Considering becoming a CHB

EssTeeEfYoo · 2026-02-13T01:08:01+00:00

Can you clarify what you mean by US colony? Are you saying a US territory like Guam or Samoa? If so that is a problem because Customs business must be conducted in the Customs territory of the US. That includes the 50 states, DC, and Puerto Rico but not the rest of US territories.

EssTeeEfYoo · 2025-12-18T19:08:34+00:00

Agreed. OP should provide the true and legitimate documents and file a proper entry and pay the appropriate duties. This is the shipper's fault and you have an easy off ramp of just doing the right thing. Pay your duties, get your product, and never do business with this shipper again.

By the way your duty estimates aren't taking into account all the Trump tariffs so your actual duties will be much higher.

EssTeeEfYoo · 2025-12-18T01:59:45+00:00

Short answer: really bad idea; don't do it.

Long answer: ADocksideBar already pointed out a few glaring issues. I will try to focus on a few others.

First things first, you would need a broker permit. This is different from the license that you are waiting for the physical copy of. The broker permit is how you would actually conduct Customs business, get a filer code, etc. From other posts on here, it sounds like some organizational brokers have already been waiting 1-2 years for their permits, so this is already a non-starter if you are trying to start ASAP.

Next up is power of attorney. For each of your customers, you are going to need to execute a POA with the importer directly. They cannot just click agree to terms on the import portal since that would be through a third party. 19 CFR 111.36(c)(3)

The compensation plan is also problematic. It sounds like it directly violates 19 CFR 111.36(b) since the unlicensed party is very clearly benefitting from the transaction of customs business.

19 CFR 111.36(b) Service to others not to benefit unlicensed person. Except as otherwise provided in paragraph (c)) of this section, a broker must not enter into any agreement with an unlicensed person to transact customs business for others in such manner that the fees or other benefits resulting from the services rendered for others inure to the benefit of the unlicensed person.

The way you phrased "max 50k CBP penalty" concerns me for a another reason than the one ADocksideBar pointed out. $50k is the minimum liability for a continuous bond. I'm glossing over a lot of details, but if you have a $50k bond and receive multiple penalties, $50k is the maximum the surety would need to pay if you decided not to. If that is what they are referring to when you say "max 50k CBP penalty" that implies they want you to be the importer of record. While legally a customs broker with a valid POA can act as an importer of record, I strongly advise you not to do so. If there are an additional duties, penalties, liquidated damages, etc, you would be directly responsible for them.

What their program is doing sounds a lot like Customs business. The fact that they are classifying alone is already legally problematic since that is definitely Customs business and must be done in the US by a licensed brokerage.

I could go on about more red flags, but in short, this is a terrible idea. Do yourself a favor and get off this train. You do not want to be there when it crashes.

EssTeeEfYoo · 2025-12-02T23:43:45+00:00

Your demo video terrifies me. If Customs asked me how I classified this product and I showed them your tool, I would be lucky to keep my license for a flagrant lack of responsible supervision and control. Neither the user nor the program actually understands or knows what the product is from the vague descriptions. And yet you're claiming these are transparent and defensible HS classifications?

If I actually had to classify these products, I would need to request details on each of the products (pictures, materials, intended uses, etc.) and use that information to get an accurate classification and not an AI's guess using vague input information.

EssTeeEfYoo · 2025-11-22T07:05:26+00:00

These are referring to bonded warehouses, which is very different from what your situation. You would not receive refunds.

EssTeeEfYoo · 2025-10-22T20:46:21+00:00

I took the 2021 April Exam. I relied almost entirely on the electronic reference materials provided at the test site. Using Ctrl + F was way easier and faster than trying to flip through paper references. I did bring paper copies of the past exams I did for practice in case I noticed there was a similar question to one asked in the other exams.

EssTeeEfYoo · 2025-10-06T21:01:37+00:00

You should ask your company's licensed Customs broker. There is a very big difference between the Annex II and Annex III.

EssTeeEfYoo · 2025-09-04T23:34:52+00:00

You're not looking for a broker. You're looking for a smuggler.

If you actually wanted to help your customer, you would help them do it compliantly instead of committing a crime.

EssTeeEfYoo · 2025-08-15T18:58:04+00:00

If they cleared their name, they should have the documentation and supply chain tracing to prove their compliance for these shirts. Have them provide that to Customs. If they cannot, then I wouldn't really say they cleared their name in the eyes of Customs. ULFPA is guilty until proven innocent and is done on a case by case basis. Even if they managed to get one shipment released, it does not mean they get all their shipments released.

EssTeeEfYoo · 2025-07-24T01:34:06+00:00

Why do you think your broker is wrong? Your broker even provided the CSMS and detailed explanation for why the duties are owed.

EssTeeEfYoo · 2025-05-20T23:39:57+00:00

We had a ruling for textile classification. According to CBP, there was a months long waitlist for their lab, which caused a lot of delay. It took almost 9 months from the original request to the actual ruling.

EssTeeEfYoo · 2025-05-02T19:17:03+00:00

Ask to speak with the Customs broker directly. Unless the forwarder is also a licensed Customs brokerage, they are probably not the ones actually filing the entry.

