CBP Spells Out Part 111 Rewrite Goals, Seeks Broker Input on Local Permit Pilot
CBP posted a fact sheet spelling out the agency's efforts related to the planned rewrite of rewrite of 19 CFR Parts 111. CBP has said it will issue an advanced notice of proposed rulemaking on the rewrite. The fact sheet includes a list of challenges the agency hopes to address within the revision of the regulations.
Challenges hoped to be addressed include:
- Illegitimate claims to be an importer of record and the opaqueness of the relationship between importers and brokers;
- Identity theft/shell importers of record;
- Inefficiencies due to rigid permitting qualifications;
- Outdated definitions and factors that are no longer relevant to current operating practices;
- Burdensome requirements to report persons currently employed by the broker at that port;
- Increasing the professionalism of the broker community; and
- Customs business conducted outside the territory of the United States.
CBP has said it is looking into establishing a pilot program that would waive the requirement to maintain a place of business within the district where customs business is being conducted. The fact sheet includes series of questions on this idea.
CBP asks:
- If CBP were to pilot test a program that would change local permitting requirements, would your members support this concept?
- How would small brokerages or importers with a sole broker on staff be affected?
(See ITT's Online Archives 12062905 for summary of CBP's discussion of the pilot during its June 28 Webinar.).
CBP also seeks input on establishing continuing education and bona fide requirements for brokers.
On continuing education, CBP asks:
- Should licensed customs brokers have a continuing education requirement to ensure they are current on the latest customs issues, regulations, and technology changes?
- What types of courses would provide customs brokers the best value and greatest professional enhancement?
- Other than traditional coursework, what other types of activities would you consider “educational”?
- How would small brokerages or importers with a sole broker on staff be affected by a continuing education requirement?
A CBP Webinar on continuing education is scheduled for Aug. 23.
On bona fides, CBP asks:
- How can the customs broker enhance their relationships with their importers, particularly those importers who represent the greatest compliance risk for CBP (e.g., one-time importers and unknown importers)?
- How do you establish bona fides with your customers to ensure secure and compliant importations?
- How can CBP help you with the establishment of bona fides for your clients?
(See ITT's Online Archives 12062211 for summary of CBP June 21 Webinar on establishing bona fides.)
CBP will meet with local and regional broker associations and will hold webinars throughout the summer to ensure we receive meaningful insights that are unique to certain ports and border regions.
Contact: roleofthebroker@cbp.dhs.gov