All posts by mitch

Got Service?

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. Information is plentiful and, 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?

Thinking About Becoming a Customs Broker?

I often hear from people who are thinking about sitting for the CBLE (Customs Broker License Exam) or those who are simply curious about the profession. Here is some info from the CBP website and 19 CFR 111.1

Customs broker. 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.

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.

Here is a link for more info about eligibility and the application process:

https://www.cbp.gov/trade/programs-administration/customs-brokers/becoming-customs-broker

Heads Up- Tariff Updates

The HTS (Harmonized Tariff Schedule) and Schedule B have been updated for 2025. Both publications show multiple pages of code changes. Due diligence in checking your codes at least annually is a best practice for importers and exporters. Make sure that you are not using obsolete codes to avoid customs delays and possible penalties.

Here are the HTS and Schedule B links. You can check individual codes or review the change records.

https://hts.usitc.gov

https://www.census.gov/foreign-trade/schedules/b/index.html

As a reminder HTS codes can be used for AES filing, with some exceptions, per the following:

NOTICE TO EXPORTERS

For reporting electronic export information in the Automated Export System (AES), the statistical reporting numbers in the HTS (with their respective descriptions and units of quantity) for articles falling in chapters 1 through 97 may be used in place of those in the Schedule B, except as noted below.

Contact mitch@adhoclogistics.com for assistance.

Beware of Self-Blinding

The need for C-level leadership is a common topic among compliance professionals. Here is another example:

Screening export shipments has become routine for most companies involved in international trade. Export software packages can perform this task or it can be manual; using the Consolidated Screening List https://www.trade.gov/consolidated-screening-list or individual lists. No one wants to do business with the bad guys. However, the routine nature of export screening makes it likely that upper level management is not involved in the process.

SUPPLEMENT NO. 3 TO PART 732 – BIS’s “KNOW YOUR CUSTOMER” GUIDANCE AND RED FLAGS

(3) Do not self-blind. Do not cut off the flow of information that comes to your firm in the normal course of business. For example, do not instruct the sales force to tell potential customers to refrain from discussing the actual end-use, end-user, and ultimate country of destination for the product your firm is seeking to sell. Do not put on blinders that prevent the learning of relevant information. An affirmative policy of steps to avoid “bad” information would not insulate a company from liability, and it would usually be considered an aggravating factor in an enforcement proceeding.

For help with exports or developing an ECP (Export Compliance Program) contact mitch@adhoclogistics.com

2025 Customs Broker Fee

From the Federal Register

This document provides notice to customs brokers that the annual user fee that is assessed for each permit held by a customs broker, whether an individual, partnership, association, or corporation, is due no later than January 31, 2025. Pursuant to fee adjustments required by the Fixing America’s Surface Transportation Act (FAST Act) and the U.S. Customs and Border Protection (CBP) regulations, the customs broker permit user fee payable for calendar year 2025 will be $180.57.

Payment of the 2025 Customs Broker Permit User Fee is due no later than January 31, 2025.

Customs brokers may either submit the fee through the eCBP portal or submit the fee at the processing Center, as defined in 19 CFR 111.1, in accordance with the remittance procedures in 19 CFR 24.22(i). CBP encourages customs brokers to pay the annual customs broker permit user fee electronically via the eCBP portal, located at https://e.cbp.dhs.gov/​brokers/​#/​home. Customs brokers who are first time users of the eCBP portal must create a Login.gov account. Instructions and training resources, such as user and quick reference guides, for customs brokers on how to create a Login.gov account and how to use the eCBP portal can be found on CBP’s website at https://www.cbp.gov/​trade/​eCBP.

Appealing?

I just reviewed a draft of an applicant’s appeal of 2 questions on the October CBLE (Customs Broker License Exam). I admire the applicant’s diligence and tenacity but disagreed with their justifications for the appeal.

We are well within the 60 day period for first appeals, but let me suggest a different strategy. If you are considering an appeal you are most likely very close to a passing grade and hoping to gain a reversal on a small number of incorrect answers.

In fact it is very difficult to gain additional points upon appeal, and preparing a compelling argument is time consuming. I know many brokers who have passed the exam on a second attempt. So, since you came close to passing the exam on October 23rd, a better use of your time would be to begin preparing to pass the April exam instead of appealing your recent score.

If you choose to appeal here is some info from the CBP website: 

The applicant must submit a compelling argument why his or her answer is correct or why the appealed question has no possible correct answer.

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