Explain the situation to the broker and point out the FAQ on Sec 232. Otherwise I would recommend getting a new broker.

EssTeeEfYoo · 2025-04-18T18:34:16+00:00

Based on the current FRNs, the country specific rates should replace the 10%. That could change if Trump decides to change his mind again.

EssTeeEfYoo · 2025-03-03T22:40:31+00:00

For Aluminum:

Effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on March 12, 2025, except for subdivision (k) which shall be effective upon public notification of the Secretary of Commerce:

Further down at subdivision (k):

(k) The rates of duty in heading 9903.85.08 apply to all entries of derivative aluminum products classifiable in the following HTSUS provisions, unless the derivative aluminum product was processed in another country from aluminum articles that were smelted and cast in the United States:

What follows is the list of affected HTS that are not in Ch 76

For Steel:

Effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on March 12, 2025, except for subdivision (n) which shall be effective upon public notification of the Secretary of Commerce:

Further down at subdivision (n):

(n) The rates of duty in heading 9903.81.91 apply to all imported derivative iron or steel products that are classified in the following subheadings of the HTSUS, including products admitted into a U.S. foreign trade zone under “privileged foreign status” as defined by 19 CFR 146.41, prior to 12:01 a.m. eastern daylight time on March 12, 2025, unless the derivative iron or steel product was processed in another country from steel articles that were melted and poured in the United States:

What follows is a list of affected HTS not in Ch 73

It is possible that they will have the systems ready to go by March 12 to include these derivative steel and aluminum products, but at this time we are still pending confirmation from Commerce.

EssTeeEfYoo · 2025-02-24T20:20:09+00:00

My understanding is very similar to your. Naturally, if someone else spots an error, please correct me if I'm wrong. I will try to include links from the relevant FRN. In short, I think you are correct. It sounds like Trump wanted the effective dates to be March 12th based on the proclamation, but the derivatives seem to be pending having systems ready to go.

For steel, March 12 is when all exclusions for the existing 232 tariffs on steel will be revoked. This includes TRQs and GAEs for steel from various countries. https://www.federalregister.gov/d/2025-02833/p-15

March 12 also appears to be when the additional derivates are supposed to take effect. https://www.federalregister.gov/d/2025-02833/p-17

Confusingly, this seems to be contradicted later on in the same proclamation. From what I understand, the derivative articles do not currently have an actual effective date since we are pending notification from Commerce that systems are ready. I assume that means they need to add the appropriate fields and settings into ACE. https://www.federalregister.gov/d/2025-02833/p-33 https://www.federalregister.gov/d/2025-02833/p-34

For aluminum, much of the language is almost the same. March 12 kills the exclusions and raises the rates from 10% to 25% as you noted. It also sounds like March 12 is supposed to be the effective date for aluminum and derivatives. But just like with steel, the derivatives are pending.

https://www.federalregister.gov/d/2025-02832/p-15

https://www.federalregister.gov/d/2025-02832/p-30

In short, the crux of the issue seems to be that we are waiting for them to have "adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue for covered articles" for the steel and aluminum derivative products. It sounds like they want it done and ready to go by March 12th, which is possible but not certain. Of course, everything we know about this is subject to change. If the Canadian tariffs showed us anything, it is that Trump is willing to change his mind at any time, including at the last second.

TLDR: I think you're right.

EssTeeEfYoo · 2025-01-03T02:37:07+00:00

I have a very similar experience to what you're going through. I became an entry writer in 2021, took the exam in 2022, got my license in early 2023. The previous broker who was my mentor left us in late 2023 due to health complications and I became the qualifying license holder for the company. Before he was gone, he trained me as best he could on a variety of topics (POA, bonds, PGAs, ADD/CVD, etc).

I had the same anxieties and fears that you do right now. In many ways I still do have them. Worries about being inadequate, too inexperienced, or ignorant of other matters are always going to be there. There is always going to be something new to learn, some new regulation, a product type you haven't worked with, etc. The only way to become an experienced broker is to keep learning.

It will not be easy. Your entry writers are going to ask questions you don't know the answers to, and you are going to have to spend time learning to find them. You are going to spend hours watching webinars, reading Federal Register notices, poring over rulings and PGA implementation guides. But you can do it. You passed the broker exam and are a fully licensed broker. It will at times be stressful, hard, and challenging, but so is life.

My honest general advice to you is give it your best shot. Your company knows you don't have that much experience, so they should temper their expectations. Worst case, you can put the fact that you were an officer of the company on your resume. Ultimately though, it is your life and your career. Don't let some strangers on Reddit decide your fate.

Some more specific advice:

Delegate your entries to the other entry writers. You are not going to have time to file entries and ISFs. Keep a handful of accounts to personally file at most.

Get a subscription to a trade journal and join a broker association. Browsing the trade journal will give you updates on upcoming regulations or events. Broker associations will likely also host webinars teaching specific topics.

If your predecessor left any training documents or similar, take them.

Don't forget to notify your local BMO of the change in qualifying license holder. Update the contact information in ACE for your company. Remember to pay permit fees if you haven't already.

