At the NCBFAA Annual Conference in Summerlin, NV, one of the major points of discussion was the future of Customs broker licensing requirements in 19 CFR 111 as CBP moves forward with ACE and entry processing evolves.

The regulations today require that a company acting as a Customs broker have a corporate license holder to exercise reasonable care and control.  If that company is operating in multiple cities, each district requires there to be a licensed Customs broker to qualify the district permits.  If the company loses their local broker, they have a period of time to fill the position.  Recently I had a friend who had to relocate to Seattle for a period of time to qualify their local office until a hire could be made to meet the statutory requirement.19 CFR Cover

Under the current system of entry processing, ACS (the Automated Commercial System) has entries submitted at a port level for processing the release and summary.  But under ACE (the Automated Commercial Environment), release and summary functions will be distributed around the country, including in Customs’ Centers of Excellence and Expertise (CEE’s) and full Remote Location Filing (RLF).

The impact of this centralization and redistribution has turned an eye to the relevance, and potential necessity, of individually licensed brokers in every office in every district.  While CBP has not come out and said that there will be a change in the regulations, it is something the industry is surveying with a wary eye.

CBP and the brokerage community want to maintain the health and respect attached to a Customs broker license.  It is difficult to obtain; the pass rate on the twice-yearly test averages five percent or less and then a rigorous background check and interview process weeds out even more candidates.  Licenses are well earned by their recipients and any reduction in their importance by CBP or the trade cannot be allowed to happen.

The NCBFAA Educational Institute sent a message out to their mailing list.

Donna Mullins of Mullins International Solutions in Atlanta has started a “See a broker / Save a broker” campaign to insure the health and vitality of the licensed broker community.  Contact her if you’re interested for more on this topic.

Whether you believe in the need for licensed Customs brokers at a district level or that one Customs broker who is the corporate license holder should qualify to exercise supervision and control, this is an issue that the NCBFAA wants feedback on and has set up the email address for people to send in their comments.

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