Mitch Kostoulakos, LCB• Ad Hoc Logistics LLC, Int’l Logistics Consultant/Licensed Customs Broker

I have always favored Continuing Education (CE) requirements for brokers. Now that this final rule has become effective I would suggest that CBP take a good look at the CBLE (Customs Broker License Exam). The passing rate for the April 2023 exam was only 5.5%. The rates for previous exams were low as well, so not many new brokers will be entering the profession. Is this what CBP wants?

LCBs take a look at the April exam and see if you could pass it.

https://lnkd.in/d2_ZdfzJ

Brandon Lord Director at U.S. Customs and Border ProtectionExecutive Director at U.S. Customs and Border Protection

On Monday, July 24, CBP’s final rule for our new Broker Continuing Education (CE) requirement became effective. Answers to a few frequent questions I’ve been getting:

1. CE credits won’t need to be reported by individually licensed brokers to CBP until the 2024-2027 Triennial Status Report that is due in February 2027.

2. CBP will not require the full 36 hours of CE credits during the initial 2024-2027 triennial. Future triennial periods will require the full 36 hours of CE credits.

3. CBP’s next step will be to solicit for and select accreditors who will review and approve non-government training content for broker continuing education credits.

Check out our website below and the factsheet under CBP Publications for more information. I look forward to implementing the CE requirement!

With less than 90 days before the next CBLE (Customs Broker License Exam), candidates are advised to start planning how to prep. Thanks to Pete Mento here is a group of LCBs ready to help you: https://www.linkedin.com/groups/12862151/

From the CBP website:

The next CBLE will be on October 25, 2023. Please continue to monitor these Announcements for the registration period dates to be posted.

CBP has contracted with PDRI to administer the October 2023 exam. PDRI is utilizing PSI resources as part of administering the CBLE.

CBP highly recommends that CBLE candidates have paper copies of the references available during the exam. Please click on the Reference Materials tab below for additional information.

NOTICE: Given the evolving COVID-19 situation examinees are responsible for checking the COVID-19 page (https://www.psionline.com/important-notice-update-concerning-covid-19-c…) regularly to find out if there is a vaccine and/or mask mandate at the registered testing site. It is THE EXAMINEE’S responsibility to stay up to date. CBP will NOT provide refunds for those who are unable to test due to being uninformed or are noncompliant with the COVID-19 policy at their respective testing sites. CBP recommends that the examinee checks the website regularly leading up to the exam, including the night before the CBLE.

Mid-year is a good time to check your HTS and Schedule B codes. The HTS has been revised 10 times so far in 2023. The Census Bureau publishes lists of obsolete Schedule B codes in January and July. Reviewing your codes at least semi-annually is a good business practice. However, in small/medium companies with minimal staffing this can easily be overlooked. When working with new clients checking codes is my first step in helping them achieve compliance with import and export regulations.

Why not take it one step further and develop a parts matrix listing descriptions, HTS codes, Schedule B codes, ECCN, License info, Country of Origin, and any other relevant import/export data? Your matrix will enable you to document new parts additions and changes as they occur. All departments involved in trade will be working with the same information so errors and omissions will be reduced.

Contact mitch@adhoclogistics.com for help with developing your matrix.

While most of my posts are focused on international logistics and regulations, I sometimes assist clients with domestic transportation issues. I have been on both sides of the table in the LTL industry so allow me to offer some thoughts.

Many shippers are making quick carrier changes at the moment due to the possible demise of YRC. Capacity will tighten and the remaining carriers will be selective in taking on, and pricing, new business. However, the industry will always be competitive and the pricing pendulum swings back and forth.

A common mistake made by small and medium sized clients is failing to prepare before meeting with carrier representatives. Another mistake is focusing on price. A better strategy is to emphasize value and show the desirability of your freight. If you determine that prospective carriers  have the capabilities to provide quality services you will be better prepared to discuss price.

Determine your specific transportation needs and goals ….for example

• Price- compare net rates (not % off because base rates differ), minimums
• Transit Times/Reliability- including pick up and delivery, terminal services, linehaul
• Inventory Costs- reduced transit time = reduced inventory costs… how transportation adds value
• Product Differentiation- faster, better service as a marketing tool
• Capability/Access- carrier has right equipment in right place at right time
• Security- carriers claim ratio and loss/damage experience
• Relationship- responsiveness and problem solving protocols

Analysis Prior to Negotiation

There is not much advantage to withholding your shipping profile from LSPs. Because the industry is competitive you will get a better deal if transportation providers know what volume they are bidding on and any specific service requirements. If this information is not available to them they will hedge their bets and be less aggressive in their offers. Gather some data and present it. This will give you professional status in the eyes of your carriers. Here is some minimum information needed. Most of it can be found in bill of lading or invoice files.

