and closing” of cargo, on a first-come-first-served basis, and must accept and keep safe merchandise delivered for examination.[6] In practice this is where containers get partly or fully devanned, cartons are opened, and the freight is reloaded after the officers finish.
| Exam level | Container opened? | Cargo unloaded? | Extra moves and fees |
|---|---|---|---|
| NII / “VACIS” scan | No | No | Move to the scanner |
| Tailgate | Yes, doors only | Partly, at most | Depends on where it’s performed |
| Intensive / CES | Yes | Partly or fully | Drayage to and from the CES, CES handling, possible storage |
Who Pays, and What It Costs You in Time
The importer pays. Under the Customs regulations, the importer bears any expense involved in preparing the merchandise for examination and in closing the packages.[7] CBP adds that when a shipment goes to a CES, the facility bills the importer for its unloading and reloading, on top of the cost of moving the cargo to and from the exam site and any temporary storage.[3]
The bigger cost is often the carrier’s clock. While the box waits for a scan slot, a CES appointment or a release, demurrage or detention can keep running under the carrier’s tariff. The Federal Maritime Commission has said that when it judges whether demurrage and detention practices are reasonable, it considers whether charges serve their purpose during government inspections and accounts for extenuating circumstances.[8] Keep the exam notices and dates; they are the evidence for any request to waive or reduce those charges. Our demurrage and detention guide covers the dispute process.
What to Do When a Hold Posts
- Get the specifics from your broker. Which hold, which exam type, and whether CBP needs documents. Everything else depends on that answer.
- Don’t move the container on your own. Moving a held box to an exam site happens under CBP’s direction, coordinated through your broker. Don’t let anyone pull or reroute it on their own initiative.
- Line up the trucker early. If a CES move is required, the dray to and from the station is on the importer’s side. Have a carrier ready so the box isn’t waiting for a truck.
- Notify the carrier and ask about free time. Tell the ocean carrier the box is on a government hold and ask what relief its tariff allows. Save the correspondence.
- Warn the consignee. Delivery dates move, and freight that has been through an intensive exam may arrive in a different condition than it shipped.
- Plan the post-release move. Decide in advance where the freight goes once CBP releases it, so the container isn’t sitting again after the exam is done.
What Freight Looks Like After a CES Exam
A CES has to close the cargo after inspection,[6] but closing a box is not the same as rebuilding a shipment for the next leg. Common conditions after an intensive exam include:
- Stretch wrap cut away and pallets re-wrapped by hand, or not at all
- Cartons opened and re-taped, sometimes with contents shifted
- Pallets broken down and restacked out of their original pattern, or loose cartons reloaded floor-style
- Labels, pallet placards or carton orientation that no longer match what the receiver expects
None of that is a customs problem; it’s a handling problem. But it can lead to refusals at a retail DC, damage on the domestic leg, or a load that doesn’t travel safely. Photograph the freight as received after release, before anyone touches it, in case a claim follows.
Example Scenario
This is a hypothetical to illustrate the sequence, not a real shipment. Say an importer’s 40-foot container of palletized housewares arrives at Port Newark and the broker reports an intensive exam. The broker coordinates the exam; the importer’s trucker drays the box to the CES and back. CBP releases the entry, but the CES has reloaded several pallets as loose cartons and cut the wrap on others. The importer has the container delivered to a nearby warehouse instead of straight to the retailer’s DC. There the freight is photographed, rebuilt onto sound pallets, re-wrapped and relabeled to the retailer’s requirements, and the empty goes back to the carrier. The DC receives a clean, compliant load.
Where a New Jersey Warehouse Fits (and Where It Doesn’t)
RapidShips is not a customs broker and has no role in the exam itself: we can’t file entries, talk to CBP on your behalf, or influence when a shipment is released. Our part starts once CBP has released the freight and your trucker brings it to our dock in East Brunswick. From there we handle the physical recovery:
- Rebuilding and re-wrapping pallets that came back from a CES exam loose, leaning or unwrapped, through our freight rework service.
- Devanning the container and moving the freight to domestic trailers with transloading, so the empty can be returned.
- Holding released freight in short-term storage if the receiver’s delivery window moved because of the exam.
If you know a box is heading for an exam and want the post-release work lined up, call 800-376-2808 or send us the shipment details.
Frequently Asked Questions
What does a CBP exam hold mean?
What is the difference between a VACIS exam, a tailgate exam and an intensive exam?
Who pays for a CBP exam?
Can a warehouse get my container released from a CBP hold faster?
Do demurrage and detention stop during a CBP exam?
Sources
- U.S. Customs and Border Protection, "Cargo Examination," accessed September 2026.
- Legal Information Institute, Cornell Law School, "19 U.S. Code § 1467 – Special inspection, examination, and search," accessed September 2026.
- U.S. Customs and Border Protection, "Tips for New Importers and Exporters," accessed September 2026.
- Legal Information Institute, Cornell Law School, "19 CFR § 118.1 – Definition," accessed September 2026.
- U.S. Customs and Border Protection, "Non-Intrusive Inspection (NII) Technology fact sheet," accessed September 2026.
- Legal Information Institute, Cornell Law School, "19 CFR § 118.4 – Responsibilities of a CES operator," accessed September 2026.
- Legal Information Institute, Cornell Law School, "19 CFR § 151.6 – Place of examination," accessed September 2026.
- Legal Information Institute, Cornell Law School, "46 CFR § 545.5 – Unjust and unreasonable practices with respect to demurrage and detention," accessed September 2026.
This guide is general operational information, not legal or regulatory advice. Rules change; confirm current requirements with the relevant agency or your carrier before acting.