19% Pass Customs Broker Exam

CBP has posted this information on their website:

The bi-annual Customs broker license exam (CBLE) was administered on April 21, 2021.  The electronic exam was held nationwide at over 120 testing locations and via remote proctor delivery. The exam results letters were emailed to the examinees on June 4, 2021. First appeals for the April 2021 exam are due to CBP no later than August 3, 2021.

The April 21, 2021 CBLE resulted in a 19% pass rate prior to appeal decisions. 

The October 8, 2020 CBLE resulted in a 37% pass rate prior to appeal decisions. 

Congratulations to those who passed the exam! Previous passing rates have rarely been higher than 10-15% so the test is obviously not easy. If you are planning to take the exam in October 2021 and would like some study tips I am happy to share what worked for me.

Contact mitch@52.91.45.227

Own It Exporters

Many of our posts focus on the basics of export compliance. Due diligence is required when filing EEIs, classification of Schedule B and ECCNs, and Country of Origin determination. An Export Compliance Program (ECP) is highly recommended as well as red flag screening, training, and audits. In spite of best efforts, mistakes will be made. In these cases a Voluntary Self-Disclosure is a smart move. Here is some info from the BIS (Bureau of Industry and Security) website:

Parties who believe they may have committed a violation of the EAR are encouraged to submit a Voluntary Self-Disclosure (VSD) to BIS. VSDs are an important indicator of a party’s desire to bring their export activities into compliance, and also may provide important information to BIS helping to identify foreign proliferation networks. Parties submitting VSDs may be eligible for significant reductions in administrative penalties, and those with well-implemented EMCPs may expect further significant reductions of administrative penalties. Procedures for submitting VSDs may be found in Section 764.5 of the EAR. The procedures detailed in Section 764.5 do not apply to VSDs involving violations of the antiboycott provisions of the EAR. Procedures for submitting VSDs for boycott violations are found in Section 764.8 of the EAR.

Contact mitch@52.91.45.227 for assistance in submitting VSDs.

MidYear HTS Revisions

The United States International Trade Commission has updated the Harmonized Tariff Schedule of the United States effective July 1, 2021. Midyear is a good time to review your harmonized codes. The change record for this revision contains 4 pages of newly established, modified, and discontinued codes.

Using obsolete codes can result in customs delays, inaccurate  duty assessments, or fines and penalties. Best practices include checking the tariff periodically. While you are at it are you sure EAR99 and NLR apply to your exports?

For assistance contact mitch@52.91.45.227

LinkedIn Comment- Logistics People

Scot Snyder• 1stUS Army Retired/Talent Sourcing/Veteran & Invisible Disabilities Advocate/Logistics Careers & Recruiting/Workforce Training

Is Logistics still a people business or is the digital marketplace technology replacing the need for skilled 3PL/Logistics Pros? Or will tribal knowledge still remain a powerful differentiator?

Mitch Kostoulakos, LCB Ad Hoc Logistics LLC, Licensed Customs Broker, International Logistics Consultant

In my opinion logistics providers must offer both high level technology and skilled people. Problem solving is a big part of logistics and clients want to follow up with trusted human contacts.

On the Borderline

The June edition of Logistics Management magazine includes a very informative article by John Schulz. Cross-Border Update illustrates the growth and complexities of trade among the three North American nations.

Along with information about USMCA and CTPAT, the author advises that in-house logistics teams must be properly trained on how to develop and maintain a classification matrix for commodities that are shipped across borders. This matrix should include Harmonized Tariff Schedule number, Schedule B number, Export Control Classification Number (ECCN), Export License Authorization, and Country of Origin, as well as any other pertinent customs data.

For help setting up your matrix contact mitch@52.91.45.227

On Your Mark

In a recent post we discussed some common reasons for customs delays. These included vague or incomplete commodity descriptions, questionable valuations, and lack of contact info for Importer of Record.

Country of Origin marking can also cause delays in clearance due to the specific regulations for imports into the US. Here is a guide produced by CBP (Customs and Border Protection) for your customs file.

https://www.cbp.gov/sites/default/files/assets/documents/2020-Jul/ICPMarking-of-COO-onUS-Imports.pdf

LinkedIn Comment- USPS

Dean Maciuba• Last Mile Experts

Not a Major Part of USPS Change Strategy

It is disappointing to see that the USPS has invested 6 years in a new vehicle search process with a flawed result, that does not embrace electric vehicles (EV’s) Clearly, it was not a major objective for the USPS to specify a major, future role for EV’s during the evaluative process. Most likely, the organization must have intentionally specified a limited role for EV’s during the process with potential suppliers.

Mitch Kostoulakos, LCB Ad Hoc Logistics LLC, Licensed Customs Broker, International Logistics Consultant

@Dean Maciuba thanks for a good post. Perhaps USPS could use EV charging stations as a revenue source by making them available to the public….

A Little Math

Tight capacity in the trucking industry illustrates the impact of density on freight rates. Here is an old school example from the archives:

Or you can use a density calculator!

Freight Forwarder Guidance Part 2

I thought about this recent post after meeting with a well established freight forwarder this week. They are focused right now on finding capacity for imports from Asia in order to serve their clients. The current supply chain disruptions illustrate the importance of freight forwarder relationships. Expertise in compliance and documentation is certainly important but first they need to be able to move the freight.

International Logistics Consulting; Licensed Customs Brokers