• Volume/Frequency- # of shipments per day, week, or month
• Weight- average weight per shipment
• Dimensions- standard dimensions, if any… palletized or non palletized…pictures are helpful
• Heaviest Shipping lanes- domestic and international
• Services- priority or economy, express or deferred
• Density- pounds per cubic foot ( for motor carriers)
• Classification- NMFC item numbers (for motor carriers)
• Dimensional Weight or Dim Factor (for air freight forwarders)
• Packaging type- transportation only, display, labeling
• Freight Payment Terms- prepaid, collect, third party
• Control- Who has authority to sign an agreement? Who makes routing decisions?

Request for Proposal/Request for Quotation

A formal RFP or RFQ is an effective way to both reduce transportation costs and gain the value that you need from your carriers. Ad Hoc Logistics can prepare your RFP/ RFQ, get it to the appropriate transportation providers, and even negotiate on your behalf.

Contact mitch@adhoclogistics.com for assistance.

Most SMEs (Small and Medium-Sized Enterprises) do not have an ECP (Export Compliance Program) or in-house expertise. If you are the CEO, COO, or CFO of one of these companies we advise assessing the risk of non-compliance and taking action. Fines and penalties for export violations can be as high as $1 million. In the meantime, here is a list from the Bureau of Industry and Security (BIS) website of things to look for in an export transaction. Make sure you are not doing business with the bad guys. A little due diligence up front saves a lot of trouble later on.

The customer or its address is similar to one of the parties found on the Commerce Department’s [BIS’] list of denied persons.

The customer or purchasing agent is reluctant to offer information about the end-use of the item.

The product’s capabilities do not fit the buyer’s line of business, such as an order for sophisticated computers for a small bakery.

The item ordered is incompatible with the technical level of the country to which it is being shipped, such as semiconductor manufacturing equipment being shipped to a country that has no electronics industry.

The customer is willing to pay cash for a very expensive item when the terms of sale would normally call for financing.

The customer is unfamiliar with the product’s performance characteristics but still wants the product.

The customer has little or no business background.

Routine installation, training, or maintenance services are declined by the customer.

Delivery dates are vague, or deliveries are planned for out of the way destinations.

A freight forwarding firm is listed as the product’s final destination.

The shipping route is abnormal for the product and destination.

Packaging is inconsistent with the stated method of shipment or destination.

When questioned, the buyer is evasive and especially unclear about whether the purchased product is for domestic use, for export, or for reexport.

For help contact mitch@adhoclogistics.com

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Industrial Safety & Rescue

Rob Wallace of UMass Amherst demonstrates how an auto descender works. #OSHASummerSummit

Mitch Kostoulakos, LCB Ad Hoc Logistics LLC, Int’l Logistics Consultant/Licensed Customs Broker

Since this is a safety demo where is the pad on the floor in case of a mishap?

https://www.linkedin.com/posts/adhoclogistics_logisticsmanagement-export-compliance-activity-7083429538281463808-UvV7?utm_source=share&utm_medium=member_desktop

John Monahan commented on this

Herb Sargent• We’re building great people with great lives — those people build GREAT projects.We’re building great people with great lives — those people build GREAT projects.

Next time you’re driving down the road and caught in a construction zone, give them a smile.

Mitch Kostoulakos, LCB Ad Hoc Logistics LLC, Int’l Logistics Consultant/Licensed Customs Broker

No one likes delays caused by construction. I always try to remember a couple of things: 1) Our aging infrastructure won’t fix itself and we need to repair as well as build new. 2) Construction jobs put people to work at good wages which get pumped back into the economy.

I have always advised clients that export compliance equals good risk management. Furthermore, compliance functions should be viewed as value adds rather than as a cost center. Whether or not a formal ECP (Export Compliance Program) is implemented, there are a number of best practices that are essential for any company involved in international trade.

Compliance is often a “back burner” project for several reasons including: Don’t know where to start, lack of C-level commitment, reluctance to allocate resources, too small to worry about compliance, no previous problems, or just plain inertia.

While the ROI for export compliance will vary for individual firms, we can identify an overall value proposition.

Risk Management– avoid the cost of fines and penalties which can reach $1 Million for criminal violations. Think of compliance as insurance.

Save Time/Save Money– export compliance means less re-work or follow up of requests for information from customers, government agencies, or forwarders.

Make Money/ Grow the Business- basic competence in exporting enables expansion to international markets. Compliance problems will cause customs delays and be an impediment to growth.

Enhance the Brand– similar to ISO certification and C-TPAT, an ECP demonstrates professionalism. Show customers and prospective customers that you know what you are doing.

I would be interested in hearing other value propositions for compliance. In the meantime, why not get started?

Contact mitch@adhoclogistics.com for help with export compliance.