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COAC Recommends Elimination of District Permitting, New Broker Hiring Requirements

The Advisory Committee on Commercial Operations of Customs and Border Protection (COAC) recommends that CBP remove the district permitting requirement and make other changes to broker regulations, said a CBP document posted ahead of the May 22 COAC meeting (here). The COAC recommendations call for new national permit framework that would require customs brokerages to employ an "adequate number of licensed brokers to ensure responsible supervision and control." The potential changes for the permitting regime has sparked some concerns among brokers, even leading to the creation of a "Save a Broker" letter writing campaign (see 14042918).

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Specifically, the COAC Role of the Broker Working Group recommends:

  • that CBP enable brokers to operate through a single, national permit, eliminating the current district permitting requirement. "COAC understands that CBP must modernize its permitting framework for Customs brokers to align broker permitting with the challenges and opportunities of 21st century electronic entry processing through programs such as Automated Commercial Environment (ACE), Remote Location Filing (RLF), the Centers of Excellence and Expertise (CEE) and eBonds."
  • that CBP work with COAC to replace current broker management processes, "related to informed compliance publications and broker handbooks to ensure a modern, national broker management process is developed and implemented prior to CBP moving forward with the proposed change in the broker national permitting framework," it said.
  • "that the new national permit framework include requirements that Customs brokerage firms employ an adequate number of licensed brokers to ensure responsible supervision and control over their Customs business and that CBP work with the appropriate stakeholder groups to define these new supervision and control requirements and provide the COAC an opportunity to comment on any new framework before implementation," it said. "COAC understands the value the Customs broker license brings to CBP and the importing community."

The broker working group is also "considering making revised recommendations on importer bona fides," it said. CBP will continue its internal work on updating the regulations in Parts 111 and 141, it said. A regulatory worksheet was submitted to the CBP Office of Regulations & Rulings in May 2013 to begin the regulatory drafting process and technical drafting work on Part 111 will continue throughout 2014, it said.

Other documents include draft recommendations, and other documents on trade modernization, the global supply chain, trade enforcement and other topics. The draft agenda is (here).

Trade Enforcement and Revenue

  • Trade Enforcement and Revenue Collection Subcommittee CBP Status (here)
  • Trade Enforcement and Revenue Collection Subcommittee Trade Executive Summary (here)

Trade Modernization

  • Trade Modernization Subcommittee CBP Update (here)
  • Trade Modernization Subcommittee Trade Executive Summary (here)
  • CBP Report on Trade Modernization Subcommittee Work on 'Role of the Broker' (here)

Trusted Trader

  • Trusted Trader Subcommittee CBP Report (here)
  • Trusted Trader Subcommittee Trade Executive Summary (here)

Export

  • Export Subcommittee CBP Report (here)
  • Export Subcommittee Trade Executive Summary (here)

One Government at Border

  • One U.S. Government at the Border Subcommittee CBP Report (here)
  • One U.S. Government at the Border Subcommittee Trade Executive Summary (here)
  • One U.S. Government at the Border ACE-ITDS Government Report (here)

Global Supply Chain

  • Global Supply Chain Subcommittee Status (here)
  • Global Supply Chain CBP ACAS Report (here)
  • Global Supply Chain Trade Executive Summary (here)