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Customs Broker License – A Necessity for Customs Business

On September 22, 2022, CBP issued a Customs Ruling that may change how businesses deal with HTS classification.

In this ruling (HQ H290535), a manufacturer, without a customs broker license, requested the ability to provide a full 10-digit classification to their customers, while adding a disclaimer to the classification about liability of risk. The request for the ruling was submitted in 2017, and almost 5 years later to the day, CBP provided determination that it is unlawful for any business to provide a 10-digit HTS classification without a customs broker license.

The ruling noted provisions in the US Code, U.S.C 1641 (b)(1), that state “No person may conduct customs business (other than solely on behalf of that person) unless that person holds a valid customs broker’s license”. Customs business includes determining and providing HTS codes at 8 or 10 digits. While providing only 6 digits is not considered customs business, the full 10 digits are required for US imports and exports, therefore classification must be determined by a licensed customs broker. In short, the practice of providing HTS codes to a customer without a customs broker license is against customs regulations and will result in monetary penalties by CBP.

How should businesses ensure compliance in the wake of this ruling? By taking reasonable care. Reasonable care can be demonstrated by seeking out a customs professional, which could be a customs broker, customs consultant, or customs attorney.  Having customs business conducted by a licensed professional reduces the risk for the importer, establish a record of correct classification of goods, and ensures customs laws are being followed.

Allyn International services not only has a corporate customs broker license, but also employs many individual Licensed Customs Brokers on staff to help our customers remain compliant. Allyn provides best-in-class classification services, as well as consulting on all global trade topics and hot issues to help our customers exhibit reasonable care and mitigate risk and additional cost.

Contributor: George Ciaffone

About Allyn International

Allyn International is dedicated to providing high quality, customer centric services and solutions for the global marketplace. Allyn's core products include transportation management, logistics sourcing, freight forwarding, supply chain consulting, tax management and global trade compliance. Allyn clients range from small local businesses to Fortune 500 firms. Allyn conducts business in more than 20 languages and has extensive experience in both developed and emerging markets. Highly trained experts are positioned throughout North and South America, Europe and Asia. Allyn’s regional headquarters are strategically located in Fort Myers, Florida, U.S.A., Shanghai, P.R. China, Prague, Czech Republic, and Dubai, U.A.E. For more information, visit


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