GAO-22-105034, COVID-19: CBP Acted to Mitigate Challenges Affecting Its Trade Operations

Full text

COVID-19
CBP Acted to Mitigate
Challenges Affecting
Its Trade Operations

Report to Congressional Committees
September 2022

GAO-22-105034

United States Government Accountability Office

 United States Government Accountability Office

Highlights of GAO-22-105034, a report to
congressional committees

September 2022
COVID-19
CBP Acted to Mitigate Challenges Affecting Its Trade
Operations
What GAO Found
The COVID-19 pandemic caused a shift in U.S. international trade trends. In
particular, an initial decline in imports occurred at the pandemic’s onset in March
2020, followed by a steep resurgence several months later. According to CBP
officials, this resurgence resulted in part from increased e-commerce shipments,
as more consumers shopped from home, and increased demand for products
such as masks. These increases contributed to a rise in the cost of shipping
goods to the U.S., as charges for shipping containers rose. Importers responded
to some of these shifts by transitioning from ocean vessel to air freight because
of air freight’s faster shipping times and lower rates.
Numbers of Import Shipments Processed by CBP, May 2018–Dec. 2021

U.S. Customs and Border Protection (CBP) took a number of steps to respond to
challenges stemming from the pandemic. For example, to minimize staff
exposure to COVID-19, the agency implemented social distancing, staggered
shifts, allowed telework, and required the use of personal protective equipment
(PPE), according to agency officials. To maintain continuity of operations, CBP
used workplace flexibilities to mitigate staff absences and adapted inspection
procedures to account for increased telework. CBP also took steps, including
reducing overtime and nonessential travel, to help address steep declines in
revenue from user fees, such as fees for inspections of commercial vessels and
trucks at U.S. ports. In addition, the agency created the COVID-19 Cargo
Resolution Team to facilitate imports and support the U.S. supply of PPE and
other COVID-19-related products.
The pandemic has not noticeably affected the timeliness of CBP’s processing
and release of import shipments, but it has slowed other operations at U.S. ports.
In the months before and after the pandemic’s onset, CBP processed and
released about 97 percent of shipments within 24 hours after they arrived at U.S.
ports or after the importers filed required entry documents. The agency uses
these documents to calculate taxes, duties, and fees for the imported goods.
However, since the pandemic’s onset, more importers have filed entry
documents on or after, rather than before, their shipments’ arrival. According to
CBP officials, this has affected certain non-CBP operations. For example, the
officials said that because of increased congestion at U.S. ports—with many
ships waiting weeks to offload—importers often file the documents and pay any
duties and fees only after their goods have been offloaded. Since the ports use
the entry documents to schedule non-CBP operations such as offloading and
moving of cargo, the later filings of these documents have sometimes slowed
such operations, according to CBP officials.
View GAO-22-105034. For more information,
contact Kimberly Gianopoulos at (202) 512-
8612 or gianopoulosk@gao.gov.
Why GAO Did This Study
CBP monitors, regulates, and
facilitates the movement of
commodities through U.S. ports. The
agency staffs 328 U.S. ports, where
goods are imported and exported by
truck, rail, plane, and ocean vessel. In
fiscal year 2021, CBP processed 36.9
million import shipments and collected
approximately $93.8 billion in duties,
taxes, and other fees, including user
fees for inspections at U.S. ports.
The CARES Act includes a provision
for GAO to conduct monitoring and
oversight of the federal response to the
pandemic. For this report, GAO (1)
analyzed general trends in U.S.
international trade since the
pandemic’s onset, (2) identified steps
CBP took to respond to challenges
stemming from the pandemic, and (3)
determined the extent to which the
pandemic has affected CBP’s
processing and release of import
shipments and other operations at U.S.
ports.
GAO reviewed CBP documents and
analyzed data on overall trends in
international trade at U.S. ports. GAO
also interviewed private sector
representatives and officials at CBP
headquarters and at five ports. GAO
selected these ports based on
geographic diversity, trade levels, and
shipment methods.

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
Letter

1
Background
3
International Trade Trends Shifted after Onset of Pandemic
5
CBP Took Various Actions to Address Challenges Stemming from
the Pandemic
18
Pandemic Has Not Noticeably Affected Timeliness of CBP’s
Import Processing and Release
27
Agency Comments
31
Appendix I
Objectives, Scope, and Methodology
34

Appendix II
GAO Contact and Staff Acknowledgments
38

Table
Table 1: CBP Seizures of COVID-19-Related Products, March
2020–Feb. 2022
27

Figures
Figure 1: Total Monthly Number of Import Shipments Processed
by CBP, May 2018–Dec. 2021
6
Figure 2: Total Monthly Value of Imported Goods, May 2018–Dec.
2021
7
Figure 3: Total Monthly Value of U.S. Exports, May 2018–Dec.
2021
8
Figure 4: Total Monthly Number of U.S. Import Shipments Valued
at $800 or Less, May 2018–Dec. 2021
10
Figure 5: Total Monthly Value of U.S. COVID-19-Related Imports,
May 2018–Dec. 2021
12
Figure 6: Total Monthly Value of U.S. Imports, by Mode of
Transportation, May 2018–Dec. 2021
13
Figure 7: Total Monthly Value of U.S. COVID-19-Related Imports,
by Mode of Transportation, May 2018–Dec. 2021
15
Figure 8: Monthly U.S. Import Costs, Jan. 2018–Dec. 2021
16
Figure 9: U.S. Import Shipping Costs, by Mode of Transportation,
May 2018–Dec. 2021
17
Contents

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
Figure 10: COVID-19 Cases, Quarantines, Hospitalizations, and
Deaths in CBP’s Office of Trade and Office of Field
Operations, March 2020–March 2022
19
Figure 11: CBP’s Historical Collections of Customs User Fees and
Percentages of Its Eligible Expenses Covered by These
Fees, Fiscal Years 2017–2021
23
Figure 12: Percentages of Shipments CBP Processed and
Released within 24 Hours after Their Arrival at U.S. Ports
or after Importers’ Submission of Entry Filing on or after
Arrival, May 2018–Dec. 2021
28
Figure 13: Total Number of Shipments for Which Importers
Submitted Entry Filing before, on, and after Shipments’
Arrival at U.S. Ports, May 2018–Dec. 2021
30

Abbreviations

CARES Act
Coronavirus Aid, Relief, and Economic Security Act
CBP

U.S. Customs and Border Protection
CCRT
COVID-19 Cargo Resolution Team
CEE
Centers of Excellence and Expertise
FEMA
Federal Emergency Management Agency
FY

fiscal year
HTS

Harmonized Tariff Schedule of the United States
OFO

Office of Field Operations
PPE

personal protective equipment
USITC
U.S. International Trade Commission

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441 G St. N.W.
Washington, DC 20548
September 19, 2022
Congressional Committees
The COVID-19 pandemic has affected nearly all aspects of international
commerce, including cross-border trade. For example, labor shortages
and port congestion led to a severe shortage of available shipping
containers, and freight rates reached historic highs in 2021, according to
the United Nations Conference on Trade and Development.1 The
container shortage contributed to worldwide supply chain disruptions, with
far-reaching consequences for businesses, consumers, and economies.2
The Department of Homeland Security’s U.S. Customs and Border
Protection (CBP) monitors, regulates, and facilitates the movement of
imported and exported commodities through U.S. ports of entry.3
International trade is a critical component of the U.S. economy. For
example, in 2021, imports of goods amounted to approximately $2.9
trillion and exports amounted to about $1.8 trillion—nearly 13 percent and
8 percent of U.S. gross domestic product, respectively.4
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act)
includes a provision for us to monitor and report on the federal response
to the pandemic.5 In this report, we (1) examine general trends in U.S

1United Nations Conference on Trade and Development, Container Shipping in Times of
COVID-19: Why Freight Rates have Surged, and Implications for Policymakers, Policy
Brief No. 84 (Geneva: April 2021), 84.
2U.S. International Trade Commission, “The Impact of the COVID-19 Pandemic on Freight
Transportation Services and U.S. Merchandise Imports” in Shifts in U.S. Merchandise
Trade, 2020, Publication 5239 (Nov. 2021), accessed Mar. 1, 2020,
https://www.usitc.gov/research_and_analysis/tradeshifts/2020/special_topic.html.
3At U.S. ports of entry, CBP officers or employees are assigned to review shipments, clear
travelers, collect duties, and enforce U.S. import and export laws and regulations.
Elsewhere in this report, we refer to ports of entry as ports.
4Bureau of Economic Analysis, U.S. International Trade in Goods and Services,
December 2021.
5Pub. L. No. 116-136, § 19010(b), 134 Stat. 281, 580 (Mar. 27, 2020). All of GAO's reports
related to the COVID-19 pandemic are available on GAO's website at
https://www.gao.gov/coronavirus.
Letter

