Category Archives: Nuts & Bolts

CBLE Results

The October 2023 CBLE (Customs Broker License Exam) resulted in a 34% pass rate prior to appeal decisions. Previous pass rate information is listed below. The exam and answer key are posted on the CBP website.

Congratulations to all who passed! You are now eligible to go through the application process, background check, and fingerprinting to obtain your license. The process can be lengthy so be patient.

Many brokers have needed more than one try, so don’t be discouraged if you came up short. If you want to challenge any of the questions here is the link explaining how to appeal.

https://www.cbp.gov/trade/programs-administration/customs-brokers/how-appeal

Pass Rate Information

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. 

The October 26, 2022 CBLE resulted in a 11.1% pass rate prior to appeal decisions. 

Scot Snyder Government Logistics | Talent Mentoring | Troops2Logistics | Recruiting | US Army Veteran & Advocate |

That’s a high pass rate. I hope it’s the same or higher in April. Thanks for sharing Mitch Kostoulakos,

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

As Mike Smiszek pointed out the exam questions now have 4 answers to choose from vs 5 in previous exams. This means less time needed to consider answers. Also if forced to guess you have a 1 in 4 chance vs 1 in 5. May have been a contributing factor to the higher pass rate. 34% is still low compared to other licensing exams.…

Mike SmiszekView Senior Trade Compliance Advisor at Braumiller Consulting Group

Mitch Kostoulakos, LCB Thanks for sharing this pass rate data. Though we’ll never know for sure, I’ll bet the pass rate was boosted by the question format change. It will be interesting to follow the pass-rate trend over the next few years (if CBP sticks with the four-answer format).

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

Mike Smiszek Yes it will be interesting. I’m never sure if I should encourage others to take the exam and put in all that effort with such low pass rate,

Heads Up Customs Brokers-Annual Permit User Fee

The annual user fee for each national permit held by a customs broker, whether it may be an individual, partnership, association, or corporation, is due no later than February 9, 2024.

The customs broker permit user fee payable for calendar year 2024 will be $174.80. CBP is also announcing that customs brokers may pay the fee electronically via the electronic Customs and Border Protection (eCBP) portal.

https://www.federalregister.gov/documents/2023/11/27/2023-26050/customs-broker-permit-user-fee-payment-for-2024-and-announcement-of-ecbp-portal-payment-option

LinkedIn Comment- Infrastructure

Ken Davis • Regional Vice President of Sales at Omni Logistics

I don’t normally wade into to these issues but, this is important ! Everything you have in your home, business, manufacturing plant, eat and drink comes in on a truck. Those of us that drive everyday know, our roads are in need of repair, bridges need to be rebuilt, infrastructure needs a lot of work. We need safe places for our road drivers to layover and get fuel, eat and shower. We need safe bridges. We need better software at our airports to handle the flights. We need modern equipment at our ports to bring us into the 21st century! 

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

Thanks for a great post…a few points to consider:
1) Infrastructure does not get better with age and can’t fix itself.
2) Spending on infrastructure is an investment. It provides good paying jobs and wages will be spent in local economies. Recycle the dollars.
3) It can be done. Visit any EU country and compare the roads, airports, etc to the US. They are way ahead of us.

Let’s Go Chiefs

C- Level executives, perhaps you have been “looking the other way” when it comes to export compliance. If you are lucky there have been no consequences for this negligence. Why not start off 2024 with a little executive action and move your organization towards compliance?

While a complete Export Compliance Program is the ideal solution, you may not be ready to commit the resources needed at this time. However, there are some steps that can be implemented immediately at little cost.

Here are a few best practices to help you get started :

1) Review and confirm correct Harmonized Tariff and Schedule B codes and maintain master list as updates occur. Proper classification follows established protocols and is the starting place for compliance.

2) Check Export Administration Regulations (EAR) for correct ECCN and license exception codes. Are you automatically using EAR99 and NLR? https://www.bis.doc.gov/ can help.

3) Confirm Country of Origin for all imports. This info is needed for your Commercial Invoice and is not always obvious, so consider consulting a Licensed Customs Broker.

4) Check common “Red Flags” such as denied parties lists, entities lists, and unverified lists. Once again, https://www.bis.doc.gov/ provides details and training.

5) Review export documentation for possible improvements.

Make export compliance a front-end process, not a last minute shipping function. Remember, while Logistics Service Providers (LSPs) are valued partners, the exporter bears primary responsibility for compliance. Finally, if exporting under ITAR you need a responsible trained officer.

Contact mitch@adhoclogistics.com for immediate assistance.

LinkedIn Post- 3PLs

Here is a link to my post about managing 3PLs.

https://www.linkedin.com/advice/1/how-can-you-improve-your-transportation-2c?contributionUrn=urn%3Ali%3Acomment%3A%28articleSegment%3A%28urn%3Ali%3AlinkedInArticle%3A7105290743644127232%2C7105290745338609664%29%2C7123653756537196545%29&dashContributionUrn=urn%3Ali%3Afsd_comment%3A%287123653756537196545%2CarticleSegment%3A%28urn%3Ali%3AlinkedInArticle%3A7105290743644127232%2C7105290745338609664%29%29&articleSegmentUrn=urn%3Ali%3AarticleSegment%3A%28urn%3Ali%3AlinkedInArticle%3A7105290743644127232%2C7105290745338609664%29&trackingId=wiYkf9I1VLpetbU1oIMBIg%3D%3D&utm_source=share&utm_campaign=copy_contribution_link&utm_medium=member_desktop

Customs Purgatory

I often hear from frustrated importers or exporters about shipments “stuck” in customs. The shipments may include critical parts needed for an equipment or plant shutdown, expensive high tech components not generally carried in inventory, or medical instruments for hospitals. Delayed orders also mean delayed payments, which gets everyone’s attention.

