U.S. Customs and Border Protection is seeking by March 7 submissions from organizations interested in reviewing and accrediting commercial training, programs, course materials, and other activities relating to a new continuing education requirement for licensed customs brokers.
Under a June 2023 final rule CBP is requiring individual customs broker license holders to complete at least 36 continuing education credits per triennial period, which works out to an hour per month. Brokers will be able to earn continuing education credits for a variety of training or educational activities, whether in-person or online, including the completion of coursework, seminars, webinars, workshops, self-guided activities, symposia, and conventions and, subject to certain limitations and requirements, the preparation and presentation of subject matter as an instructor, discussion leader, or speaker.
Brokers will report and certify their compliance with this new requirement when submitting their triennial status reports, beginning with the 2027 reports due between approximately Dec. 15, 2026, and Feb. 28, 2027. However, for the triennial period beginning Feb. 1, 2024, and ending Jan. 31, 2027 – and for that period only – CBP will reduce the number of credits required to be completed by six for approximately every six months that elapse between Feb. 1, 2024, and the date on which brokers may begin completing qualified continuing education activities. That date will be announced in a future CBP notice and will depend, in part, on when entities approved by CBP can begin accrediting educational activities or trainings.
CBP has explained that while training or educational activity provided by it or any other federal agency that is relevant to customs business will automatically qualify as continuing education credit, training or educational activity offered by corporations, non-profit organizations, or foreign government agencies will only qualify if it has been approved beforehand by a CBP-selected accreditor.
CBP has now advanced this process by publishing a request for proposals from those interested in becoming accreditors.
Criteria for becoming an accreditor include at least one key official possessing a customs broker license; a demonstrated knowledge of international trade laws, customs laws and regulations, and general customs practices for imported goods and goods subject to drawback; and a demonstrated knowledge of other U.S. government agencies involved in international trade transactions. Applicants must also submit information on any prior experience performing or managing similar efforts as well as project management plans outlining how accreditation responsibilities will be met.
Those responsibilities will include (1) developing and effectively maintaining a website where providers can submit accreditation materials, (2) drafting standard operating procedures for reviewing materials submitted for accreditation, determining if the activity detailed in the submission is acceptable and eligible for continuing education credit, and responding within four days, (3) reporting to CBP as needed on metrics such as number of submissions, timeliness of responses, and approvals/rejections, and (4) participating in regular status meetings with CBP and other accreditors.
Accreditors will be approved for an initial three-year period, with possible renewals.
For more information, please contact Paula Connelly (via email or at (781) 897-1771) or Lenny Feldman (via email or at (305) 894-1011).
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