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
international trade since the pandemic’s onset in March 2020,6 (2) identify
steps CBP has taken to mitigate challenges associated with administering
imports and exports since the pandemic began, and (3) determine the
extent to which the pandemic has affected CBP’s processing and release
of import shipments and other operations at U.S. ports.
To examine general trends in U.S. international trade since the
pandemic’s onset, we analyzed U.S. Census Bureau7 and CBP trade
data for May 2018 through December 2021.8 To assess the reliability of
these data, we reviewed relevant documentation, interviewed
knowledgeable CBP officials, and conducted electronic data testing. We
determined that the data were sufficiently reliable for our purposes of
analyzing international trade trends during the pandemic and selecting a
nongeneralizable sample of ports for further review.
To identify steps CBP has taken to mitigate challenges associated with
administering imports and exports since the pandemic’s onset, we
gathered and analyzed data on CBP’s collection of user fees as reported
in its fiscal year (FY) 2023 Congressional Budget Justification.9 We
interviewed CBP budget officials about these fees and found the data
sufficiently reliable for the purpose of summarizing certain user fee
collections in FYs 2017 through 2021. In addition, we spoke with CBP
officials in Washington, D.C., and with CBP staff and trade community
representatives at five U.S. ports. We selected this nongeneralizable

6For the purposes of this report, we date the pandemic’s onset to March 11, 2020, when
the World Health Organization declared the COVID-19 outbreak to be a global pandemic.
7We used publicly available data from the U.S. Census Bureau to characterize trends in
trade for May 2018 through December 2021—a period spanning an equal number of
months before and after the pandemic’s onset—to obtain a balanced view of changes in
international trade trends. Our analysis included the value of trade associated with
products needed to prevent and address COVID-19 infection, the total value of import and
export shipments to the United States, and the cost of importing by various modes of
transportation.
8We reviewed U.S. Customs and Border Protection (CBP) trade data for May 2018
through December 2021, including the number of import shipments processed at U.S.
ports and the number of de minimis shipments (i.e., shipments valued at $800 or less). De
minimis shipments are those that CBP may admit free of duty and any tax imposed on or
by reason of importation for which the aggregate fair retail value in the country of shipment
of articles imported by one person on one day does not exceed $800. See 19 U.S.C. §
1321(a)(2)(C) and 19 C.F.R. § 10.151.
9In this report, “imports” and “exports” refer to imports and exports of goods.

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
sample of ports by using criteria such as geographic location, port type
(sea, land, or air), and trade value.
To determine whether the pandemic has affected CBP’s processing and
release of imported shipments or certain other operations at U.S. ports,
we reviewed and analyzed CBP data on processing and release of
imported shipments from May 2018 through December 2021.10 To assess
the reliability of these data, we reviewed relevant documentation, spoke
with knowledgeable CBP officials, and conducted electronic testing of
data. We determined that the data were sufficiently reliable for our
purpose of analyzing the timing of importers’ filing of certain customs
documents and the amount of time CBP took to process and release
import shipments. In addition, we interviewed CBP officials and trade
community representatives at the five selected ports.
See appendix I for further information about our scope and methodology.
We conducted this performance audit from April 2021 to September 2022
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
As the primary agency involved in monitoring, regulating, and facilitating
the flow of goods through U.S. ports of entry, CBP reviews import
shipments to determine whether they should be inspected for compliance
with U.S. laws and regulations. CBP’s process for reviewing, inspecting,
and releasing shipments to importers occurs in three phases: pre-entry,
entry, and post-entry.11

10We reviewed CBP trade data for May 2018 through December 2021, including the total
number of shipments for which importers submitted required entry documentation on or
after the shipments’ arrival and the percentage of import shipments that CBP processed
and released within 24 hours.
11CBP contributes to facilitating both imports and exports, but the majority of its trade
facilitation and enforcement work focuses on imports to the United States, according to
CBP officials. Depending on the type of product being imported, other U.S. federal
agencies may also have roles in examining shipments and taking enforcement actions.
For instance, the U.S. Fish and Wildlife Service examines selected imports that fall within
its jurisdiction.
Background

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
•
Pre-entry. CBP collects advance information about shippers,
importers, and cargo to evaluate shipments for potential import
security and trade enforcement risks.12 Before a shipment’s departure
from its point of origin, the carrier generally must electronically submit
a manifest13 in CBP’s Automated Commercial Environment.14 For
shipments imported by sea, importers are also generally required to
submit an importer security filing.15 This information feeds into CBP’s
Automated Targeting System, which screens the shipment information
against intelligence from CBP’s National Targeting Center and other
intelligence and law enforcement databases. The Automated
Targeting System assigns each shipment a risk-based score. CBP
reviews the submitted documents and the shipment’s risk score to
determine whether to release or inspect the cargo on its arrival.
•
Entry. According to CBP officials, the agency reviews all shipments
entering the United States to determine whether an inspection is
necessary. If the importer has submitted documentation known as an
entry filing, CBP either releases the cargo to the importer or pulls the
cargo for inspection.16 CBP inspections determine whether legal or
regulatory violations have occurred. If an inspection identifies no
violations, CBP releases the shipment to the importer. If the importer
has not submitted an entry filing, CBP holds the cargo in bonded
warehouses until the importer submits the entry filing or CBP seizes
the abandoned cargo, according to CBP officials.

12See CBP, CBP Trade Strategy: Fiscal Years 2009-2013 (Washington, D.C.: 2009).
13When required, importers and carriers must provide a manifest that documents the
names and addresses of shippers and consignees; detailed descriptions of the goods
being imported; information about the carrier; and information about the day, time, and
port of arrival. Specific filing requirements differ, depending on a number of criteria,
including the mode of entry (air, land, or sea) or the country of origin of the goods. See 19
C.F.R. Parts 4, 122-123.
14CBP’s Automated Commercial Environment is a system through which the trade
community reports imports and exports and the government determines imports’
admissibility.
15Importer security filings require information such as the shipment’s country of origin,
manufacturer, and seller and must be submitted to CBP no later than 24 hours before the
cargo is loaded on a vessel destined for the United States. 19 C.F.R. § 149.2.
16Submission of an entry filing—CBP Form 3461—initiates the cargo release process and
is typically required before CBP can release cargo. Generally, when entry documentation
is required, an importer may submit an entry filing before, on, or after the shipment’s
arrival. 19 C.F.R. §§ 142.2 and 142.3.

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
•
Post-entry. Within 10 working days after the time of entry, importers
generally must file an entry summary and deposit estimated duties if
these requirements have not been met.17 CBP uses the entry
summary to calculate customs duties and make an initial assessment
of taxes, fees, and duties owed.18 The agency may conduct a follow-
up review of the entry summary to verify the importer’s compliance
with trade laws and estimates of import taxes, fees, and duties.

After the pandemic’s onset in March 2020, the number of U.S. import
shipments declined for several months before rebounding to exceed
prepandemic levels. According to CBP officials, country-wide shutdowns,
first in Asia and then in the United States, caused this drop in the number
of import shipments in the initial months of the pandemic. Import
shipments began to increase as countries reopened, and e-commerce
activity and consumer demand increased exponentially in mid-2020. In
September 2020, the number of import shipments largely began to
exceed the number before the pandemic.
CBP trade data show that at the beginning of the pandemic, from March
2020 through June 2020, CBP processed a total of 10 million import
shipments—20 percent fewer than the 12 million it processed over the
same period in 2019. A year later, from March 2021 through June 2021,
CBP processed a total of 13 million import shipments—7 percent and 28
percent more, respectively, than the number processed during the same
months in 2019 and 2020. In December 2021, CBP processed 15 percent
more import shipments than it processed in December 2019.
Figure 1 shows the total number of import shipments CBP processed
each month from May 2018 through December 2021.

