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
Character Counts
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!
CBLE Results Posted!
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.
CBLE Anxiety
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.
Customs Business
What is “customs business”? Licensed Customs Brokers deal with customs business on a daily basis but their activities are not always clear to new clients. For example, classifying goods for others is definitely customs business.
Importers, if you have been relying on your suppliers for HTS classifications of your products check this September 2022 CBP ruling. Briefly, it states that suppliers are not qualified to provide HTS classifications unless they employ LCBs (Licensed Customs Brokers), even with a disclaimer that the information is advisory.
Classifying goods for others is “customs business” and must be carried out by a licensed customs broker. Pursuant to 19 U.S.C. § 1641(b)(1), “[n]o person may conduct customs business (other than solely on behalf of that person) unless that person holds a valid customs broker’s license . . . .”
https://rulings.cbp.gov/ruling/H290535
The ruling includes the following language which explains that classifying to the six digit level is not considered customs business:
We note, however, that CBP has consistently held that classifying goods to the six-digit level of the HTS is not customs business and does not require a customs broker’s license. This level of classification “does not constitute customs business because the six-digit HTS provision is insufficient for entry.”
Contact mitch@adhoclogistics.com for classification help.
Customs Broker Continuing Education
If you are a Licensed Customs Broker (LCB), it is a good idea to have a strategy in place to fulfill your continuing education requirement. Here is a reminder from the CBP website:
To maintain an active license, individually licensed brokers must earn 20 CE credits from qualifying educational activities that occur beginning January 1, 2025 through January 31, 2027. January 31, 2027 is the end of the current triennial period.
I have started gaining credits by registering and participating in Trade Outreach Webinars hosted by CBP. These are free of charge and there are a number of webinars to choose from each month. I must admit that some of the topics do not apply to my clients’ commodities. However, I am learning something from each webinar, which is the goal of continuing education, and avoiding a scramble toward the end of the triennial period.
Why not get started now? Here is the link for Trade Outreach Webinars:
https://www.cbp.gov/trade/stakeholder-engagement/webinars
What is a Customs Broker?
I have fielded quite a few questions about tariffs and Customs Brokers in the last few weeks. While importers are familiar with brokers, many others are not. Here is some info from the CBP website:
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.
Corporations, partnerships and associations must have a broker license to transact Customs business. Each of these businesses must have at least one individually licensed officer, partner or associate to qualify the company’s license. Failure to have a qualifying officer or member (of a partnership) for more than 120 days will result in the revocation of the broker license.
Countdown to Exam Day
If you are scheduled to sit for the CBLE (Customs Broker License Exam) on April 23rd your preparations have most likely included practice exams as well as a deep dive into the HTS tariff and customs regulations. Not to mention blood, sweat, and tears.
Let me suggest also reviewing the notifications on the CBP website so that you don’t have an unexpected complication on exam day. The notifications include details about Covid restrictions, reference materials allowed, and ID/Proof of Citizenship requirements. There are separate sections for remote and in-person test takers.
You will find the info under this link:
Look for the heading It’s Exam Day !
Best of luck on April 23rd!
Who’s Responsible?
Most roadblocks to implementing an ECP (Export Compliance Program) are self-imposed. The project stalls while management procrastinates. The process certainly must start with management commitment. As has been reported, CBP and BIS are ramping up enforcement activities. Potential clients admit that they have allowed compliance to fall through the cracks or, after some initial steps, moved it to the “back burner”. The reasons for this are usually other priorities, cost, insufficient staffing, or belief that the business is too small.
One of my first questions for the client is “Who is responsible for compliance in the organization?” If they rely on their Customs Broker or LSP (Logistics Service Provider) I advise that these providers are good resources but that the client, as IOR (Importer of Record) or EOR (Exporter of Record), is legally liable for any violations.
Sometimes compliance has been assigned to the shipping department or to an administrative staffer. While I can help with best practices and training, this is a poor arrangement. Shipment screening must be a front end process starting with order entry. Shippers are under pressure to get orders out the door. Administrative staffers have multiple responsibilities and may lack specific knowledge.
In house compliance professionals are often given responsibility without authority. Further, they may be at mid or lower management levels, or in the wrong chain of command. With or without a formal ECP, compliance professionals must have the authority to place holds on questionable exports without being overruled by sales, finance, or supply chain. Well written protocols for resolving issues and releasing holds require C-level or legal approval.
All of the above illustrates the importance of compliance independence. This may mean reporting to the CEO, COO, or legal department in order to remove pressure from other groups.
So once again; “Who’s responsible?”
Contact mitch@adhoclogistics.com for immediate assistance.
Exporting Due Diligence
Customs delays in other countries are problematic for exporters, requiring a lot of time and effort to resolve. One of my recent posts considered 3 common causes of customs delays: vague or incomplete descriptions, questionable valuations, and lack of IOR contact info on commercial invoices. These items are easily fixed. The real complexity in international trade is due to the many different regulations applying to destination countries.
Best practices in exporting include due diligence and research when shipping to a country for the first time. The Country Commercial Guides published by the International Trade Administration are an excellent no cost starting point. Here is the link:
https://www.trade.gov/country-commercial-guides
Contact mitch@adhoclogistics.com for assistance.