By Bruce Leeds, Senior Counsel, Braumiller Law Group
U.S. Customs & Border Protection (CBP) published the Final Rule on continuing education for individual customs broker license holders in the Federal Register on June 23, 2023. This Final Rule made several changes to Part 111 of the Customs Regulations and imposed a continuing education requirement on individual license holders.
A good part of the background discussion in the Final Rule involved where to get the required educational hours and who is to provide them.
Part 111.103 of the new regulations contains the requirements for training to qualify towards the continuing education requirement. Any training offered by CBP – whether online or in person – will count. Training offered by other U.S. Government agencies may also count if it is relevant to Customs business. In the Federal Register notices, it was stated that "CBP will identify when a government offered training or educational activity is related to customs business and qualified continuing broker education."
Thus, the Food & Drug Administration could offer training on the requirements for importing food products and that training would count toward the continuing education requirement if CBP identified it as qualifying.
All qualified training offered by U.S. Government agencies does not need to be accredited. This means it automatically qualifies and no further qualification is needed. Of course, the broker attending the training would need to keep records of the training received.
Originally published September 12, 2023
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