17If an importer is not required to, or chooses not to, file an entry summary at the time of
entry, the importer must file the entry summary, with estimated duties attached, within 10
working days after the time of entry. 19 C.F.R. § 142.12. See also 19 C.F.R. § 141.68
regarding time of entry.
18An entry summary consists of CBP Form 7501.
International Trade
Trends Shifted after
Onset of Pandemic
Imports Initially Declined
before Surpassing
Prepandemic Levels

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
Figure 1: Total Monthly Number of Import Shipments Processed by CBP, May 2018–Dec. 2021

Note: Numbers of shipments shown represent those for which CBP processed an entry filing (CBP
Form 3461). An entry filing provides information about a shipment from an overseas supplier to an
importer in the United States, including country of origin, product information, entry date, quantity
being imported, and dollar value.

Census Bureau trade statistics show that the total monthly value of import
shipments also declined at the pandemic’s onset before surpassing
prepandemic levels.19 According to CBP officials, the total monthly value
of all goods imported to the United States (i.e., import value) declined
after the pandemic’s onset, when factories and countries shut down, then
resurged as online shopping and demand for personal protective
equipment (PPE) increased. Census trade data show that from March
2020 through August 2020, monthly import values remained below their
prepandemic levels. Beginning in September 2020, total monthly import
values began to exceed those in the same month of the year before the
pandemic’s onset. For instance, in September 2020, the total import value
was 1 percent higher than in September 2019; in December 2021, the
total import value was 17 percent higher than in December 2019.

19We express import values in U.S. dollars to characterize trends in import volume and to
establish trends in a single unit of measure. Since the unit of measure for volume (e.g.,
kilogram or quantity) may differ across products, using quantity to accurately portray
trends in import volume is not feasible. We have adjusted all import values for inflation,
using December 2021 as the base month and using monthly import price indices from the
Bureau of Labor Statistics.

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
Figure 2 shows the total monthly value of imported goods from May 2018
through December 2021.
Figure 2: Total Monthly Value of Imported Goods, May 2018–Dec. 2021

Note: The Census Bureau’s import data contain information about the total monthly value of all
imported shipments that cleared U.S. customs. Census cannot reliably account for shipments valued
below $2,000; therefore, to improve the coverage, timeliness, and relevance of its trade statistics for
international goods, Census uses statistical methodologies to account for imported shipments valued
at less than $2,000. We have adjusted all import values for inflation, using December 2021 as the
base month and using monthly import price indices from the Bureau of Labor Statistics.

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The total monthly value of U.S. exports also dipped significantly after the
pandemic’s onset before rebounding and surpassing prepandemic export
levels late in 2021.20 The United States exported $430 billion of goods
from March 2020 through June 2020—26 percent less than the $543
billion of goods exported over the same period in 2019. One year later,
the United States exported $519 billion of goods from March 2021
through June 2021—4 percent more than the value of goods exported
over the same period in 2019. In December 2021, U.S. exports were 1
percent higher than in December 2019.
Figure 3 shows total monthly value of U.S. exports from May 2018
through December 2021.
Figure 3: Total Monthly Value of U.S. Exports, May 2018–Dec. 2021

Note: The Census Bureau’s import data contain information about the total monthly value of all
shipments exported from the United States. Census cannot reliably account for shipments valued
below $2,500; therefore, to improve the coverage, timeliness, and relevance of its trade statistics for
international goods, Census uses statistical methodologies to account for exported shipments valued
at less than $2,500. We have adjusted all export values for inflation, using December 2021 as the
base month and using monthly export price indices from the Bureau of Labor Statistics.

20We express export values in U.S. dollars to characterize trends in export volume and to
establish trends in a single unit of measure. Since the unit of measure for volume (e.g.,
kilogram or quantity) may differ across products, using quantity to accurately portray
trends in export volume is not feasible. We have adjusted all export values for inflation,
using December 2021 as the base month and using monthly export price indices from the
Bureau of Labor Statistics.
Exports Also Declined
before Rebounding to
Prepandemic Levels

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
According to CBP data, the total monthly number of de minimis imports
(i.e., shipments with a value of $800 or less that are processed at U.S.
ports and imported by one person on 1 day) has risen since the
pandemic’s onset.21 From May 2018 through February 2020—before the
pandemic’s onset—month-to-month growth in the number of de minimis
imports averaged roughly 2 percent; from March 2020 through December
2021—after the pandemic’s onset—month-to-month growth in these
shipments averaged over 8 percent.
CBP data show that the number of de minimis imports more than
doubled, from 23 million to more than 51 million, from March through July
2020 and rose by another 50 percent, from 51 million to 76 million, from
July 2020 through December 2021. From December 2019 through
December 2021, the number of de minimis imports increased by 173
percent.
Figure 4 shows the total number of de minimis import shipments CBP
processed each month from May 2018 through December 2021.

21According to CBP officials, the volume of de minimis shipments (also known as Section
321 shipments) began increasing before the pandemic largely as a result of an increase in
the de minimis value from $200 to $800 under the Trade Facilitation and Trade
Enforcement Act of 2015. Pub. L. No. 114-125, § 901(c), 130 Stat. 223 (Feb. 24, 2016).
This section amended section 321(a)(2)(C) of the Tariff Act of 1930, which is codified as
amended at 19 U.S.C. § 1321(a)(2)(C).
Import Shipments Valued
at $800 or Less Have
Risen Sharply since
Pandemic’s Onset

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
Figure 4: Total Monthly Number of U.S. Import Shipments Valued at $800 or Less, May 2018–Dec. 2021

Note: We calculated the numbers shown by counting all shipments with bills of lading for less than or
equal to $800 for each month.

Several CBP officials we spoke with attributed the rise in de minimis
imports to an increase in e-commerce during the pandemic. For example,
according to the officials, Los Angeles International Airport, which
processes 40 percent of all U.S. de minimis import shipments, processed
an exponentially greater number of de minimis shipments after the
pandemic’s onset. The officials told us that the airport processed 7 million
e-commerce shipments in FY 2019, 54 million in FY 2020, and 144 million
in FY 2021. As of December 2021, the port’s e-commerce totals for FY
2022 had already surpassed the totals for FY 2021. CBP officials said
that e-commerce now accounts for the vast majority of shipments
entering the United States.

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The pandemic triggered an increase in the volume and value of imports of
products used to prevent, diagnose, or treat COVID-19 infection, such as
PPE, testing kits, and ventilators.22 The total monthly value of such
imports averaged $12.5 billion from May 2018 through February 2020,
rising to an average of $16.6 billion from March 2020 through December
2021.23 Imports of COVID-19-related products accounted for 5 percent of
overall import value from May 2018 through February 2020 and 7 percent
from March 2020 through December 2021.24
Imports of PPE drove the surge in COVID-19-related imports in the
pandemic’s initial months.25 The total monthly value of PPE imports
increased by roughly 540 percent, from $832 million in February 2020 to
$5.3 billion in June 2020. PPE imports accounted for 7 percent of the
value of all COVID-19-related imports from May 2018 through February
2020, increasing to 16 percent from March 2020 through December 2021.
Figure 5 shows the total monthly value of COVID-19-related imports from
May 2018 through December 2021.

