Category Archives: Nuts & Bolts

Customs Broker License Exam Information

The customs broker license examination (CBLE) is scheduled for October 8, 2020, as previously announced in the Federal Register notice (84 FR 71440) published on December 27, 2019.  CBP will administer two examination sessions: one in the morning and one in the afternoon, the times will be announced soon.  CBP’s highest priority is the health and safety of all test-takers and CBP personnel.  Information will be added concerning the CBLE as soon as possible, please regularly check this website for updates regarding the October 8, 2020 examination.  If you have questions please email Headquarters Broker Management Branch at brokermanagement@cbp.dhs.gov.

Updated: July 28, 2020

Next Exam

The CBLE registration is scheduled to open early on August 3, 2020 and will close on September 8, 2020. 

LinkedIn Comment

David J. DiSanto • 1stDiSanto & Associates, Inc. Consulting in Supply Chain Analysis & Optimization2w • 2 weeks agoWould you buy airline stock now ?400,000 Jobs Lost at Airlines During Coronavirus Pandemicaviationpros.com • 2 min readAbout 400,000 airline workers have been fired, furloughed or told they may lose their jobs due to the coronavirus, according to Bloomberg calculations. The aviation industry has suffered more than most as the pandemic destroys ticket sales and strips..

Mitch Kostoulakos, LCB 

1m

Good question Dave. Would be a great investment if you pick the right airline.Like Mitch Kostoulakos, LCB’S comment

BIS Webinar

The Bureau of Industry and Security is a good resource for export compliance information and training.

Complying with U.S. Export Controls Virtual Seminar September 9-10, 2020

September 9-10, 2020 Complying with U.S. Export Controls

This two-day virtual program is led by BIS’s professional counseling staff and provides an in-depth examination of the Export Administration Regulations (EAR). The program will cover the information exporters need to know to comply with U.S. export control requirements on commercial goods. We will focus on what items and activities are subject to the EAR; how to determine your export control classification number (ECCN); steps to take to determine the export licensing requirements for your item; when you can export or reexport without applying for a license; export clearance procedures; and record keeping requirements.

A Little Due Diligence

As I have written in previous posts, it is a mistake to leave export compliance in the hands of your shipping department. Shippers are under time pressure to get shipments out the door and often do not have sufficient knowledge or training to avoid mistakes. In addition shippers rarely have the authority to stop shipments if they spot red flags and this can have big consequences. So don’t give shippers the responsibility for compliance without the authority.

Many exporters automatically classify their shipments as EAR99 and NLR without checking that these designations are accurate. A little due diligence goes a long way so here goes.

Exporters, do you know how to determine your ECCN (Export Control Classification Number)? While it is true that many exported commodities can be designated EAR 99 and NLR (No License Required), it is important to first check for an ECCN. The correct ECCN is necessary in order to determine if a license is required for your shipments.

There are three ways to determine ECCN: 1) self classify, 2) consult manufacturers of commodities, 3) request a classification by BIS.

The CCL (Commerce Control List) Index @ bis.gov is a good place to start.

https://lnkd.in/gi4iFCu

If you need help contact mitch@52.91.45.227

Test Yourself

In a recent post we discussed Country of Origin and “substantial transformation”. Here are a few questions from the April 2019 Customs Broker License exam. If you sit for the exam you have 4.5 hours to answer 80 questions, or a little more than 3 minutes per question, in an open book format. Questions 8 and 9 may seem obvious using the substantial transformation rule. Question # 11 will take a deeper dive into the regulations and this is what makes the exam difficult as it may consume valuable time. Test yourself and post your answers if you like.

8. Swedish iron ore is refined into steel near the town of Essen, Germany, and subsequently fashioned into automobile radiators in Bratislava, Slovakia, in 2018. What marking is required for the automobile radiators?

A. Product of EEC B. Made in SK C. Product of Germany D. Made in Slovakia E. Made in Czechoslovakia

9. Fish are caught by a Norwegian flagged vessel in international waters off the coast of Portugal. The fish are kept either whole or filleted on-board. The fillets are sent to England, where they are seasoned, battered, and pre-fried. What is the country of origin of the battered fillets?

A. Portugal B. England C. Norway D. Canada E. Spain

11. Mr. Smith contacts your brokerage from the Customs area at the local international airport. He has just flown in from the UK and is attempting to bring in new Scottish 100% wool sweaters to sell at his new store. CBP has advised him that although an appropriate country of origin label is found affixed to the sweaters, the fiber content label is not acceptable. Which of the following actions should the local CBP brokerage take? A. The sweaters should be released to Mr. Smith if he agrees to remove the content label because no labeling is needed due to the exemption of wool wearing apparel. B. The sweaters should be released to Mr. Smith because they fall under the Wool Products Labeling Act of 1939. C. The sweaters must be returned to the UK. D. The sweaters should be released to Mr. Smith, but he will have to label the sweaters at his own expense under Customs supervision. E. The sweaters should be released to Mr. Smith, but a marking duty equal to 10% of the price in the domestic retail market duty should be assessed against Mr. Smith.

