To all who sat for the April 23rd CBLE (Customs Broker License Exam) you may now have your weekends back. I know from personal experience that you are feeling both relief that the exam is over and anxiety about your results. Here is some info from the CBP website about what happens next:

CBLE Score Notification Letters and Appeal Due Dates

The bi-annual Customs Broker License Exam (CBLE) is administered on the fourth Wednesday of April and October.  Exam Results Letters are emailed to examinees within two to three weeks from the date of the exam. First Appeals are due no later than 60 days from the date the Exam Results Letters were sent. Second Appeals are due no later than 60 days from the date the First Appeal Results Letters were sent.

Pass Rate Information

The October 23, 2024 CBLE resulted in a 24% pass rate prior to appeal decisions.

The May 1, 2024 CBLE resulted in a 13% pass rate prior to appeal decisions.

The October 25, 2023 CBLE resulted in a 34% pass rate prior to appeal decisions.

The April 26, 2023 CBLE resulted in a 5.5% pass rate prior to appeal decisions.

I will write about the appeal process after the results of the April exam are posted.

What is “customs business”? Licensed Customs Brokers deal with customs business on a daily basis but their activities are not always clear to new clients. For example, classifying goods for others is definitely customs business.

Importers, if you have been relying on your suppliers for HTS classifications of your products check this September 2022 CBP ruling. Briefly, it states that suppliers are not qualified to provide HTS classifications unless they employ LCBs (Licensed Customs Brokers), even with a disclaimer that the information is advisory.

Classifying goods for others is “customs business” and must be carried out by a licensed customs broker. Pursuant to 19 U.S.C. § 1641(b)(1), “[n]o person may conduct customs business (other than solely on behalf of that person) unless that person holds a valid customs broker’s license . . . .”

https://rulings.cbp.gov/ruling/H290535

The ruling includes the following language which explains that classifying to the six digit level is not considered customs business:

We note, however, that CBP has consistently held that classifying goods to the six-digit level of the HTS is not customs business and does not require a customs broker’s license. This level of classification “does not constitute customs business because the six-digit HTS provision is insufficient for entry.”

Contact mitch@adhoclogistics.com for classification help.

If you are a Licensed Customs Broker (LCB), it is a good idea to have a strategy in place to fulfill your continuing education requirement. Here is a reminder from the CBP website:

To maintain an active license, individually licensed brokers must earn 20 CE credits from qualifying educational activities that occur beginning January 1, 2025 through January 31, 2027. January 31, 2027 is the end of the current triennial period.

I have started gaining credits by registering and participating in Trade Outreach Webinars hosted by CBP. These are free of charge and there are a number of webinars to choose from each month. I must admit that some of the topics do not apply to my clients’ commodities. However, I am learning something from each webinar, which is the goal of continuing education, and avoiding a scramble toward the end of the triennial period.

Why not get started now? Here is the link for Trade Outreach Webinars:

https://www.cbp.gov/trade/stakeholder-engagement/webinars

I have fielded quite a few questions about tariffs and Customs Brokers in the last few weeks. While importers are familiar with brokers, many others are not. Here is some info from the CBP website:

Customs brokers are private individuals, partnerships, associations or corporations licensed, regulated and empowered by U.S. Customs and Border Protection (CBP) to assist importers and exporters in meeting Federal requirements governing imports and exports. Brokers submit necessary information and appropriate payments to CBP on behalf of their clients and charge them a fee for this service.

Brokers must have expertise in the entry procedures, admissibility requirements, classification, valuation, and the rates of duty and applicable taxes and fees for imported merchandise.

There are approximately 14,454 active licensed Customs brokers in the United States.

Corporations, partnerships and associations must have a broker license to transact Customs business. Each of these businesses must have at least one individually licensed officer, partner or associate to qualify the company’s license. Failure to have a qualifying officer or member (of a partnership) for more than 120 days will result in the revocation of the broker license.