22For more information about factors influencing import trends in various types of COVID-
19-related products, see U.S. International Trade Commission, COVID-19 Related Goods:
The U.S. Industry, Market, Trade and Supply Chain Challenges, Investigation No. 332-580
(December 2020).
23U.S. Census Bureau trade statistics—a widely used source analyzing U.S. international
trade—do not contain precise data on import values of COVID-19-related products. As a
result, we estimated the import value of all product types and categories within those
types, using Harmonized Tariff Schedule of the United States (HTS) statistical reporting
numbers and associated product groupings listed by the U.S. International Trade
Commission (USITC). See U.S. International Trade Commission, COVID-19 Related
Goods: U.S. Imports and Tariffs, Investigation No. 332-576, USITC Publication 5073
(Washington, D.C.: June 2020). For more information about factors influencing import
trends in various types of COVID-19-related products, see U.S. International Trade
Commission, COVID-19 Related Goods: The U.S. Industry, Market, Trade and Supply
Chain Challenges, Investigation No. 332-580 (December 2020).
24See GAO-22-105397 for more information.
25For the purposes of this report, we refer to products used to prevent, diagnose, or treat
COVID-19 infection as COVID-19-related products.
Imports of Products to
Prevent or Address
COVID-19 Infection
Increased

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Figure 5: Total Monthly Value of U.S. COVID-19-Related Imports, May 2018–Dec. 2021

Notes: U.S. Census Bureau trade statistics—a widely used source of analysis of U.S. international
trade—do not contain precise data on the import value of COVID-19-related products. As a result, we
estimated the import value for all product types and categories within those types, using Harmonized
Tariff Schedule of the United States (HTS) statistical reporting numbers and associated product
groupings listed by the U.S. International Trade Commission (USITC). See U.S. International Trade
Commission, COVID-19 Related Goods: U.S. Imports and Tariffs, Investigation No. 332-576, USITC
Publication 5073 (Washington, D.C.: June 2020).
Product categories that USITC identified as COVID-19 related refer only to the subset of goods
considered to be COVID-19 related in each HTS-10 statistical reporting number. Furthermore,
revisions to the HTS on July 1, 2020; January 1, 2021; and July 1, 2021, provided several new HTS-
10 statistical reporting numbers that more narrowly defined some COVID-19-related product
categories.
To study the import value of these products throughout and before the COVID-19 pandemic, we
identified product categories that had changed since June 2020 and mapped them back to their
original statistical reporting number in USITC Publication 5073 to provide a consistent time-series of
monthly trade in these products. Therefore, the values shown overestimate the imports of products
directly relevant to COVID-19 response; nevertheless, these values are useful for tracking import
value trends for such products throughout and before the start of the COVID-19 pandemic.
We have adjusted all import values for inflation, using December 2021 as the base month and using
monthly import price indices from the Bureau of Labor Statistics.
aExamples of products included in the “Other” category include hospital beds and wheelchairs.

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
Our review of Census trade statistics showed that the total monthly value
of U.S. imports arriving by ocean vessel and other means, such as rail or
truck, dropped immediately after the pandemic’s onset, while the total
monthly value of imports arriving by air cargo increased slightly (see fig.
6). In February 2020, 22 percent of imports’ total value arrived by air
cargo, while 78 percent arrived by ocean vessel or other means. By May
2020, 33 percent of imports’ total value arrived by air cargo. The average
monthly value of products imported by air cargo rose from $50 billion for
the period from May 2018 through February 2020 to $57 billion for the
period from March 2020 through December 2021.
Figure 6: Total Monthly Value of U.S. Imports, by Mode of Transportation, May 2018–Dec. 2021

Note: The Census Bureau’s import data contain information about the total monthly value of all
imported shipments that cleared U.S. customs. Census cannot reliably account for shipments valued
below $2,000; therefore, to improve the coverage, timeliness, and relevance of its trade statistics for
international goods, Census uses statistical methodologies to account for imported shipments valued
at less than $2,000. We have adjusted all import values for inflation, using December 2021 as the
base month and using monthly import price indices from the Bureau of Labor Statistics. We
calculated import value for “other cargo” by subtracting the value of imports by ocean vessel cargo
and air cargo from total import value.

Despite initial challenges in acquiring COVID-19-related products by air, a
majority of such products were imported by air cargo instead of ocean
vessel in the pandemic’s early months. According to the U.S. International
Imports Shifted from
Ocean Vessel and Other
Means to Air Cargo Early
in Pandemic

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
Trade Commission (USITC), the shortage of passenger flights made it
difficult to acquire COVID-19-related products through air cargo in the first
days of the pandemic.26 However, airlines responded to the shortage by
increasing the number of dedicated air freighters to offset the decline in
passenger cargo, and some airlines removed seating in passenger
planes to create more space for cargo transport.27 According to CBP
officials, some importers of COVID-19-related products also shifted from
ocean freight to air cargo early in the pandemic to take advantage of
empty passenger planes and ad hoc flights.28
In addition, the Federal Emergency Management Agency’s (FEMA)
Project Airbridge—an effort to expedite imports of critical supplies—
began chartering air freighter flights from overseas, expanding importers’
options for acquiring COVID-19-related products by air cargo.29 According
to FEMA, from March 29 through June 18, 2020, the agency completed
249 flights through Project Airbridge facilitating imports of nearly 1.5
million N-95 masks, more than 2.5 million face shields, and 937 million
gloves.
Significant increases in maritime shipping costs also contributed to the
rise in imports via air cargo. According to knowledgeable industry
representatives, an increase in the price of ocean containers—from
$5,000 to $25,000 per container in some cases—had a large influence on
importers’ transitioning from ocean vessel to air cargo. The price of air
cargo also rose, but more moderately.
U.S. imports of COVID-19-related products by air cargo averaged $8.3
billion monthly from May 2018 through February 2020. This amount
increased to $12.8 billion for the period from March through June 2020

26U.S. International Trade Commission, “The Impact of the COVID-19 Pandemic on
Freight Transportation Services and U.S. Merchandise Imports,” accessed June 27, 2022,
https://www.usitc.gov/research_and_analysis/tradeshifts/2020/special_topic.html.
27Air cargo can arrive in the hold, or “belly,” of a passenger plane (known as belly cargo)
or as dedicated air freight on a flight whose sole purpose is to deliver cargo.
28Ad hoc flights are nonscheduled flights on aircraft leased by logistics companies that
contract with shippers.
29Project Airbridge was a joint public–private sector effort led by FEMA. According to CBP
officials, PPE shipments imported by ocean vessel can take weeks, while shipments by air
take only hours. The project began in March 2020 and ended in June 2020.

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
before declining to $9.9 billion for the period from July 2020 through
December 2021.
Figure 7 shows the total monthly value of COVID-19-related products
imported by air cargo, ocean vessel, and other modes of transportation
from May 2018 through December 2021.
Figure 7: Total Monthly Value of U.S. COVID-19-Related Imports, by Mode of Transportation, May 2018–Dec. 2021

Note: The Census Bureau’s import data contain information about the total monthly value of all
imported shipments that cleared U.S. customs. Census cannot reliably account for shipments valued
below $2,000; therefore, to improve the coverage, timeliness, and relevance of its trade statistics for
international goods, Census uses statistical methodologies to account for imported shipments valued
at less than $2,000. We have adjusted all import values for inflation, using December 2021 as the
base month and using monthly import price indices from the Bureau of Labor Statistics. We
calculated import values for “other cargo” by subtracting the value of imports via ocean vessel cargo
and air cargo from total import values.

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
During the pandemic, higher shipping costs led to an increase in overall
import costs.30 Our analysis of Census Bureau trade data found that
importers’ shipping costs averaged $283 per $10,000 of goods imported
from May 2018 through February 2020. From March 2020 through
December 2021, average shipping costs increased by 20 percent, to
$340 per $10,000 dollars imported. Import charges per $10,000 of goods
remained stable from May 2018 through February 2020 but increased by
49 percent from March 2020 through December 2021.
According to CBP officials, the initial increase in shipping costs was
directly related to the high volumes of PPE coming into the United States.
For example, because customers were willing to pay higher prices for
PPE, shipping companies began to charge higher prices, which in turn
drove overall import costs higher. As figure 8 shows, import costs
increased steadily through December 2021.
Figure 8: Monthly U.S. Import Costs, Jan. 2018–Dec. 2021

Notes: The Census Bureau’s import data contain information about total monthly import charges paid
for all imported shipments that cleared U.S. customs. Census cannot reliably account for shipments
valued below $2,000; therefore, to improve the coverage, timeliness, and relevance of its trade

30These import costs represent freight, insurance, and other charges (excluding U.S.
import duties) incurred in loading the goods on the carrier at the port of export
and unloading the goods from the carrier at the first U.S. port. For overland shipments
originating in Canada or Mexico, import costs include freight, insurance, and all other
charges, costs, and expenses incurred in bringing the goods from the point of origin (i.e.,
where the shipment of goods begins its journey to the United States) in Canada or Mexico
to the first U.S. port.
Higher Shipping Costs
Drove Up Overall Import
Costs

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
statistics for international goods, Census uses statistical methodologies to account for imported
shipments valued at less than $2,000. We have adjusted all import costs for inflation, using
December 2021 as the base month and using monthly import price indices from the Bureau of Labor
Statistics.
The import costs shown represent the aggregate of all freight, insurance, and other charges
(excluding U.S. import duties) incurred in loading the goods on the carrier at the foreign port of export
and unloading the goods from the carrier at the first U.S. port of entry. For overland shipments
originating in Canada or Mexico, import costs include freight, insurance, and all other charges, costs,
and expenses incurred in bringing the goods from the point of origin in Canada or Mexico to the first
U.S. port of entry.

