Passing the CBLE (Customs Broker License Exam) and background check to obtain a Customs Broker License is a difficult endeavor. LCBs (Licensed Customs Brokers) know that they must file a Triennial Status Report and pay the associated fee every 3 years. But what if, for whatever reason, a broker has missed the deadline? If so you still have time to save your license. Here is some info from the CBP website.

Failure to submit a TSR and associated fee by February 29, 2024 will result in a license suspension by operation of law on March 1, 2024.

CBP provides a Certified Letter to each licensed broker who fails to submit a timely TSR and associated fee at the last known address on file with CBP.

It is the broker’s responsibility to maintain current address information with CBP.

Failure to submit a TSR and associated fee within 60 days of the suspension warning letter will result in a license revocation by operation of law without prejudice to the submission of a new license application.

This means that the revoked license cannot be reinstated, and the affected broker may submit a new license application.

License revocations are published in the Federal Register.

Many of my clients are hard-working owners or operators of small businesses. They don’t have in-house compliance or logistics expertise, so must wear several hats. Day to day activities or unexpected issues take up most working hours. As a result, functions such as logistics planning and import/export compliance are often unmanaged or left entirely to LSPs (Logistics Service Providers). While LSPs are valued resources, the ultimate responsibility for compliance rests with the USPPI. You can outsource a lot of the activity but not the responsibility.

Making sure that your business is in compliance with import and export regulations is good risk management as well as good business. Think of it as insurance. A few basic steps can make a big difference and can be implemented quickly.

Ad Hoc Logistics can provide step by step guidelines, train your employees, and set up sustainable procedures. Our copyrighted programs include:

Exporting for Smart People- Because You’re No Dummy

Red Flag Screening

A to Z of Managing Logistics

Contact mitch@adhoclogistics.com for info.

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No, I’m not referring to golf, but using links as a logistics term. Exporters tend to become comfortable with their LSPs (Logistics Service Providers) and may be overly reliant on a single provider. Supply chain audits and best practices make it clear that diversifying LSPs can help mitigate disruptions, improve service, and possibly reduce costs.

Logistics is tactical in support of supply chain strategy, so must be able to adapt to the planned diversification. The textbook terms nodes and links are descriptive in logistics and supply chain discussions. Nodes are fixed locations such as factories and distribution centers. Links are Logistics Service Providers (LSPs) which connect the nodes from pick up (first mile), through line-haul operations (middle mile), to end user delivery (last mile). The links include ocean and air carriers, freight forwarders, truck lines, integrated parcel systems, customs brokers, and possibly 3PLs. It is easier to change links than nodes. However, if diversification is to reduce supply chain disruptions, both nodes and links must be strengthened.

New LSPs must be evaluated for their export compliance and ability to perform first mile, middle mile, and last mile operations. Details matter. Failure to review documentation, for example, can cause customs delays. New LSPs can make or break supply chain strategy. Consider their services as “value adds” rather than just cost. Consistent performance is more important than rates when new links are utilized in your supply chain.

Diversifying any supply chain requires time, a complete project plan, upper management commitment, and attention to detail.

We can help you work with the links. Contact mitch@adhoclogistics.com for assistance.

As all logistics professionals know, problem solving is a big part of the job. My clients are mostly small or medium sized firms working with minimal staffs, so I frequently assist them in resolving service issues. I have shared my thoughts about customer service in previous posts. AI is adding a new way of interacting with supply chain partners and can be an efficient way to transmit info. However, for me, transmitting info is not the issue. Ultimately, clients of LSPs need someone to take responsibility and actually solve the problem without passing the buck.

We engage with a variety of providers including freight forwarders, carriers, integrators, and customs brokers. Most have automated systems for efficiency and cost control purposes. When looking for a status update or answer to a simple question these systems are fine. Self service can be frustrating, though, when the problem is not easily described, and is of no use for more complex issues. Information is easier to get than action.

The ability/authority to solve problems is what defines great customer service. Reaching a human being in customer service requires patience and many times that person is simply reading from a script. If I haven’t been able to solve the problem on-line then I need someone with the ability and authority to resolve the issue.

LSPs, don’t force your clients to dump problems on their account rep or e mail the CEO. A few key people in customer service roles with the authority to fix problems on the spot will earn you a lot of customer loyalty.

Agree?

Clients often ask me to train new employees on the basics of international trade and customs clearance. This includes the roles of LSPs (Logistics Service Providers). Shippers are usually familiar with Freight Forwarders but may be unclear about Customs Brokers. Here is some info from the CBP website for reference:

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.

Customs broker. “Customs broker” means a person who is licensed under this part to transact customs business on behalf of others.

Customs business. “Customs business” means those activities involving transactions with CBP concerning the entry and admissibility of merchandise, its classification and valuation, the payment of duties, taxes, or other charges assessed or collected by CBP on merchandise by reason of its importation, and the refund, rebate, or drawback of those duties, taxes, or other charges. “Customs business” also includes the preparation, and activities relating to the preparation, of documents in any format and the electronic transmission of documents and parts of documents intended to be filed with CBP in furtherance of any other customs business activity, whether or not signed or filed by the preparer. However, “customs business” does not include the mere electronic transmission of data received for transmission to CBP and does not include a corporate compliance activity.

Contact mitch@adhoclogistics.com for info about our copyrighted presentation “Exporting for Smart People”.

Electronic Export Information (EEI) filing has become routine for exporters and it is easy to “file it and forget it” once the submission has gone through.

Auditing EEI ((also referred to as AES) filings is a good business practice. If you are a self filer is anyone checking the accuracy of your submissions? Does your freight forwarder have an audit procedure in place if they are filing for you? Here is the risk:

§ 30.71 False or fraudulent reporting on or misuse of the Automated Export System.

(1) Failure to file; submission of false or misleading information. Any person, including USPPIs, authorized agents or carriers, who knowingly fails to file or knowingly submits, directly or indirectly, to the U.S. Government, false or misleading export information through the AES, shall be subject to a fine not to exceed $10,000 or imprisonment for not more than five years, or both, for each violation.

Are you aware of this potential filing error?

A common misconception is that EEI and Commercial Invoice value should match. However, inland freight and insurance charges must be accounted for in the EEI filing whether or not they are on the commercial invoice.

Contact mitch@adhoclogistics.com for assistance.

BIS (Bureau of Industry and Security) has recently revised their website making it a little easier to navigate. This is helpful. However, in my opinion, the CCL (Commerce Control List) remains difficult to use. The CCL Index is a good starting place but from there the reader is quickly in the weeds.

I’m reviewing and updating a Master Parts List for a client and am easily able to check HTS and Schedule B codes. ECCN (Export Control Classification Number) verification is a much longer process. Here is a link to Category 5- Telecommunications and Information Security as an example:

https://www.bis.doc.gov/index.php/documents/regulations-docs/2336-ccl5-pt1-3/file

The entire CCL consists of this type of incomprehensible documentation. BIS, how about revising the CCL to make it more user friendly? Anyone else agree with me?