Role of the Broker with CEEs to be Largely the Same, Though CBP Communication will be Vital, Says COAC

CBP posted items agreed upon during the Dec. 4 meeting of the Advisory Committee for Commercial Operations (COAC), including a set of recommendations from the COAC Subcommittees on the Role of the Broker and Trade Facilitation regarding the increased reliance on Centers for Excellence and Expertise (CEEs).

No Drastic Change Expected

The subcommittees believe the relationship between the broker, importer and CBP will largely remain the same, though, the point of contact at CBP will change. With this change of procedure, the appropriate party will contact the CEE instead of a local port or other CBP contact, they said. Good communication between the CEE and brokers and importers is crucial to the success of the CEE’s.This includes clear communication recognizing which importers are in an assigned CEE. Brokers have established processes to prepare and file entry summary documents. CEEs requesting documentation from importers should be careful not to add additional cost to the entry process.

The COAC recommends:

• To gather commodity information for each CEE, CBP should reach out to brokers and importers.
• To learn industry practices, CBP will need to work with importers in that industry and/or their broker.
• CBP needs to educate brokers, importers and other involved parties on the 5 W’s of the CEE’s (who, what, when, where, why)
  • a)When to contact which CEE about entry issues, trade program issues, etc.
  • b)What situations will the broker and or the importer be contacted by the CEE
  • c)Why certain documents are filed in the CEE and others not. (including entry summaries/statements)
  • d)Where each of the CEE’s are located, where/how they can be reached, and the commodities they handle.
  • e)Who will be responsible, CEE/Broker/Importer, to insure that issues do not get lost and are timely resolved.
• The CEE’s should meet regularly with importers and brokers to discuss evolving roles and responsibilities.
• The Customs Brokerage community can help CBP reach small and medium enterprises (SMEs) through the Centers without unnecessarily draining resources. Specifically, CBP should implement policies that:
  • a)Allow Brokers to act as a filter, leveraging their experience and expertise to help SME’s route their inquiries appropriately insuring the Centers are contacted when the expertise of their highly skilled staff would be most beneficial to both CBP and the trade.
  • b)Leverage the Customs Brokerage community as a bi-directional education partner that can share the unique challenges and knowledge of their SME importer clients with Center staff and bring information back from the Centers to SME’s through the multiple channels available to them.
  • c)Reach out to SME importers by leveraging the Customs Brokerage community’s membership in industry and regional trade associations as an additional resource for bi-directional education. Most brokers are members of trade associations that can reach more SME importers in a single information or education session.
• Additional actions that should be considered include:
  • a)Creation of a CEE Work Group to focus on
    • i)Efficient processes to satisfy developing changes resulting from creation of the CEE’s
    • ii)Detailed recommendations on CEE processing that benefits CBP and the trade
    • iii)Working with Participating Government Agencies
  • b)Collect and where appropriate incorporate trade suggestions into the CEE Guidelines
  • c)Create and post to the CBP website a CEE Question and Answer document

(CBP has started increased outreach efforts regard the role of brokers within the CEEs. See ITT's Online Archives 12120725 for recent FAQs that discuss the role of the broker with the CEEs.)