According to an analysis by the USITC, shipping costs for ocean vessels
began to rise in June 2020 because of recovering consumer demand for
goods as well as container shortages.31 As figure 9 shows, increased
shipping costs for air cargo and ocean vessels drove the increase in
overall shipping costs after the pandemic began.
Figure 9: U.S. Import Shipping Costs, by Mode of Transportation, May 2018–Dec.
2021

Notes: The Census Bureau’s import data contain information about total monthly shipping costs paid
for all imported shipments into the United States. Census cannot reliably account for shipments
valued below $2,000; therefore, to improve the coverage, timeliness, and relevance of its trade
statistics for international goods, Census implements statistical methodologies to account for
imported shipments valued at less than $2,000. We have adjusted all shipping costs for inflation,

31U.S. International Trade Commission, “The Impact of the COVID-19 Pandemic on
Freight Transportation Services and U.S. Merchandise Imports.”

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
using December 2021 as the base month and using monthly import price indices from the Bureau of
Labor Statistics. We calculated shipping costs for other cargo by subtracting import costs for
shipments via vessel cargo and air cargo from total import costs. Shipping costs include freight,
insurance, and other charges, excluding duties.

According to the Federal Reserve of St. Louis, the average global market
price of shipping a 40-foot container increased from about $1,330 in the
first week of February 2020 to about $11,100 in the second week of
September 2021. In the beginning of 2022, the average price of shipping
a container of goods across the Pacific Ocean was eight to nine times
higher than the average price before the pandemic, according to
Freightos, a digital booking platform for international shipping. Shipping
rates across the Pacific Ocean declined by 30 percent in May 2022 (to an
average of $10,672 per container) but remained roughly 35 percent
higher than shipping rates in early summer 2021, according to Freightos.
The increase in the cost of shipping containers caused the costs of ocean
shipping to rise more sharply than the costs of shipping by alternative
modes of transportation. From May 2018 through December 2021,
average monthly charges per $10,000 of goods imported by ocean vessel
rose by 26 percent, from $421 for May 2018 through February 2020 to
$532 for March 2020 through December 2021, according to Census trade
data. In contrast, average monthly charges per $10,000 of goods
imported by air cargo rose by 19 percent, from $213 for May 2018
through February 2020 to $253 for March 2020 through December 2021.
For imports by other means, including rail and truck, average monthly
charges per $10,000 of goods rose by 5 percent, from $175 for May 2018
through February 2020 to $185 for March 2020 through December 2021.

According to CBP officials, CBP has taken several actions to limit its
employees’ exposure to COVID-19. As frontline workers, CBP officers
have performed public-facing duties throughout the pandemic, and some
have contracted COVID-19 (see fig. 10). According to CBP officials, CBP
instituted a variety of changes to mitigate staffs’ risk of exposure,
including social distancing, mandatory PPE requirements, staggered
shifts, alternative work schedules, and teleworking. CBP also authorized
CBP Took Various
Actions to Address
Challenges Stemming
from the Pandemic
CBP Acted to Help
Mitigate Staffs’ Risk of
COVID-19 Exposure

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
weather and safety leave to reduce the number of individuals in a given
location, according to CBP officials.32
Figure 10: COVID-19 Cases, Quarantines, Hospitalizations, and Deaths in CBP’s
Office of Trade and Office of Field Operations, March 2020–March 2022

Note: The Office of Trade facilitates legitimate trade, enforces law, and protects the national economy
to ensure consumer safety and create a level playing field for U.S. businesses. The Office of Field
Operations conducts inspections and enforces immigration and customs laws at U.S. ports.

In addition, CBP modified certain processes and procedures to prevent
the spread of COVID-19. For example, at the Port of Laredo, CBP limited
person-to-person contact between truck drivers and staff by expanding
the use of available technologies, such as by requiring truckers to use
CBP’s preexisting online payment system instead of cash, according to
officials. As of January 2022, the port was conducting virtually no cash
transactions, according to officials.

To address COVID-19-related staff absences, CBP used flexible work
policies, including overtime, temporary staff assignments, telework, and
temporary or permanent reallocation of staff. For example, officials at
ports said they were able to use 29-day temporary duty assignments and
overtime to compensate for staff shortages. CBP also offered maximum
telework to staff whose duties could be performed while teleworking,
according to CBP officials. Uniformed officers with public-facing duties

32Weather and safety leave allows executive agencies to approve paid leave if certain
conditions prevent their employees from safely performing work at an approved location.
See 5 U.S.C. § 6329c.
CBP Acted to Maintain
Continuity of Operations
CBP Took Steps to Ensure
Adequate Staffing

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
continued to work in person, while nonessential ununiformed officers
worked remotely.
In addition, according to CBP officials, relatively low passenger volumes
during the pandemic allowed the agency to reallocate officers from
passenger processing to cargo processing to meet the heightened
demand created by the increase in e-commerce shipments. Officials at
one port also told us that CBP added permanent positions to cargo
services during the FY 2021 annual job bid cycle. According to officials
and private sector representatives, employee absences related to
COVID-19 had not significantly affected operations, as job sites had
adjusted to meet staffing needs.
CBP worked with private sector warehouse operators to address staffing
shortages that affected its operations, particularly those related to timely
delivery, presentation, and removal of cargo for inspection. According to
CBP officials, the Port of Los Angeles had a backlog of containers in May
and June 2020 due to warehouse staffing issues. These officials reported
that warehouse operators had reduced their staff when cargo drastically
declined at the beginning of the pandemic, which led to a lack of available
staff when cargo volumes increased after a few months. According to
CBP officials, CBP met with the warehouse operators to remind them of
their contractual commitments and the necessity of appropriate staffing to
meet CBP’s needs, and the issue was resolved within 3 to 4 weeks.
CBP port officials told us that when import and entry specialists from
CBP’s Centers of Excellence and Expertise (CEE) started working
remotely, CBP uniformed officers had to assume some of those
specialists’ duties.33 Before the pandemic, import specialists often
participated in on-site inspections of certain products under their purview
(i.e., medical supplies, electronics, and machinery) or other targeted
inspections. To accommodate the specialists’ expanded telework and
physical absence, uniformed CBP officers sent photographs, scanned
documents, and took other steps to facilitate the specialists’ inspections,
according to CBP officials.
Working remotely with CEE specialists and other government agencies’
staff was effective, according to port officials, but made inspections more

33In FY 2017, CBP officially established 10 CEEs to increase uniformity of practices
across ports, facilitate the timely resolution of trade compliance issues nationwide, and
further strengthen critical agency knowledge on key industry practices.
CBP Adapted Inspection
Operations to Address
Increased Telework

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
complex and caused some minor delays.34 For example, at one of the five
ports where we conducted interviews, CBP officials said that requesting
CEE staff to perform on-site inspections often required discussion with a
CEE supervisor and sometimes led to delays. To enhance CBP port
officials’ ability to conduct inspections, CEE specialists held trainings for
CBP officers—for example, teaching them to identify certain counterfeit
products. CEE specialists also sent images and descriptions of
counterfeit products to all ports for their awareness.
Like many other federal agencies, CBP shifted from conducting in-person
meetings to using virtual meeting platforms to preserve internal and
external communications during the pandemic.
For internal communications, CBP switched to Microsoft Teams for
meetings and communications. Officials noted that they came to
appreciate it as a communication tool.
For external communications, CBP began using virtual meeting platforms,
such as Zoom or Microsoft Teams, to maintain ongoing communications
with the trade community and provide updates on the status of CBP
operations. According to CBP officials, CBP has used virtual platforms for
meetings with brokers associations, freight forwarders, trucking
associations, and other stakeholders as well as for tours and seminars.
CBP personnel at the Port of Laredo told us that they had performed a
number of in-person visits and briefings prior to the outbreak but
transitioned to using virtual platforms for such activities after the
pandemic’s onset. Officials said that although this may have limited
access for some participants, Laredo’s online engagements often had
wider participation from groups previously unable to attend face-to-face
meetings. Such groups included Mexican government officials and
industry and trade association representatives as well as representatives
of Detroit automakers such as General Motors.
In addition, CBP established a page on its public website to provide trade
announcements and advisories related to its operations and the
pandemic. CBP also announced changes in its operations through a

