Customs Exams and Holds: US Exam Types vs India's RMS

The dray was booked for 7 a.m., the warehouse had a door and a crew waiting, and the driver came back empty because the terminal would not release the box. The broker had seen the exam selection the afternoon before but sent it to an inbox nobody watched overnight. Four days later the container is still waiting for a slot at the examination station, free time has run out, and the planner is moving outbound orders to cover the missing stock.

A customs exam or hold cannot be prevented by the operations team, but its cost and duration can be controlled. When the hold is visible to dispatch within the hour, the box is presented quickly, and every day is tracked against the legal clocks and the terminal's free time, most exams close inside a week with charges that finance expected.

• What this guide covers: US exam types from scanner to full devanning, the detention clock in 19 U.S.C. 1499, who pays, and how India's Risk Management System routes a bill of entry to facilitation, assessment or examination.
• What it adds: a dated hold trace, a cost formula, worked charges in USD and INR, and a readiness checklist for dispatch, the broker and the warehouse.

What a customs exam selection sets moving at the port

An exam selection turns a routine pickup into a sequence with four owners: the broker who sees the hold, the dispatcher who stops the truck, the examination site that books a slot, and finance that absorbs the extra charges. If any one of them learns late, the free-time clock keeps running while nothing moves.

Our guide to customs query document workflow deals with a different event: customs asking for papers or explanations about a declaration. This article covers the physical side, when officers want to see the goods, and the operational holds that follow. Other import topics sit on the logistics and supply chain hub.

US exam types, from a scanner image to a full CES devanning

US exams escalate in cost and time: a scan with large-scale imaging equipment, a look through the open doors, then a full unload at a centralized examination station. Plan the truck and the warehouse around the most likely next step, not the current one.

CBP describes its large-scale non-intrusive inspection equipment as X-ray and gamma-ray imaging systems able to image a whole container or truck. In January 2026 testimony to a House subcommittee, CBP said it had 405 large-scale systems deployed at air, sea and land ports as of 2 December 2025, and that officers scanned over 17 million sea containers, rail cars and vehicles with them in fiscal year 2025.

A centralized examination station is defined in 19 CFR 118.1 as a privately operated facility, not in the charge of a customs officer, where merchandise is made available for physical examination. The operator must serve users first come, first served, keep a custodial bond and bill users directly for its services under 118.4. Under 118.11(c) its fees must be comparable to those for similar services in the area.

The legal clock: 19 U.S.C. 1499 detention and the 30-day rule

Once goods are presented for examination, CBP has five business days to release or detain them, five more to send a detention notice, and 30 days to make a final admissibility decision. Silence past day 30 counts as an exclusion that the importer can protest.

Section 1499(c) and 19 CFR 151.16 set these steps. Goods count as presented only when they are in a condition to be viewed and examined by an officer; presenting the container alone does not start the clock. The notice must give the start of the detention, the specific reason, the expected length, the nature of any tests and information that could speed the outcome.

CBP detention under 19 U.S.C. 1499(c) and 19 CFR 151.16 starts when the cargo is presented in a condition to be examined; CBP has five business days to release or detain, five more to issue a detention notice, and a 30-day silence becomes an exclusion the importer may protest.

• Test results on request: under 151.16(d) the importer can ask in writing for test results and methods, except proprietary or enforcement methods.
• Deemed exclusion: under 151.16(f) no decision within 30 days is treated as an exclusion under 19 U.S.C. 1514(a)(4), which can be protested.
• Protest timing: a protest not allowed or denied by the 30th day after filing is treated as denied on that day, opening the route to court.
• Preparation cost: under 151.16(b), unless goods are examined at the public stores, the importer pays to prepare and move them for examination.

Who pays for a US exam and how charges reach the invoice

CBP does not charge for the exam, but the importer pays for everything around it. The bill arrives from four directions: the CES operator, the drayage carrier, the terminal or line for extra days, and the broker for coordination.

CBP's guidance for new importers cites 19 CFR 151.6 for the rule that the importer bears any expense of preparing merchandise for examination and closing packages. It notes that a shipment selected for examination will generally move to a CES, which unloads and reloads it and bills for that service, and that a complete devanning may cost several hundred dollars, with rates varying across the country.

Customs examination cost in the United States falls on the importer under 19 CFR 151.6 because CBP does not charge for the exam itself, so a centralized examination station's devanning bill, storage, drayage, demurrage and chassis days should be accrued daily against the entry in the TMS, with each line closed within 30 days.

CES fees are not open-ended. Under 19 CFR 118.5 an operator must give 90 calendar days' written notice and justification to change its fee schedule and stays bound by the existing schedule until the port director approves the change. Ask your broker for the CES fee schedule for each port you use and load it into the freight audit rules.

Demurrage and detention are the charges most likely to dwarf the CES bill. Our guide to demurrage, detention and terminal storage covers how those clocks and disputes work; for an exam, the key is recording the hold start and release times so the days can be challenged where the terminal or line caused the delay.

How India's Risk Management System routes each bill of entry

In India the decision to examine is made by the Risk Management System before an officer sees the goods. Each self-assessed bill of entry is either facilitated with no assessment or examination, or interdicted for verification of assessment, for examination, or for both.

Section 17 of the Customs Act, 1962 makes the importer self-assess duty, and section 17(2) lets the proper officer verify that self-assessment, including by examining or testing the goods, with a proviso that selection is primarily based on risk evaluation. The CBIC Customs Manual, 2025 says bills with no RMS interdiction are facilitated for clearance on payment of duty without assessment and examination.

