CSCB Recommendations on Customs Broker Licensing

July 30, 2009

30 July 2009

CSCB Recommendations on Customs Broker Licensing

The following is a message from CSCB President Carol West. Any questions or comments about the CSCB and issues related to customs broker licensing may be sent to [email protected].

The Canadian Society of Customs Brokers participates fully and constructively in CBSA's Brokers Licensing and Account Security Programs Review, and we also have two repreresentatives on CBSA’s Licensing Advisory Committee. As the organization representing the interests of customs brokers in Canada, we have extensive knowledge, experience and understanding of issues related to customs broker licensing, especially the role of licensing in protection of the public interest.

The following recommendations have been presented to CBSA as a starting point for further discussion of the licensing issue:

a) The licensing of customs brokers must continue. Licensing provides a standard that is readily understandable by the buyers of customs brokerage services. CSCB supports the principle of a single licence allowing a customs broker to transact business anywhere in the country.

b) A customs broker should not be expected to pay more for his licence fee under a new system than he pays today. CSCB is willing to further explore fee structure options.

c) In those situations where paper must be submitted, and there is a customs broker operating in that location, a distant broker must engage that broker as a sub-agent.

d) Licensing should be enhanced as follows:

i. financial (if surety or similar provider is willing to provide a licence bond, then that should be accepted as indicative of financial viability)

ii. business knowledge should be assessed. The CSCB is willing to consider how we might play a role in assessing the business operational knowledge of the individual named on the customs broker license.

iii. customs knowledge should be assessed and ongoing knowledge should be mandated. The CCS designation should be mandatory for the individual named on the customs broker license. The linkage between the CCS designation and the licensing function guarantees the maintenance of knowledge that is critical to CBSA compliance and security initiatives. The CSCB is willing to hold responsibility for the administration of the CCS designation program as it relates to the broker licensing function. All record-keeping and other costs associated with the designation would be borne by the CSCB. On an annual basis, the CSCB would communicate to CBSA the names of those who fail to maintain their designation to allow CBSA to ensure that those named on the licenses still meet the knowledge requirement.

iv. license renewals should be for a term of 3 years. At time of renewal, a local CBSA official should conduct a face-to-face interview with the individual named on the license.

Although the CSCB position is that the CCS designation should replace CBSA's current Professional Examination to meet the knowledge requirement of a customs brokers licence, that is only part of the CSCB recommendation on customs broker licensing. We are also focused on elements relating to financial stability and business knowledge. We believe our comprehensive approach to the issue of broker licensing, which is being developed by the CSCB Board of Directors, will be good for the industry and good for the public we serve.


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