34Other government agencies working with port officials included the Food and Drug
Administration, Environmental Protection Agency, and U.S. Department of Agriculture. In
a report that we expect to issue in fall 2022, we will examine the Consumer Products
Safety Commission’s withdrawal of port inspectors in response to the pandemic.
CBP Took Steps to Maintain
Communication during
Pandemic

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
series of Cargo Systems Messaging Service messages.35 For example,
the agency issued messages recommending that importers use its
automated systems to the fullest extent possible to minimize virus
exposure and maintain trade activities. Further, CBP issued public
bulletins conveying pandemic-related information to the trade community.
For example, officials at the Port of Los Angeles released a bulletin
regarding upcoming WebEx seminars, which, according to the officials,
would inform the trade community about changes in trade facilitation and
enforcement due to the pandemic, among other topics.
CBP officials and private sector representatives told us that CBP
communications were consistently maintained and transitioned well to
virtual platforms during the pandemic. For example, CBP officials we
spoke with said CBP headquarters did a good job of communicating with
them, despite some early confusion as information about COVID-19 was
initially changing rapidly. Private sector representatives said CBP was
very responsive to inquiries, proactive in sharing information, and helpful
in bringing together multiple stakeholders.
CBP has taken steps to address dramatic decreases in user fees
collected from airline passengers and other inspection fees, which help
fund associated CBP salaries and operations.36 A senior CBP official
testified to Congress that user fees provide significant support for port
operations and fund about 40 percent of CBP’s Office of Field Operations
(OFO) salaries.37
In the 3 years before the pandemic, CBP’s collections of user fees for
inspections of, among other things, commercial vessels and vehicles—
known as customs user fees—averaged about $552 million a year. In FYs
2017 through 2019, these fees covered about 78 percent of eligible CBP
expenses, according to CBP data. In contrast, CBP collections of these
fees in FYs 2020 and 2021 amounted to around $426 and $145 million,

35According to CBP, the Cargo Systems Messaging Service is one of its methods of
communicating news and updates to trade partners regarding its automated systems.
36CBP is authorized to use certain user fee revenues as reimbursement for certain
inspection activities it performs at ports and for associated costs. These fees include the
immigration inspection user fee, the agricultural quarantine inspection fee, and other
customs user fees collected pursuant to 19 U.S.C. § 58c.
37OFO maintains border security and facilitates lawful trade and travel at U.S. ports.
CBP Took Steps to Offset Loss
of Revenue from User Fees

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
respectively—about 65 percent of eligible expenses in FY 2020 and 20
percent in FY 2021, according to CBP data (see fig. 11).
Figure 11: CBP’s Historical Collections of Customs User Fees and Percentages of
Its Eligible Expenses Covered by These Fees, Fiscal Years 2017–2021

Note: The customs user fees shown are fees authorized under 19 U.S.C. § 58c. CBP collects these
fees as reimbursement for its inspections of commercial vessels, commercial vehicles (trucks), rail
cars, private aircraft and vessels, barges and other bulk carriers, air and sea passengers, cruise
vessel passengers, ferry passengers, and dutiable mail. CBP also collects user fees for broker
permits.

To help address this shortfall, Congress, through the Consolidated
Appropriations Act, 2021, provided CBP’s OFO with $840 million for
necessary expenses related to customs and immigration inspection and
pre-inspection services at, or in support of, ports. According to the act,
these funds were provided to offset the loss of fees for certain customs
services and other user fees as a result of the COVID-19 pandemic.38
According to CBP officials, the FY 2021 appropriation offset the majority
of the lost user fees. To cover the remainder of the loss, the agency
reduced overtime and nonessential travel, used carryover fees paid from
FY 2019, and delayed the entry dates of new employees, according to
CBP officials.

38Pub. L. No. 116-260, Div. F, Title V, § 541, 134 Stat. 1477 (Dec. 27, 2020). These funds
remained available until September 30, 2021.

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
OFO officials told us that as of April 2022, the agency estimated the
shortfall in user fees would be around $669 million for FY 2022. Through
the Consolidated Appropriations Act, 2022, Congress provided $650
million for the same purposes as in the 2021 act.39 The officials said that
CBP would likely use the mechanisms that it used for FY 2021—with the
exception of carryover funds and delayed hiring—to cover the $19 million
shortfall.

CBP took action to accommodate some of the financial challenges
importers faced as a result of the pandemic. On April 20, 2020, the
Secretary of the Treasury and CBP postponed for 90 days the deadline to
pay the deposit of certain estimated duties, taxes, and fees for importers
experiencing a significant financial hardship due to COVID-19.40
To expedite its provision of temporary financial relief to importers, CBP
did not require them to submit documentation establishing their eligibility
for duty deferment, according to CBP officials. Rather, according to
officials, CBP relied on importers’ comprehension of the conditions of the
duty postponement, which it communicated through its Cargo Systems
Messaging Service, the FAQs on CBP.gov, and repeated contacts with
the trade community. According to officials, CBP also relied on the
importers’ obligation to exercise reasonable care, as stated in Section
484 of the Tariff Act of 1930.41 According to CBP officials, as of
November 2021, 2,921 importers (roughly 1 percent of all importers) had
taken advantage of the 2020 duty postponement. CBP officials said that

39Pub. L. No. 117-103, Div. F, Title V, § 542, 136 Stat. 344 (Mar. 15, 2022).
40This temporary postponement applied only to entries or withdrawals from warehouses,
for consumption, that were made on or after March 1, 2020, and no later than April 30,
2020, by importers of record with a significant financial hardship. An importer was
considered to have significant financial hardship if the importer’s operation was fully or
partially suspended during March 2020 or April 2020 as a result of orders from a
governmental authority limiting commerce, travel, or group meetings because of COVID-
19 and if, as a consequence of such suspension, the importer’s gross receipts for March
13 through 31, 2020, or April 2020 were less than 60 percent of its gross receipts for the
comparable period in 2019.
4119 U.S.C. § 1484(a).
CBP Acted to Support
Importers and the U.S.
Supply of COVID-19-
Related Products
CBP Postponed Duty
Payments by Importers Facing
Financial Challenges

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
this resulted in the postponement of $579 million—4 percent of CBP’s
total revenue for that period—of estimated duties, taxes, and fees.
In March 2020, CBP formed the COVID-19 Cargo Resolution Team
(CCRT) to mitigate challenges related to the importation of PPE and other
COVID-19-related products. Such challenges included coordinating with
other government agencies and tracking large PPE shipments to state
and local governments. For example, according to officials, the CCRT
coordinated with various Pennsylvania government offices, U.S. senators,
and the Port of Philadelphia regarding the importation of PPE from China.
The CCRT also provided guidance to the importing community at large—
including the influx of new importers and nontraditional importers such as
state and local governments—on topics such as dutiable imports, the
entry process, and the clearance process. In addition to outlining
requirements for typical importing, the guidance listed importing
requirements for corporations, private individuals, and foreign
governments donating goods imported for relief efforts in response to
COVID-19.
The CCRT provided guidance in part through CBP’s COVID-19 Relief
Imports web portal, which it established to take and direct all cargo
inquiries related to importing medical supplies to fight the spread of the
virus. The portal allows users to review pertinent information and submit
direct inquiries to the CCRT. As of January 2022, the CCRT had received
more than 3,600 inquiries about topics such as PPE duties, importation,
and classification as well as requests for information about cargo holds
and guidance on facilitating imports and exports.
The CCRT also helped facilitate and track shipments of COVID-19-
related products. According to CBP, immediately after the CCRT’s
establishment, the team began tracking critical medical supply shipments
from overseas that FEMA’s Project Airbridge was airlifting to expedite
delivery. According to one CBP official, the CCRT worked with FEMA on
a daily basis to alert ports that shipments of these critical medical
supplies were arriving. Overall, the CCRT helped expedite the arrival and
clearance of 418 Project Airbridge flights as well as an additional 62
flights for other FEMA procurements. According to CBP port officials, the
CCRT was a useful initiative to address challenges related to PPE
distribution. As a result of this coordinated effort, personnel were able to
prepare for the immediate release of high-priority cargo.
CBP Created Team to Assist
Importers and Facilitate
Imports of COVID-19-Related
Products