India's Risk Management System, applied under section 17(2) of the Customs Act, 1962, routes each self-assessed bill of entry to facilitation, assessment, examination or both; CBIC set a 90% facilitation aim in Circular 14/2021-Customs and expects a faceless assessment group's first decision within three working hours of allocation.

• Facilitated bill: no assessment and no examination; the bill moves to registration and out of charge once duty is paid.
• Assessment only: a faceless assessment group verifies classification, value and exemptions, and may raise up to three queries on one bill.
• Examination only: the goods are examined in the CFS or import shed against an examination order, without a separate assessment query.
• Assessment and examination: both steps apply, and the order between them decides whether it is a first or second check.

The Manual records that CBIC moved to raise facilitation to 90% in July 2021 through Circular 14/2021-Customs, and that the faceless assessment group's first decision on a bill, whether accepting the self-assessment, raising a query or ordering a first check, should be communicated within three working hours of allocation. Those are administrative targets, not guarantees, but they give a broker a reference when a bill sits untouched.

First check, second check and the examination order at the CFS

A first check examines goods before assessment; a second check assesses first and examines afterwards. Second check is the normal route, and a first check is used when the importer lacks full information and asks for it, or when the officer has reason to see the goods before assessing duty.

The Customs Manual, 2025 explains that goods interdicted for examination are checked for the correctness of the declaration, that samples may be drawn for testing, and that standard examination orders have applied to all second check cases since April 2023. After examination, the shed officer gives the clearance order and the goods leave as out of charge.

• Re-assessment and speaking order: if verification shows the self-assessment was wrong, section 17(4) allows re-assessment, and section 17(5) requires a speaking order within 15 days unless the importer accepts it in writing.
• Provisional assessment: where the duty cannot be finalised, for example for liquid bulk cargo, the Manual directs second check with duty assessed provisionally under section 18.
• Uncleared goods: under section 48, goods not cleared, warehoused or transshipped within 30 days of unloading may be sold by the custodian after notice to the importer and customs permission.
• Duty on lost goods: if goods are found destroyed during examination, section 23 allows remission of duty before clearance for home consumption.

Once the order is given, transport from the port or CFS to the warehouse may need its own paperwork. Our guide to the e-way bill for imported cargo covers that leg, which starts only after out of charge.

A dated hold trace from selection to release

Exams rarely fail on the officer's side; they fail in the hand-offs between broker, dispatcher and examination site. The trace below follows one intensive exam where each delay was avoidable and the legal clock was never tracked.

1. Monday 15:40, entry 123-4567890-1: the broker's ACE query shows the container selected for an intensive exam; the alert goes to a shared mailbox and dispatch is not told.
2. Tuesday 07:00, dry run: the driver arrives for pickup and the terminal refuses release because of the exam hold; the dray carrier bills a dry run of $175 under rate code DR-01.
3. Tuesday 14:00, CES booking: the broker books the station, which quotes a three-day queue; no one writes down the date the container will be presented.
4. Friday 10:30, devanning: the container is unloaded at the CES and officers ask for the invoice line for a mixed-SKU pallet, which the importer takes until Monday to supply.
5. Following Wednesday 16:00, release: CBP releases the cargo; terminal free time ended five days earlier, and with no hold-start record the importer cannot dispute any of the demurrage days.

Three fields would have changed the outcome: the hold timestamp pushed to dispatch, the presentation date recorded by the CES, and the invoice and packing list for every pallet held ready before devanning. The same fields work for an Indian CFS, where the registration time, examination time and out-of-charge time define the hold.

Dollars and rupees: costing one exam inside the landed cost

Exam charges are part of the cost of bringing goods to their location, so they belong in landed cost, not in a general freight expense line. Accrue them daily while the hold lasts, because the final invoices arrive weeks after release.

Hold cost  H = SUM over charges i of [ r_i x max(0, t_i - f_i) ] + E + T

r_i = daily rate for charge i (terminal demurrage, line detention, CES storage, chassis)
t_i = days the box was held for that charge, from hold start to release
f_i = free days still available when the hold started
E   = examination handling (CES devanning and reload, or CFS de-stuffing)
T   = extra transport (CES shuttle, dry runs, rescheduled delivery)

Accrual record per day:
{ "entry": "123-4567890-1", "container": "ABCU1002345", "hold_type": "INTENSIVE",
  "hold_start": "2026-11-02T15:40", "presented": null, "released": null,
  "charges": [ { "code": "DEM", "rate": 175.00, "free_days_left": 1 } ] }

The figures below are illustrative, for a 40-foot container of household goods held for a physical exam in each market. Real rates come from the CES schedule, the terminal and CFS tariffs and the line's detention tariff for your contract.

The demurrage and detention lines make up more than a quarter of the US total and 40% of the Indian one, which is why hold timestamps matter more than negotiating the exam fee. In India the import landed cost also carries duty and IGST; our guide to import landed cost in India shows where these clearing charges sit in that build-up.

Which hold checks the TMS can run and where a broker decides

Status polling, clock arithmetic and charge accruals are fixed rules the TMS should run without anyone asking. Describing goods to an officer, choosing to request a first check or deciding to protest are judgements for the broker and the importer.

Exam readiness checklist for the next selected shipment

Most of the cost of an exam is set before the officer opens the doors. A short readiness checklist, owned jointly by the broker, dispatch and the warehouse, keeps the box moving and the charges defensible.

Exams will keep happening; the aim is to make each one a short, costed event rather than a surprise. If you want hold alerts, exam clocks and charge accruals built into your TMS and broker workflow, share your current process with us through the project request form.