In many cases the delay is compounded by simple communication issues. Importer of record (IOR) contact info is often lacking on the commercial invoice. Customs in the importing country will not contact the exporter if they have questions or concerns. If they are unable to contact the IOR the shipment will go into storage. Make sure you include recipient name, address, phone number, and e mail address on your CI.

The CI is the most critical document for customs purposes. The data used in customs entries comes directly from the commercial invoice for the transaction. All countries have different, and sometimes obscure, customs regulations. It is true, however, that most delays are caused by a few commercial invoice errors or omissions.

Commodity descriptions should answer the questions: What is it? What is it made of? What is it used for? Use plain language which can be understood by anyone. Avoid trade names, brand names, or part numbers in the description. These can be added below the description or to the packing list if needed. If using a harmonized code it is best to enter only the first 6 digits, which are universal. All countries apply their own last 4 or more digits.

Contact mitch@adhoclogistics.com for immediate assistance.

Value for customs may appear to be too low for the commodity being shipped. The customs agencies in the destination country need to make sure that duty rates are accurate and will hold up the shipment if in doubt. Make sure that your commercial invoice reflects the correct transaction value.

Logistics and Finance

While logistics managers excel in orchestrating the flow of goods from Point A to Point B, they typically tread on less certain ground when it comes to financial matters. Logistics managers with operations backgrounds and responsibilities typically leave finance to the accountants. But this gap in financial acumen can be a hindrance in the ever-evolving world of supply chain management. Logistics managers with at least a basic understanding of the financial aspects of the supply chain will be better positioned to improve their business operations.

Read the full post

World Bank LPI 2023

The World Bank has published their Logistics Performance Index for the first time since 2018.

The LPI ranks countries on critical dimensions of trade including customs performance, infrastructure quality, and timeliness of shipments. The data used in the rankings are derived from a survey of logistics professionals answering questions about foreign countries with which they trade. Respondents are asked to identify their line of business (freight forwarder, transport operator, export/import trader, customs broker), typical freight mode utilized, and country in which they are working.

The index benchmarks six areas of performance and gives nations a score of 1-5 for each category. The categories are: 1) Efficiency of customs clearance process; measuring speed, simplicity, and predictability of formalities 2) Quality of trade related infrastructure; focusing on ports, railroads, and information technology 3) Ease of arranging competitive pricing for shipments; ability to compare rates and services on-line  4) Competence and quality of logistics services; in-country customs brokers, transport operators, and freight forwarders  5) Ability to track and trace shipments; transparency and availability of real time information and 6) Timeliness of shipments in reaching destination within scheduled time of arrival; Hardly Ever, Rarely, Sometimes, Often, Nearly Always.

The Global Rankings show the US at 17th (tied with Republic of Korea), down from 14th in 2018.

See the rankings here: https://lpi.worldbank.org/international/global

Click here to see the methodology used in the Global Rankings: https://lpi.worldbank.org/sites/default/files/2023-04/Methodology_LPI_survey.pdf

Let’s break down the US performance in 2023 vs 2018 by category:

LPI Score; 3.8 down from 3.89

Efficiency of Customs; 3.7 down from 3.78

Infrastructure; 3.9 down from 4.05

Ease of Arranging Intl Shipments; 3.4 down from 3.51

Logistics Competence; 3.9 up from 3.87

Tracking and Tracing; 4.2 up from 4.09

Timeliness of shipments: 3.8 down from 4.08

While most of the scores have dropped slightly, the US’ overall ranking has dropped steadily. Here are the LPI average US rankings for previous years.

2023 tied for 17th.

2018 14th

2016 11th

2014 9th

2012 9th

Readers have commented that the size and complexity of the US economy makes comparisons with smaller countries difficult. This is a fair point. However, there is no question that the US has room for improvement in all six LPI dimensions.

Here are the top ten countries by LPI score for 2023:

Singapore   
Finland 
Denmark 
Germany 
Netherlands 
Switzerland 
Austria 
Belgium 
Canada 
Hong Kong SAR, China 

The full LPI 2023 Report includes more detail and suggestions for policy makers. Read the report here: https://lpi.worldbank.org/sites/default/files/2023-04/LPI_2023_report.pdf

  • For the bottom performers, the most important improvements are in customs clearance and infrastructure.
  • Mid-level logistics performers are showing progress with more countries clustered at an average score of 3 to 4.
  • Logistics services are showing resilience. Even with Covid induced disruptions overall scores in 2023 are broadly the same as in 2018.

The report identifies four performance groups:

  • Logistics Friendly- Top performing countries, most of which are high income (25)
  • Consistent Performers- Countries performing better than most in their income group (25)
  • Partial Performers- Indicates logistics constraints often seen in low and middle-income countries (46)
  • Poor Logistics Performers- these are the least developed nations (43)

While comparisons among nations with diverse economies and levels of development will always be difficult, the LPI can be used by individual countries to identify opportunities to improve.