Customs Broker Permit User Fee as payment is due no later than February 24, 2023. The fee is $163.71 for each permit held.
Nice to pay for just one permit this year.
Hire a Geek
Nerd: “socially awkward” and “an intelligent but single-minded person obsessed with a nonsocial hobby or pursuit” Geek: “a digital-technology expert or enthusiast” and “a person who has excessive enthusiasm for and some expertise about a specialized subject or activity”. Compliance folks sometimes refer to themselves as Geeks.
Demand for compliance professionals has never been higher, as LinkedIn users can readily see. Companies of all sizes and in all industries realize that being in compliance means fewer supply chain disruptions. At the very least compliance is good risk management. Think of it as insurance.
Compliance is about attention to detail, consistency, process, and oversight. I guarantee that your compliance folks are not trying to practice “sales prevention”. The goal is to complete transactions the right way, avoid customs or logistics delays and reduce exposure to fines and penalties. However, there is no doubt that complying with all of the agencies involved in international trade generates a lot of red tape and can be frustrating.
Compliance managers must have the authority to stop shipments when red flags appear. In order to ensure independence compliance folks should not be in the supply chain, finance, or marketing chain of command. Better reporting relationships would be with the legal department, CEO, or COO.
Consider just a few of the details that can make or break a smooth transaction:
Harmonized Codes to the full 10 digits including heading and sub heading. It is very easy to transpose digits.
Schedule B Codes, ditto
ECCN , Alpha numeric, number, letter, followed by 3 numbers. Example 4A994. Then followed by sub paragraph level and don’t forget the dot between the last number and the sub para.
License Exceptions are designated by 3 letter codes and must be compatible with the ECCN listed.
COO, Country of Origin markings and proper codes on documents and AES filings. Best not to guess here. Have you ever entered CH for China?
Valuation must be determined accurately and is best covered in a separate post which I have done on 05/09/2019.
These tactical elements are just some of the basics. We could also mention commodity descriptions, red flag screening, and plenty of other details. Trade policy is more strategic, encompassing trade agreements, incoterms, and dealing with enforcement agencies. There is a lot at stake so, hats off to the compliance teams.
For assistance contact mitch@52.91.45.227
LinkedIn Comment- Duties/Tariffs
Mitch Kostoulakos, Ad Hoc Logistics LLC, Licensed Customs Broker, International Logistics Consultant
Agree. Importers and consumers pay the duties or tariffs. They are simply a type of tax.
LinkedIn Comment- Gaining New Customers
Good post Mike. I agree completely. It is also a reminder to focus on existing accounts. It is much easier to keep a customer than gain a new one.
Checked your EEI lately?
Electronic Export Information (EEI) filing has become routine for exporters and it is easy to “file it and forget it” once the submission has gone through.
Auditing EEI ((also referred to as AES) filings is a good business practice. If you are a self filer is anyone checking the accuracy of your submissions? Does your freight forwarder have an audit procedure in place if they are filing for you? Here is the risk:
§ 30.71 False or fraudulent reporting on or misuse of the Automated Export System.
(1) Failure to file; submission of false or misleading information. Any person, including USPPIs, authorized agents or carriers, who knowingly fails to file or knowingly submits, directly or indirectly, to the U.S. Government, false or misleading export information through the AES, shall be subject to a fine not to exceed $10,000 or imprisonment for not more than five years, or both, for each violation.
Are you aware of this potential filing error?
A common misconception is that EEI and Commercial Invoice value should match. However, inland freight and insurance charges must be accounted for in the EEI filing whether or not they are on the commercial invoice.
For audits of your EEI filings contact mitch@52.91.45.227
Trade Like a Pro
Clients often say “we’ve used the same harmonized codes for years” and “our commodities 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 codes is a sign of an amateurish operation. It is likely that, for these clients, commercial invoice descriptions also need updating. If they are an exporter we should check ECCNs, License Exceptions, Country of Origin, and Schedule B numbers as well.
The Harmonized Tariff Schedule code is a 10-digit import classification system for commodities imported into the United States. HTS codes or numbers are administered by the U.S. International Trade Commission (ITC). The first 6 digits, sometimes referred to as HS codes, are standard for more than 200 countries. The last 4 digits are specific to the United States. Schedeule B numbers are used for export and are often, but not always, identical to HTS codes. They are administered by the U.S. Census Bureau.
Customs brokers use the HTS, along with CBP regulations, in their day to day business. Importers and traders may also make use of the HTS in determining duty rates. Checking the validity of harmonized codes at least semi-annually is a good business practice. What may be surprising is the frequency of revisions to the HTS.
The tariff archives show that the 2022 HTS was revised 12 times. Don’t assume that your codes are valid. A little due diligence helps avoid problems down the road. Contact mitch@52.91.45.227 for a review of your HTS codes.
LinkedIn Comment- Customer Service
How I Passed the CBLE
If you are planning to sit for the April 2023 CBLE (Customs Broker License Exam) it is best to start preparing now. I have had requests for study tips so am happy to oblige. The CBLE is difficult, with passing rates sometimes as low as 10%.
Recognizing that there are many different learning styles, here is what worked for me:
I took a prep course but, as good as it was, additional study was essential. I estimate that I spent about 50-60 hours on weekends leading up to the exam.
I downloaded 4-5 previous exams (320-400 total questions) from the CBP website and used 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. In Step 3 I circled all the questions I had missed in Steps 1 and 2 and created a separate “final” exam which I took several times until I answered all the questions correctly.
Good luck but don’t rely on luck.
CBLE Announcement
It’s not too early to begin preparing for the April 2023 CBLE (Customs Broker License Exam). Here is the announcement posted on the CBP website:
The next CBLE will take place on Wednesday, April 26, 2023. Registration will open on February 24, 2023 and close on March 24, 2023 late registration will not be accommodated.
The CBLE is administered on the fourth Wednesday of April and October (unless there is an insurmountable scheduling conflict or holiday).
An in-person CBLE exam option will be available for the April 2023 exam. A remotely proctored exam may be offered to a limited number of registrants.
NOTICE: Given the evolving COVID-19 situation examinees are responsible for checking the PDRI/PSI COVID-19 page (https://www.psionline.com/important-notice-update-concerning-covid-19-c…) regularly to find out if there is a vaccine or mask mandate at the registered testing site. It is THE EXAMINEE’S responsibility to stay up to date. CBP will NOT provide refunds for those who are not able to test as a result of being uninformed or noncompliant about the COVID-19 policy. CBP and PDRI/PSI recommend that the examinee checks the website regularly leading up to the exam, including the night before the CBLE.
I have had inquiries about study tips and will include some in a future post.
Contact mitch@52.91.45.227
The Matrix
No, I’m not referring to the sci-fi film. As noted in recent posts, HTS and Schedule B codes have been updated for 2023 and both tariffs will post changes throughout the year. Reviewing your codes at least semi-annually is a good business practice. However, in small/medium companies with minimal staffing this can easily be overlooked. When working with new clients checking codes is my first step in helping them achieve compliance with import and export regulations.
Why not take it one step further and develop a parts matrix listing descriptions, HTS codes, Schedule B codes, ECCN, License info, Country of Origin, and any other relevant import/export data? Your matrix will enable you to document new parts additions and changes as they occur. All departments involved in trade will be working with the same information so errors and omissions will be reduced.
Contact mitch@52.91.45.227 for help with your matrix.