Your container arrives at Port Miami, your customs broker files the entry, and then nothing. The status reads "HOLD — Exam Required." Your drayage appointment is gone, free time is burning, and your warehouse is waiting. CBP exam holds hit importers without warning, and the costs add up fast if you don't know how to respond. This article covers the types of exams CBP runs, what triggers them, how long they take, and exactly who pays for the extra port fees.
Types of CBP Exams
CBP runs several levels of examination. Understanding which type your container got helps you estimate the delay and cost.
VACIS and tailgate exams are CBP-absorbed costs — CBP owns the equipment and labor. Intensive exams are different. The importer pays for CES handling.
What Triggers an Exam Hold
CBP does not publish its targeting criteria. The targeting system — ATS (Automated Targeting System) — scores every entry and flags containers for exam. What feeds the score:
- Country of origin. Containers from high-risk countries — currently those under Section 301 tariffs, certain Southeast Asian origins, or countries on OFAC watch lists — draw higher scrutiny.
- Importer history. New importers with no CBP track record get examined more often than established importers with clean histories.
- Commodity type. Electronics, footwear, apparel, steel, and aluminum trigger tariff-related exams under anti-dumping/countervailing duty (AD/CVD) orders.
- ISF accuracy. An Importer Security Filing submitted late, with vague commodity descriptions, or with HTS codes that don't match the commercial invoice raises flags.
- Anomalies between the manifest and entry documents. If the carrier's bill of lading says one thing and the CBP entry says another, ATS notices.
- Random selection. CBP runs a percentage of containers through exam at random regardless of risk score. No pattern, no way to prevent it.
Some importers believe that CBP exam holds are targeted based on their past exam history. That's partially true — if your last two containers passed cleanly, that can lower your score. If you've had seizures or penalties, your score goes up and stays up until your compliance record improves.
Timeline and Process at Port Miami
At Port Miami and Port Everglades, the sequence after a hold notification looks like this:
- Hold appears in ACE (Automated Commercial Environment) — your customs broker sees it first.
- For VACIS: the terminal schedules the container to move to an NII lane. Usually happens within 24–48 hours of the hold notice.
- For intensive exam: the container moves to a CES. At Port Miami, the primary CES facility is operated by a third-party exam station company. The container gets trucked from the terminal to the CES yard.
- CES hands perform the unload, examination, and restuff. CBP officer inspects during or after.
- CBP releases the hold in ACE. Your broker gets notification.
- Container returns to terminal (or goes direct to your drayage carrier for delivery).
For a VACIS exam, total delay from hold notification to release: 1–3 days. For an intensive exam at Port Miami: 3–7 business days, sometimes longer during peak season or if CBP has questions about the cargo. During the weeks after a major tariff change — like the Section 301 updates in early 2026 — exam volumes surge and CES backlogs stretch.
Who Pays for Exam Costs
CBP does not charge importers for the exam itself — the agency's labor and equipment are covered by the government. What importers pay for:
Total cost of an intensive exam at Port Miami: $700–$2,500+ by the time you add CES fees, partial demurrage, chassis per diem, and re-dispatch. Budget for it if your cargo or origin country puts you in a regularly-examined category.
How It Affects Your Drayage
A CBP hold kills your terminal appointment. When the container finally releases, you need a new appointment — and depending on the terminal, those slots may be days out. At Port Miami's POMTOC and SSA terminals, appointment windows during peak periods fill 48–72 hours in advance.
At One A Trucks, when we receive a hold notification through your broker, we cancel the existing appointment, monitor the ACE status daily, and reschedule the moment the hold clears. We don't charge a re-booking fee for CBP exam holds — it's not something you caused, and it's not something we can prevent.
A few things that make exam holds worse from a drayage standpoint:
- The container moves from the main terminal to the CES yard and back — two extra truck moves that add 1–2 days minimum.
- CES facilities have their own business hours. If the exam finishes Friday afternoon, the container may not return to terminal until Monday.
- After an intensive exam, the CES restuffing quality varies. We've seen containers return with cargo shifted, which means the driver notes it on the POD at delivery to protect against later damage claims.
What to Do When Your Container Is on Hold
The moment you see a CBP hold in your entry status, run through this list with your customs broker:
- Confirm the exam type. VACIS vs. intensive changes the timeline and cost significantly. Your broker can usually find out from the terminal or CBP port director's office which exam type was ordered.
- Request a demurrage waiver from the steamship line. Send them the CBP exam notice. Most lines — MSC, Evergreen, CMA CGM, Hapag-Lloyd — will pause demurrage for the duration of a CBP exam hold if you ask formally and promptly.
- Notify your warehouse. If your warehouse has a tight delivery appointment and labor scheduled, reschedule before the window expires. A no-show at the warehouse costs more than rescheduling early.
- Contact your drayage carrier. Give them the hold status and expected exam type. A good carrier monitors the status themselves but a direct call confirms you're aligned.
- Check chassis per diem exposure. If the container is sitting on chassis at the terminal while waiting for exam, calculate how much chassis cost you're accumulating per day. Ask the terminal or CES whether off-chassis storage is an option.
- Document everything. If cargo arrives damaged after an intensive exam, the CES is responsible for the unload/restuff. You need photos at delivery and a note on the POD to build a damage claim.
One step that some importers miss: after the exam clears and your container is released, pull the CBP exam results from ACE. If CBP found nothing and released the container, that clean exam result on your record can support a request to CBP for reduced future targeting — not guaranteed, but worth having your broker raise it.
Exam holds are a cost of importing. They're not random in the sense that CBP targets based on real data — but for a given importer, any single shipment can get flagged by factors beyond your control. The importers who manage exam holds well are the ones who have their broker on speed dial, know their CES facility contacts, and keep their ISFs accurate and early.