BIS (Bureau of Industry and Security) released an updated version of the Interactive CCL earlier this year. In my opinion the new version is much more user friendly than previous editions. It is easier to search by keywords and browse ECCN entries. Navigating and comparing the entries is still pretty time consuming, however.
Here is the link to the CCL:
https://www.bis.gov/regulations/ear/interactive-commerce-control-list?isExpanded=&category=&keyword=
Did you know? The dollar symbol, $, is used by quite a few countries around the globe, including the United States, Australia, New Zealand, Canada, and Hong Kong.
Currency designation is required information on Commercial Invoices. If your transaction is in US dollars indicate USD on the CI. The dollar sign alone is not sufficient and will most likely cause a delay in customs.
The uncertainty about tariffs makes validating HTS codes more important than ever.
Clients often say “we’ve used the same harmonized codes for years” and “our products are duty free“. As a Licensed Customs Broker and consultant this tells me that I need to do some checking on the client’s behalf. Using obsolete or invalid HTS (Harmonized Tariff Schedule) codes is a sign of an amateurish operation. It is likely that, for these clients, commercial invoice descriptions need updating. If they are also an exporter we should check ECCNs, License Exceptions, and Schedule B numbers as well.
The HTS has been revised 15 times so far in 2025. Here is the link to the revisions for your reference:
https://hts.usitc.gov/download/archive
Don’t assume that your codes are valid. A little due diligence helps avoid problems down the road. Contact mitch@adhoclogistics.com for assistance.
Tariff uncertainty is the biggest issue in international trade today and, undoubtedly, for the foreseeable future. It is not easy to determine which commodities are subject to specific tariffs. Here is a reminder that the first step is accurate classification of the goods. This is “customs business” and must be carried out by a licensed customs broker (unless classifying solely on your own behalf).
https://www.linkedin.com/posts/adhoclogistics_customs-business-what-is-customs-business-activity-7320068799938846720-9jjx?utm_source=share&utm_medium=member_desktop&rcm=ACoAAAGVD3UBu7RY4T4x68-aqSLyiBDvybv-4A0
The April 2025 Customs Broker License Exam and Answer Key have been posted on the CBP website
https://www.cbp.gov/document/publications/past-customs-broker-license-examinations-answer-keys
Congratulations once again to all who passed the April 2025 Customs Broker License Exam.
It may come as a surprise that it can take up to a year before your license is issued. In addition to a passing grade on the CBLE, eligibility to become a customs broker requires applicants to be a US citizen at least 21 years of age, not be a current Federal Government employee, and possess good moral character.
Character is determined by an extensive background investigation. From the CBP website:
“Each Broker license applicant must undergo a background investigation that includes a fingerprint analysis and review of character references, credit reports, and arrest records. Arrests and convictions do not necessarily preclude the issuance of a license. In partnership, association, or corporation applications, individuals identified as principals with controlling interest, officers, partners, or members will also undergo a background investigation.”
Licensed Customs Brokers, via their entry filings, are responsible for the assessment of revenue for the United States in the form of duties and taxes. They must also ensure that they, and their clients, comply with the laws and regulations in all transactions. So the background check is more than a mere formality. Be patient applicants!
The April 23, 2025 CBLE (Customs Broker License Exam) resulted in a 30% pass rate prior to appeal decisions. Previous pass rate information is listed below. The exam and answer key will be 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. Let me suggest, however, that a better strategy may be to take the exam again in October.
https://www.cbp.gov/trade/programs-administration/customs-brokers/how-appeal
Pass Rate Information
The April 23, 2025 CBLE resulted in a 30% pass rate prior to appeal decisions.
The October 23, 2024 CBLE resulted in a 24% pass rate prior to appeal decisions.
The May 1, 2024 CBLE resulted in a 13% pass rate prior to appeal decisions.
To all who sat for the April 23rd CBLE (Customs Broker License Exam) you may now have your weekends back. I know from personal experience that you are feeling both relief that the exam is over and anxiety about your results. Here is some info from the CBP website about what happens next:
CBLE Score Notification Letters and Appeal Due Dates
The bi-annual Customs Broker License Exam (CBLE) is administered on the fourth Wednesday of April and October. Exam Results Letters are emailed to examinees within two to three weeks from the date of the exam. First Appeals are due no later than 60 days from the date the Exam Results Letters were sent. Second Appeals are due no later than 60 days from the date the First Appeal Results Letters were sent.
Pass Rate Information
The October 23, 2024 CBLE resulted in a 24% pass rate prior to appeal decisions.
The May 1, 2024 CBLE resulted in a 13% pass rate prior to appeal decisions.
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.
I will write about the appeal process after the results of the April exam are posted.