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
To ensure adequate supplies of products such as PPE to meet U.S.
needs during the pandemic, CBP worked with FEMA to prevent the
export of such products without FEMA’s approval.42 In addition, CBP
worked with the Food and Drug Administration, the Centers for Disease
Control and Prevention, and the Department of Health and Human
Services to identify goods that CBP should prevent from being exported,
according to CBP officials.
CBP used the Automated Export System—a nationwide system
operational at all ports and for all methods of transportation—to review
over 20 million export cases, applying automated targeting rules or
manual review.43 As a result of that review, CBP presented almost 200
shipments to FEMA’s Export Cargo Review Working group, which then
determined whether each shipment should be redirected to U.S.
commerce, purchased for the national stockpile, or cleared for export.
CBP reported that it returned only 13 of those shipments to the U.S.
supply. Port officials we spoke with said they did not experience any
significant challenges in implementing FEMA’s Temporary Final Rule.
In carrying out its standard operations, CBP targeted and seized
counterfeit, unapproved, or otherwise substandard COVID-19-related
products. For example, CBP officials at the Port of Cincinnati, Ohio,
intercepted a shipment of “bathroom accessories” from South Korea that
they determined to be facemasks improperly branded with Food and Drug
Administration markings and labeling. In another example, CBP officials
at the DHL cargo facility in Philadelphia seized 100 COVID-19 rapid test
kits that were not authorized for emergency use in the United States.
From March 2020 through February 2022, CBP recorded 3,467 seizures
of COVID-19-related products, totaling more than 50 million items (see
table 1).

42In April 2020, FEMA issued a Temporary Final Rule allocating certain scarce or
threatened materials for domestic use and prohibiting their exportation from the United
States without FEMA’s explicit approval while the rule remained in effect. The rule was
extended on December 31, 2020, and was in effect until June 30, 2021.
43According to CBP, the Automated Export System—a joint venture between CBP,
several other federal agencies, and the export trade community—is the central point
through which export shipment data required by the agencies is submitted electronically to
CBP.
CBP Helped Identify and
Intercept Certain Exports of
COVID-19-Related Products
CBP Interdicted Counterfeit or
Unauthorized Imports of
COVID-19-Related Products

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
Table 1: CBP Seizures of COVID-19-Related Products, March 2020–Feb. 2022
Product
Number of seizures
Number of items seized
Masks
1,140
49,171,859
Hand sanitizers
43
579,353
Lianhua qingwena
209
228,780
COVID-19 test kits
426
183,798
“Virus Shut Out” lanyardsb
107
76,375
Antibody test kits
48
51,257
Hydroxychloroquine tablets
228
36,462
Vaccination cards
1,003
29,555
Chloroquine tablets
95
19,535
Azithromycin tablets
163
12,532
Respirator/ventilator
5
3,595
Total
3,467
50,393,101
Source: U.S. Customs and Border Protection (CBP). | GAO-22-105034
Note: CBP determined that these products were COVID-19 related.
aTraditional Chinese medicine used to treat COVID-19 and other illnesses.
bDevices purported to protect wearers from COVID-19 that the Environmental Protection Agency
determined were illegal.

Our review of CBP data found that the time the agency took to process
and release shipments did not change after the onset of the COVID-19
pandemic. According to officials, CBP cannot release a shipment into
U.S. commerce until the importer has submitted the entry filing in the
agency’s Automated Commercial Environment system before, on, or after
the shipment’s arrival.44

44According to CBP regulations, importers of goods for which entry documentation is
required may generally submit the entry filing before, on, or within 15 days after their
shipment’s arrival. 19 C.F.R. § 142.2.
Pandemic Has Not
Noticeably Affected
Timeliness of CBP’s
Import Processing
and Release
CBP’s Processing and
Release Times Remained
Stable after Pandemic’s
Onset

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
As figure 13 shows, our review of CBP data found that both before and
after the pandemic’s March 2020 onset, CBP released more than 97
percent of shipments within 24 hours after their arrival at U.S. ports (if the
entry filing had already been submitted) or after submission of the entry
filing (if submitted on or after the shipment’s arrival).45 According to CBP
officials, nearly all imports to the United States are released
automatically.
Figure 12: Percentages of Shipments CBP Processed and Released within 24 Hours
after Their Arrival at U.S. Ports or after Importers’ Submission of Entry Filing on or
after Arrival, May 2018–Dec. 2021

Note: Submission of an entry filing—CBP Form 3461—initiates CBP’s cargo release process and is
typically required before CBP can release cargo. Generally, when entry documentation is required, an
importer may submit an entry filing before, on, or after the shipment’s arrival. 19 C.F.R. §§ 142.2. and
142.3.

45For shipments whose importers submitted the entry filing before arrival, we calculated
processing time as the period between the shipment’s arrival and its release. For
shipments for which entry filing was submitted on or after arrival, we calculated processing
time as the period between submission of the entry filing and release of the shipment.

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
According to CBP port officials, congestion at U.S. ports during the
pandemic has caused uncertainty about when shipments will be
offloaded, leading more importers to submit entry filings after their
shipments arrive and slowing some non-CBP port operations. For
example, at times during the pandemic, dozens of container ships have
waited at anchor outside the Port of Los Angeles–Long Beach, some for
several weeks, before offloading, according to CBP officials. CBP officials
and private sector representatives we spoke with said that to postpone
paying duties and fees on goods before they are offloaded, some
importers may choose to submit their entry filings after their shipments
arrive.
Our review of CBP data showed an increase in the total number of
shipments for which an entry filing was submitted after arrival at a U.S.
port in the months after the pandemic’s onset (see fig. 12). On average,
the percentage of entry filings submitted at least 1 day after the
shipment’s arrival rose from 46 percent in May 2018 through February
2020 to 55 percent in March 2020 through December 2021. In March
2020, 49 percent of all entries were filed at least one day after arrival,
increasing to 57 percent in December 2021.

Port Congestion Has Led
More Importers to Submit
Entry Filings after
Shipments’ Arrival,
Delaying Some Port
Operations
Factors Contributing to Port Congestion
during Pandemic
A number of factors have contributed to port
congestion during the COVID-19 pandemic,
according to CBP officials and private sector
representatives. For example:
•
Unavailability of truck drivers,
longshoremen, and truck chassis to move
shipments
•
Larger numbers of shipments to certain
ports
•
Insufficient port capacity and
infrastructure for increasingly larger
vessels
•
Infection of warehouse staff with COVID-
19
•
Stay-at-home orders for nonessential
employees
•
Incentives for carriers to leave shipments
on docks to collect fees from importers
while their shipments await pickup
Source: GAO interviews with U.S. Customs and Border
Protection (CBP) officials and private sector representatives.
|  GAO-22-105034

Page 30
GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
Figure 13: Total Number of Shipments for Which Importers Submitted Entry Filing before, on, and after Shipments’ Arrival at
U.S. Ports, May 2018–Dec. 2021

Note: An importer submits an entry filing—CBP Form 3461—to initiate the cargo release process and
is typically required before CBP can release cargo. Generally, when entry documentation is required,
an importer may submit an entry filing before, on, or after the shipment’s arrival. 19 C.F.R. §§ 142.2.
and 142.3.

CBP officials and industry representatives told us that that the increase in
submissions of entry filings after shipments’ arrival may have affected
some non-CBP port operations during the pandemic. Cargo offloading
and transportation services at ports use information from CBP entry filings
to schedule the staff and trucks necessary for offloading and moving
cargo. When entry filings are submitted after shipments’ arrival, offloading
and transportation service providers at ports do not receive this
information in advance and, as a result, may assign insufficient numbers
of staff or trucks to move the cargo when it arrives.

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GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
We provided a draft of this report to the Department of Homeland Security
for review and comment. The department provided technical comments,
which we incorporated as appropriate.
We are sending copies of this report to the appropriate congressional
committees, the Secretary of Homeland Security, and other interested
parties. In addition, the report is available at no charge on the GAO
website at https://www.gao.gov.
If you or your staff have any questions about this report, please contact
me at (202) 512-8612 or gianopoulosk@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made key contributions to this
report are listed in appendix III.