A. The sweaters should be released to Mr. Smith if he agrees to remove the content label because no labeling is needed due to the exemption of wool wearing apparel. B. The sweaters should be released to Mr. Smith because they fall under the Wool Products Labeling Act of 1939. C. The sweaters must be returned to the UK. D. The sweaters should be released to Mr. Smith, but he will have to label the sweaters at his own expense under Customs supervision. E. The sweaters should be released to Mr. Smith, but a marking duty equal to 10% of the price in the domestic retail market duty should be assessed against Mr. Smith.

Comment on LinkedIn

Mitch Kostoulakos, LCB commented on thisDavid J. DiSanto • 1stDiSanto & Associates, Inc. Consulting in Supply Chain Analysis & Optimization2w •

The airline said it’s starting to see signs people are flying again. United expects passenger revenues to grow 50% to 100% between June and July, though that will still be down as much as 88% compared with last July, normally part of the busy summer travel season.

United Taps Frequent Flyer Program for $5 Billion Loan as Air Travel Remains Sluggish….United Airlines is using its frequent flyer program to borrow $5 billion as passenger travel, which ground to a near-halt during the COVID-19 pandemic, starts to pick up but remains far short of a typical summer travel season. The loan secured by its…

Mitch Kostoulakos, LCB   Licensed Customs Broker, International Logistics Consultant

EU is not an option for Americans right now

Measure Absolutely

The economic downturn we are experiencing will no doubt result in some consolidation in the Logistics Service Provider (LSP) industry. For clients who are planning to change providers this is a good time to establish service standards that are relevant to their operations. For example, on time service standards are basic and common to all LSPs .

Most logistics service providers present clients with monthly reports touting their on time delivery percentage. It is easy to become complacent when LSPs routinely report 97-99% on time service after taking exceptions for weather and other factors.

Why not challenge them to measure absolute performance failures instead of percentages? In a high volume operation even a small percentage can mean a lot of late shipments and unhappy customers. In a smaller operation with fewer customers every shipment is critical. If LSPs can track and report percentages they should be able to do the same for absolute numbers of shipments. FedEx has measured absolute performance for years.

Finally, if you are an LSP, remember that you have a client on both ends of the shipment, so service failures have twice the impact. Different metrics are like fresh eyes on an operation.

Need help? Contact mitch@52.91.45.227

Mitch’s LinkedIn Comments

Liz Ryan • 3rd+Founder and CEO, Human Workplace; Author, “Reinvention Roadmap”

“Fake fun” at work has nothing in common with real job satisfaction. “Fake fun” is insulting and annoying. One of the worst things HR people, CEOs or anyone else can do is to pretend that “fake fun” will make your workplace a great place to work.

I don’t need a foosball table or free beer on Friday nights – I need

RESPECT
FAIR PAY
CLEAR DIRECTION
THE RIGHT EQUIPMENT AND TOOLS
APPROPRIATE TRAINING FOR MY JOB
RESPECT FOR MY PERSONAL TIME
THE LATITUDE TO DO MY JOB
TO BE ABLE TO SHARE MY OPINION WITHOUT WORRYING THAT DOING SO WILL HURT ME
S

Mitch Kostoulakos, LCB   YouLicensed Customs Broker, International Logistics Consultant

Excellent Post Liz. HR departments spend a lot of time and money trying to “motivate” thru games, cheerleading, and lucite awards. I have taught performance management seminars featuring the points on your list. These are the true motivators.

What’s Your Agenda?

Zoom meetings are replacing face to face sales calls for LSP (Logistics Service Provider) representatives and I’m hearing a lot of frustration from former colleagues and clients. LSP reps are under pressure to conduct an aggressive number of zoom meetings or phone contacts per day. Indications are that this strategy will continue as it reduces costs and may increase sales productivity.

Clients are often working remotely and with reduced staffing so understandably want to avoid these calls. The discussion usually includes small talk, commiseration, service issues, and client complaints about rates or surcharges. Let me suggest an alternative approach that can be a big plus for small/medium shippers. Rather than avoid the calls why not look to set the agenda and add value while also reducing the number of routine calls? I guarantee that you will have your LSP representative’s attention.

A common mistake made by small and medium sized clients is failing to prepare before meeting with LSP representatives. Another mistake is focusing on price. A better strategy is to emphasize value in your discussions with providers. If you determine that they have the capabilities to provide quality services, then you can move the discussion to price. Consider: if simply asking for lower rates can result in transportation savings, how much better would the result be with a little preparation? Here are some suggestions from someone who has spent many years on the LSP side of the table.

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 providers. Because the industry is so competitive you will get a better deal if LSPs 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 providers. 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@52.91.45.227