If you are planning to take the customs brokers exam in April you should be well into your preparations by now. In a previous post I shared the prep strategies that worked for me. Here is the info again with the key steps highlighted. Best of luck but don’t rely on luck.
According to CBP Customs and Border Protection passing rates for the customs brokers exam average only 3-11% nationwide. The test is given twice per year in April and October. It consists of 80 multiple choice questions and a passing grade is 75%. The exam is open book which makes it seem easy. However, the books consist of the HTUS Harmonized Tariff of the United States and CFR 19 Code of Federal Regulations, totaling hundreds of pages. The difficulty is in being able to quickly access the right section for each question. It is a four hour exam so three minutes per question is not much time.
I took a prep course in Boston taught by Atty. Mary Wright. The class met two nights per week for 6 weeks prior to the exam. Mary explained the material very thoroughly from her background as a customs attorney and prior experience as an import specialist for CBP. We also reviewed previous exams in class. As good as this class was, I would not have been able to pass the exam without additional study. I estimate that I spent about 40-50 hours on weekends leading up to the exam.
I used 6 previous exams and a 3 step process. In step 1 I took each test for accuracy, ignoring the clock. In step 2 I took the tests again in the same order, while timing myself to make sure I could finish within 4 hours. I believe that step 3 was the key to my success. For this phase I circled all the questions I had missed in steps 1 and 2 and created a separate mini exam which I took several times until I answered all the questions correctly.
Schedule B codes have been updated for 2015. Best practices for exporters include checking to make sure Schedule B codes are up to date. Using obsolete or inaccurate codes can mean customs delays, onerous re-work and lengthy communications with customs agencies in destination countries, as well as possible fines and penalties. Take the time now to verify codes and update your parts lists.
For help contact mitch@52.91.45.227
|
||||||||||||||||||||||||||||||||||||||||
 |
||||||||||||||||||||||||||||||||||||||||
 |
||||||||||||||||||||||||||||||||||||||||
|
When the ECCN (Export Control Classification Number) comes up on export documents most shippers automatically enter EAR 99. For license questions NLR (No License Required) is often used as a default exception. While these may be the correct entries, it is a good business practice to check and confirm. Here is some info from a previous post.
As part of any Export Management Program, exporters need to make sure they are using correct commodity classifications and license exceptions. While freight forwarders can provide expertise in these areas the exporter bears primary responsibility for compliance. If you are automatically using NLR and EAR 99 you may be at risk. According to EAR part 732 “For items subject to EAR but not listed in CCL the proper classification is EAR 99. EAR 99 is a basket for items not specified under CCL and appears at the end of each Category on the CCL.”
If you need help contact mitch@52.91.45.227
Ad Hoc Logistics is currently helping a client resolve a conflict between Incoterms and Liner terms. In this transaction the Incoterm used is incompatible with the Liner term resulting in a dispute over payment of some fees. Following is some basic info from a previous post about Incoterms.
For help with Incoterms contact mitch@52.91.45.227
Incoterms Basics
Incoterms are rules used to facilitate global trade. Incoterms were created and are administered by the International Chamber of Commerce and are updated every 10 years. Incoterms 2010 published by ICC Services Publications, Paris FR is a very good reference. Some of the important points covered in the book are:
Incoterms 2010 includes several rules changes:
Attached chart is a quick guide to Incoterms 2010
Do you want to get a handle on export compliance in 2015? Implementing a formal Export Management Compliance Program can be quite intimidating and expensive, especially for small and medium sized companies. An EMCP requires a significant commitment of time on the part of management and usually involves hiring an outside consultant for the initial set up. There is no question that a written EMCP is a good investment for any company to make. An EMCP establishes clear accountability, written instructions, and reduces risk of non compliance. If the exporter has not experienced problems or incurred any fines it is easy to make an EMCP a “back burner” issue. If your company has not implemented an EMCP it is still good business practice to take some basic compliance steps. While these steps cannot take the place of a written EMCP they will help reduce risk of non compliance. To get started I suggest the following:
Contact mitch@52.91.45.227 for help.
In a previous post I discussed Red Flags to be aware of in export transactions. Here is more detail from the Bureau of Industry and Security about the Consolidated Screening List. The Department of Commerce lists that are included in the Consolidated Screening List are: Denied Persons List, Unverified List, and Entity List. For help with export compliance contact mitch@52.91.45.227
Prior to taking any further actions, users are to consult the requirements of the specific list on which the company, entity or person is identified by reviewing the webpage of the agency responsible for such list. The links below will connect you to the specific webpage where additional information about how to use each specific list is contained.
Here is a list from the Bureau of Industry and Security (BIS) website of things to look for in an export transaction. My next post will discuss “Lists of Parties of Concern” including “Denied Persons”. Make sure you are not doing business with the bad guys. A little due diligence up front saves a lot of trouble later on.
For help with export compliance contact mitch@52.91.45.227
This cohort was very diverse. In the beginning, they weren’t so sure about giving up their Friday nights and Saturdays. But as we proceeded, we heard time and again from these students how they wished they’d taken the course years ago!
I recently completed recertification of my CTL (Certified Transportation and Logistics) through AST&L (American Society of Transportation and Logistics). I believe that professional certifications are a valuable credential. Professionals prefer to do business with other professionals.