Kimberly M. Gianopoulos
Director, International Affairs and Trade

Agency Comments

Page 32
GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
List of Committees
The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Patty Murray
Chair
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Rosa L. DeLauro
Chair
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Frank Pallone, Jr.
Chairman
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives

Page 33
GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives
The Honorable Richard Neal
Chairman
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives

Appendix I: Objectives, Scope, and
Methodology

Page 34
GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
In this report, we (1) examine general trends in U.S. international trade
since the COVID-19 pandemic’s onset in March 2020, (2) identify steps
that U.S. Customs and Border Protection (CBP) has taken to mitigate
challenges associated with administering imports and exports since the
pandemic began, and (3) determine the extent to which the pandemic has
affected CBP’s processing and release of import shipments and other
operations at U.S. ports.
To address these objectives, we selected a nongeneralizable sample of
five ports of entry across the United States for virtual site visits: John F.
Kennedy International Airport; Los Angeles International Airport; and the
Ports of Laredo, Los Angeles, and Long Beach. Our criteria for selecting
this sample included total import value, change in total import value
before and after the pandemic, geographic diversity, and port type. In
selecting the ports for our sample, we used Census Bureau trade
statistics and CBP data to develop a list of the top 10 percent of ports,
ranked by total import value, from September 2018 through August
2021.1 We then narrowed that list to ports that experienced the greatest
change in total import value from a selected period before the pandemic’s
onset (April 2019–February 2020) through a selected period after the
pandemic’s onset (April 2020–February 2021).2 To make our final
selections, we considered geographic diversity and port type. We
selected ports representing the United States’ east and west coasts and
southern border as well as a range of port types (sea, land, and air).
To address our objectives, we also interviewed CBP officials and staff as
well as trade community stakeholders. We interviewed officials in several
CBP offices and bureaus in Washington, D.C., including the Office of
Trade and the Office of Field Operations.3 We also interviewed personnel
from CBP’s Centers for Excellence and Expertise (CEE). In addition, we

1The dimensions we considered included total import trade value, air import value, vessel
import value, other import value, West region import value, Northeast region import value,
South region import value, and Midwest region import value.
2We considered the ports with the greatest change in total import value to be the five ports
where data on the value of imports processed showed the largest increase or decrease
from the selected period before the pandemic’s onset through the selected period
following the onset. To more clearly compare any changes between the pre-pandemic and
post-pandemic periods for the purposes of our selection, we excluded the month of March
2020.
3CBP’s Office of Trade facilitates legitimate trade, enforces law, and protects the national
economy to ensure consumer safety and create a level playing field for U.S. businesses.
The Office of Field Operations maintains border security and facilitates lawful trade and
travel at U.S. ports.
Appendix I: Objectives, Scope, and
Methodology

Appendix I: Objectives, Scope, and
Methodology

Page 35
GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
interviewed stakeholders from the trade community at each of the five
selected ports, including brokers, freight forwarders, and other
representatives of trade associations. While the views of CBP field
officials and private sector stakeholders are not generalizable to all
locations, they provided vital insight into the impact of the COVID-19
pandemic on the Office of Field Operations’ and the ports’ workforces as
well as operational modifications undertaken throughout the pandemic.
To examine general trends in U.S. international trade since the
pandemic’s onset, we analyzed U.S. Census Bureau trade statistics on
import and export values and import costs as well as CBP data on the
number of entries CBP processed. Specifically, we used Census trade
statistics and CBP data to analyze monthly de minimis shipment trends,
import and export values, the total number of entries processed, import
values of COVID-19-related products, and import value by mode of
transportation for May 2018 through December 2021. We chose this
period, representing an equal number of months before and after the
pandemic’s onset in March 2020, to obtain a balanced view of changes in
international trade trends. Because our analysis showed considerable
declines in imports and exports in the pandemic’s initial months (March
2020–June 2020) followed by an established recovery in its later months
(July 2020–December 2021), we report trends in the initial and later
months to best characterize the general trends we observed.
To assess the reliability of the Census trade statistics regarding the total
value of import and export shipments to the United States, the value of
trade associated with products most needed to prevent and address
COVID-19 infection, and import costs by mode of transportation from May
2018 to December 2021, we reviewed relevant documentation and
conducted electronic data testing. We determined that these data were
sufficiently reliable for our purposes of analyzing international trade trends
during the pandemic. To assess the reliability of CBP data, including the
number of import shipments processed into the United States and the
number of de minimis shipments, we reviewed relevant documentation,
interviewed knowledgeable CBP officials, and conducted electronic data
testing. We determined that these data were sufficiently reliable for our
purposes of analyzing international trade trends during the pandemic.
To examine the actions CBP took to respond to challenges associated
with administering imports and exports since the pandemic began, we
analyzed CBP data on employee COVID-19 cases from March 2020
through March 2022, including confirmed cases, hospitalizations, deaths
due to COVID-19, and quarantined employees. We had collected these

Appendix I: Objectives, Scope, and
Methodology

Page 36
GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
data for a June 2021 report and updated them for our current report.4 The
data are maintained in CBP’s Workforce Incident Tracker, established in
July 2020, according to CBP officials. To assess the reliability of CBP
data on employee COVID-19 cases for our June 2021 report, we
conducted electronic testing, reviewed documentation such as CBP
guidance for entering data in the Workforce Incident Tracker, and
interviewed relevant CBP headquarters officials involved in establishing
the tracker and verifying case data. We found the data were sufficiently
reliable to provide approximate summary data for COVID-19 cases,
hospitalizations, and deaths among CBP’s workforce as well as the
approximate number of employees in quarantine status.
In addition, we gathered and analyzed data on CBP’s collection of user
fees as reported in its Congressional Budget Justifications. We also
interviewed CBP budget officials to verify the reliability of these user fee
amounts. Further, we examined key CBP policies and procedures
established to reduce the spread of COVID-19, such as social distancing
measures and the use of protective equipment. We also reviewed various
pieces of legislation and regulations related to CBP’s efforts to mitigate
any challenges caused by the pandemic. Moreover, we reviewed
documents and guidance related to CBP’s COVID-19 Cargo Resolution
Team (CCRT), such as guidance that the CCRT dispersed through the-
public facing COVID-19 Relief Imports web portal. Finally, we spoke with
officials at CBP headquarters, the CEEs, and the five selected ports to
obtain information about challenges that the agency had faced and how it
had addressed them.
To determine the extent to which the pandemic affected CBP’s
processing and release of import shipments and certain other port
operations, we analyzed CBP data for May 2018 through December
2021, showing the amount of time CBP took to clear a shipment after the
importer filed entry documentation or arrived at a U.S. port. We also
analyzed CBP data for May 2018 through December 2021, showing the
timing of importers’ submission of entry filings (i.e., before, on, or after
their shipment’s arrival in the United States) and changes in the timing of
these submissions after the pandemic’s onset. To assess the reliability of
these data, which CBP had compiled and aggregated, we reviewed
relevant documentation, interviewed knowledgeable CBP officials, and
conducted electronic data testing. We also reviewed descriptive statistics

4See GAO, Border Security: CBP’s Response to COVID-19, GAO-21-431 (Washington,
D.C.: June 14, 2021).

Appendix I: Objectives, Scope, and
Methodology

Page 37
GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
provided by CBP for variables relevant for analyzing processing times, as
well as missing values, to assess the reliability of the data. We
determined that these data were sufficiently reliable for our purposes of
(1) analyzing the amount of time CBP took to process and release import
shipments and (2) determining whether importers filed their import entries
before or after their arrival at port. In addition, we asked officials at CBP
headquarters and the five selected ports as well as private sector
representatives at the ports about any effects of the pandemic on port
operations.
We conducted this performance audit from April 2021 to September 2022
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.

Appendix II: GAO Contact and Staff
Acknowledgments

Page 38
GAO-22-105034  Pandemic's Effect on U.S. Customs Operations
Kimberly Gianopoulos at (202) 512-8612 or GianopoulosK@gao.gov
In addition to the contact named above, Christina Werth (Assistant
Director), Mason Thorpe Calhoun (Analyst-in-Charge), Larissa Barrett,
James Boohaker, Lilia Chaidez, Reid Lowe, Nisha Rai, Claudia
Rodriguez, Brian Tremblay, Anna Watson, and Alexander Welsh made
key contributions to this report.
Appendix II: GAO Contact and Staff
Acknowledgments
GAO Contact
Staff
Acknowledgments
(105034)

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