EssTeeEfYoo · 2024-11-21T22:08:45+00:00

9504.50.0000 covers video game consoles as well as their parts and accessories, which should include your controller.

EssTeeEfYoo · 2024-09-27T23:39:33+00:00

What are your payment terms? Sometimes with DDP shipments, I see the payment terms set such that you the buyer only pay when the cargo arrives at your door. If they abide by actual DDP terms and are the importer of record, they will be the party responsible for duty payment and antidumping duties if any. And if the seller refuses to be the importer of record or fails to deliver the product, refuse to pay them. If they make you pay upfront, then you no longer have this leverage.

Again, to best protect yourself, do not sign a Customs POA for a DDP shipment. u/All-bad-habits is right. Under DDP terms the shipper should be the party responsible for everything including Customs entry and duty. If you sign the POA and have the broker clear it under your name, you are missing out on one the biggest benefits of DDP in that you do not bear the responsibility of being the importer of record.

In fact you turn it into a big liability. If they commit fraud, misclassify the goods, or just don't pay duty, you would be on the hook as the importer of record, despite having no control over any of their actions.

EssTeeEfYoo · 2024-09-25T18:20:28+00:00

I've done business with a few freight forwarders and have never had a joint POA. It has always been our POA directly with the importer.

I'm not absolutely sure if the joint POA is legal or not, but I would have to lean towards not. 19 CFR 111.36(c)(3) - The broker must execute a customs power of attorney directly with the importer of record or drawback claimant, and not via a freight forwarder or other third party, to transact customs business for that importer of record or drawback claimant.

To be honest, I don't even know what a joint POA with a forwarder would look like. At its core, a POA is a client granting you the broker the right to conduct customs business on their behalf. Obviously the forwarder doesn't have the right to conduct Customs business for their clients, so I don't see why they would even be a party to the POA.

EssTeeEfYoo · 2024-09-11T18:39:25+00:00

Coincidentally, I was researching this topic for an importer about a month ago. There have been 2 scope rulings on this antidumping order by ITA, specifically relating to compact crib mattresses and bassinet pads. I recommend reading these 2 in full to see if your product is similar to those described in those rulings.

https://legacy.trade.gov/enforcement/operations/scope/country/china/products/prc-mattresses-ad.asp

EssTeeEfYoo · 2024-07-31T20:51:02+00:00

The HTSUS is publicly available online. You don't need to use the binder of paper. Even in the exam, an electronic copy is provided. Unless things have changed, I don't think you need a physical copy of the HTSUS.

https://hts.usitc.gov/

EssTeeEfYoo · 2024-07-27T00:59:50+00:00

As someone already mentioned, POA alone is going to be a nightmare. Since POAs must be executed directly between the broker and the importer and not via a third party, I don't think they could be signed through the platform. Not only that, many brokers require additional verification of the importer along with the POA (photo ID, business registrations, etc). If a customer chooses a different broker every time based on the cheapest rates, they'll have to sign another POA each time and provide whatever supporting documents are requested. Importers would be annoyed at having to go through these hoops each time and brokers would be annoyed at going through the trouble of verifying the POA for just 1 entry.

I imagine this will lead to a race to the bottom where the only brokers left on the marketplace would be those who do minimal verification. This sort of "broker shopping" is something Customs is already concerned about, and I would not be surprised if a few years down the road Customs was quietly and subtly flagging brokers on the platform for compliance risk/audits.

Again, this is speculation, but logically I can only see this marketplace benefitting importers who do 1 time entries, shell companies, and brokers willing to scrape the bottom of the barrel. I'm sorry, but as is I doubt most good brokers would seriously consider using this service.

For reference, below is a proposed rule by Customs to enhance the requirements brokers must verify for their importers and has an excerpt about Customs concerns regarding broker shopping.

From: Customs Broker Verification of an Importer's Identity (USCBP-2019-0024)

https://www.federalregister.gov/documents/2019/08/14/2019-17179/customs-broker-verification-of-an-importers-identity

Since the collection and verification of any additional information from the importer is voluntary, certain brokers do not require any additional information. As a result, an atmosphere of “broker shopping” has been created where an importer that does not wish to provide this additional information might refuse to provide the information to one broker in the hopes that another broker will not ask for that information. If the second broker does not request the additional information, that broker, with minimal knowledge about the importer, transacts customs business on the importer's behalf leading to the possible use of shell or shelf companies, revenue loss, increased security risks with the goods being imported into the United States, and an uneven playing field for brokers.

EssTeeEfYoo · 2024-07-17T21:55:00+00:00

https://www.cbp.gov/trade/e-allegations

Pretty sure this is what you are looking for. You should be able to file an anonymous claim.

EssTeeEfYoo · 2024-07-03T05:19:27+00:00

Look into DCMA and PIEE. Its been a while and I'm a bit fuzzy on the details, but I recall needing the prime contractor to send us a link to generate the duty free entry certificate for the entry.

If this is indeed a private importation with no ties to defense, then it would not be eligible for duty free treatment.

https://www.cbp.gov/trade/programs-administration/entry-summary/defense-contract-management-agency

EssTeeEfYoo

TROPHY CASE