CONTINUING EDUCATION FOR LICENSED CUSTOMS BROKERS - Comments on CBP NPRM (Docket No. USCBP-2021-0030)

Sep 26, 2026

Uploaded by Oliver

Letter supporting U.S. Customs and Border Protection’s proposed rulemaking to require continuing education (CE) for individual licensed customs brokers. The author endorses the policy as a means to improve professionalism, competency, trade compliance, and revenue protection. Comments address practical regulatory design, including CE credit unit definitions, minimum credit counts per triennial period, and recordkeeping and availability requirements such as accepting electronic transcripts and allowing reasonable time for CBP inspection.

LanguageEnglish

CategoryExam

FormatPDF

Pages4

Reading Time10 min

AccessFree to download

Continuing Education for Licensed Customs Brokers

Background

Regulatory Provisions

Section 111.1 Definitions – Continuing Education Credit

Section 111.102(b) Required Minimum Number of Continuing Education Credits

Section 111.102(d)(1) Recordkeeping Requirements

Section 111.102(d)(2) Availability of Records

Section 111.103(a)(1)(i) and (ii) Accreditation of Qualifying Continuing Broker Education Providers

November 09, 2021 Elena D. Ryan, Special Advisor Programs and Policy Analysis Regulations and Rulings Office of Trade U. S. Customs and Border Protection [Email:](Email: Broker.Continuing.Education@cbp.dhs.gov)[ ](Email: Broker.Continuing.Education@cbp.dhs.gov)[Broker.Continuing.Education@cbp.dhs.gov](Email: Broker.Continuing.Education@cbp.dhs.gov) Melba Hubbard Chief, Broker Management Branch Trade Policy and Programs Office of Trade U. S. Customs and Border Protection [Email:](Email: melba.hubbard@cbp.dhs.gov)[ ](Email: melba.hubbard@cbp.dhs.gov)[melba.hubbard@cbp.dhs.gov](Email: melba.hubbard@cbp.dhs.gov) Via Federal eRulemaking Portal [http://regulations.gov](http://regulations.gov) U.S. CUSTOMS & BORDER PROTECTION DOCKET NO. USCBP-2021-0030 CONTINUING EDUCATION FOR LICENSED CUSTOMS BROKERS Dear Ms. Ryan and Ms. Hubbard: I am writing in support of U.S. Customs & Border Protection’s (“CBP”) Notice of Proposed Rulemaking (“NPRM”) published in Federal Register Vol. 86, No. 173 on September 10, 2021, proposing the amendment of its regulations to require continuing education for individual customs brokers license holders. As an instructor of Customs Regulations in preparation for the Customs Brokers Licensing Examination, I appreciate the opportunity to offer the following comments to ensure the continuing education regulations are fully effective, practical and administrable. Background I commend CBP for proposing the regulations, recognizing that continuing education (“CE”) will enhance the professionalism and competency that already exists in the customs broker community and will increase trade compliance and protection of the revenue of the United States. I fully agree that CBP’s regulatory changes derive support in 19 U.S.C. §1641(f) providing that: The Secretary may prescribe such rules and regulations relating to the customs business of customs brokers as the Secretary considers necessary to protect importers and the revenue of the United States, and to carry out the provisions of this section As is the case in numerous professions, I agree with CBP that a CE requirement will enhance the value of the customs broker and improve customs brokers’ skills, performance and activity. In particular, I acknowledge CBP’s finding that brokers obtaining continuing education experience an exponentially reduced number of penalties, regulatory audits and validation activities compared to those that do not procure such education. Regulatory Provisions A. Section 111.1 Definitions – Continuing Education Credit. CBP should recognize the smallest unit of continuing education credit as a 30 minutes half credit due to the frequency of classes offered for this length of time and a 55 minutes full credit for practical purposes. Numerous, high-caliber training programs extend for thirty (30) minutes. Often such programs present breaking or “hot” issues of particular relevance to the brokerage and importing community alike. I understand that other professions recognize thirty (30) minutes as the smallest unit of CE and CBP likewise should adopt the same standard. Also, CBP should award one full credit for every fifty-five (55) minutes of CE to allow for breaks, technical issues and the like. Again, this is consistent with other professional programs that award one credit for every fifty (50) or fifty-five (55) minutes ofCE. B. Section 111.102(b). Obligations of Individual Customs Brokers in Conjunction with Continuing Broker Education Requirement – Required Minimum Number of Continuing Education Credits. I agree that thirty-six (36) continuing education credits of qualifying continuing broker education each triennial period is a reasonable and attainable requirement. I recognize that thirty-six (36) hours is administrable, tracking to one credit per month or thirty-six (36) over the triennial period. This also facilitates pro-rata requirements and tracking for those reinstated following a period of v

FAQs

What is the purpose of the proposed continuing education requirement?

To amend CBP regulations so individual licensed customs brokers must complete continuing education, enhancing professionalism, competency, trade compliance, and protection of U.S. revenue.

How does the author suggest CBP should define CE credit units?

By treating 30 minutes as the smallest half-credit unit for practical classes, and awarding one full credit for 55 minutes, aligning with how other professions measure CE time.

What recordkeeping and documentation does the author recommend CBP accept?

CBP should recognize transcripts or similar electronic certifications as sufficient documentation, and should provide reasonable timeframes for record availability during inspection.

Sep 26, 2026

Uploaded by Oliver