NABI supports the National Customs Brokers and Forwarders Association of America (NCBFAA) on Improving Customs Broker Regulations
Re: U.S. Customs and Border Protection Bureau, DHS Docket No. USCBP-2020-0009, Notice of Proposed Rulemaking MODERNIZATION OF CUSTOMS BROKERS REGULATIONS
Dear Ms. Simon and Ms. Hubbard:
The National Association of Beverage Importers (NABI) appreciates the opportunity to comment on U.S. Customs and Border Protection’s (CBP) Notice of Proposed Rulemaking (NPRM) published in 85 Federal Register 34836 (June 5, 2020) concerning the Modernization of Customs Brokers Regulations in Title 19, Code of Federal Regulations (CFR) Parts 24 and 111. Since 1935, NABI is the leading trade association dedicated to interests, needs, and advocacy of importers of wine, distilled spirits, and beer or malt beverages.
NABI Members rely on the customs broker community for the successful importation of wine, distilled spirits, and beer and malt beverages in the global supply chain to efficiently enter the United States marketplace. In these turbulent times of retaliatory tariffs ever changing and, in some cases, exclusions being granted, extended, or terminated, the customs brokers play essential front-line roles for our Members’ compliance with these additional duties. Moreover, the Craft Beverage Modernization Act (CBMA) as implemented by CBP places complex entry filing responsibilities on customs brokers for beverage alcohol products. In all of these instances, an effective and efficient customs broker community is essential for importers’ businesses and any and all regulations promulgated by CBP must acknowledge and recognize the fundamental need for customs brokers to have clarity of their duties, minimal regulatory burdens that target only the essential needs to protect the revenue and enforce the relevant laws of Partner Government Agencies (PGA), and provide the least bureaucratic framework with the interface of the customs broker community and CBP. CBP has done a commendable job over the years in responding to these needs and the Modernization of Customs Brokers Regulations is a continued movement forward.
The customs broker community best understands its day-to-day operational needs and the interface of business operations and CBP regulations. As importers, we do not second guess their recommendations as concisely presented in their comprehensive comment letter submitted in this proposed rulemaking by the National Customs Brokers and Forwarders Association of American (NCBFAA). NABI supports and endorses their comment letter.
A Team is only as fast as its slowest runner. NABI wants to ensure that our customs brokers can sprint. Thank you again for this opportunity and please do not hesitate to contact me should you need any additional information.
Robert M. Tobiassen President firstname.lastname@example.org