At The Port

The October 2026 Customs Broker License Exam is this Wednesday, October 28. This week: how to run a timed diagnostic on yourself - the protocol, the pacing, the error log, the traps, and a seven-question drill on everything from Episodes 1 and 2.

In this episode:

* The official numbers: 80 questions, 4.5 hours, 75% to pass, no penalty for guessing, and the new appeals threshold (57+ to appeal up to 4 questions)

* Recent pass rates: April 2026 - 22% pre-appeal; October 2025 - 12%; April 2025 - 30%

* The diagnostic protocol: 25 released-exam questions, 85 minutes, one sitting, HTSUS + Title 19 open and nothing else

* Pacing at the exam’s own 3.4-minutes-per-question tempo, and the two-pass method

* The error log: tag every miss as knowledge, lookup, or time

* Three ways to waste a diagnostic

* Seven-question drill: Parts 141, 142, and 111

The exam facts in this episode come from CBP’s official pages and released exam documents (linked below). The study techniques - the 85-minute diagnostic, the error log, the two-pass method - are suggested technique, not CBP rules. The diagnostic is an invitation for whenever you are ready, not an assignment.

Disclosure: the host and every expert you hear on this show are AI-generated voices playing fictional characters. Nobody you hear is a real person, and no voice is meant to imitate any living person.

Sources

* CBP Customs Broker License Examination page (exam date Oct 28, 2026; withdrawal deadline Oct 26, 8:30am EDT; pass rates; appeals threshold; results timing; self-selection; candidate webinar)

* April 2026 official exam + directions (80 questions, 270 minutes, 75% passing, single best answer, no guessing penalty)

* October 2025 official exam (category mix cited in the episode)

* CBP Becoming a Customs Broker (approximately 14,454 active licensed brokers)

* 19 CFR Part 141 (Entry of Merchandise - 141.0a, 141.1, 141.5, 141.11, 141.34, 141.35)

* 19 CFR Part 142 (Entry Process - 142.2)

* 19 CFR Part 111 (Customs Brokers - 111.11, 111.13, 111.21, 111.24, 111.28, 111.29, 111.96)

Next Monday: Entry, the deep dive - 19 CFR Parts 141 and 142, the biggest category on the exam.

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Episode 2: The broker's license - who needs one, what it lets you do, and what it costs to keep. License vs. national permit, the 18-to-sit / 21-to-hold rule, responsible supervision and control, the records rules, the client notification letter, and staying licensed: triennial reports and continuing education (19 CFR Part 111).Cold open: the October 28, 2026 CBLE and CBP's new appeals threshold, plus the Triennial Status Report deadline facing every licensed broker.All voices on this show are AI-generated fictional characters, not real people; no voice is meant to imitate any living person. Study aid only - always confirm against the regulations CBP names for your exam.

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At the Port: The Customs Broker Exam Course

Episode 1 — Entry: Getting Goods In the Door

Published transcript. All voices on this show are AI-generated fictional characters, not real people; no voice is meant to imitate any living person. This course is a study aid — always confirm against the current regulations CBP names for your exam.

Quick note before anything else: every voice you hear on this show — the host, the experts, all of them — is an A.I.-generated voice playing a fictional character. Nobody on this podcast is a real person, and no voice is meant to sound like any living person. The customs law, though? Completely real. Let's go.

On October 8th, 2026 — ten days ago — Customs and Border Protection published a proposed rule called "Low-Value Shipments." If it becomes final, it rewrites how millions of packages enter the United States. Informal entries — the kind used for shipments worth twenty-five hundred dollars or less — would have to be filed electronically before or on the day of importation. The fifteen-day filing window importers have leaned on for decades? Gone, for those shipments. Every informal entry would need a customs bond. And a consignee that isn't the actual owner or purchaser — carriers, freight forwarders, postal operators — would have to hire a licensed customs broker to stand in as importer of record. Six days later, CBP pushed the compliance date for the new international mail entry procedures from late October to January 20th, 2027. The trade gets ninety more days to scramble.

And one more, because it's too good to skip. CBP's agriculture center in Miami just closed a country-of-origin case involving tuna. Pacific-caught fish was getting a quick rinse and a new label in another country, then entering the U.S. as a product of that country to dodge duties. CBP said nice try — fish caught on the high seas take the flag of the vessel that caught them. Importers are now correcting 789 entry summaries, paying about 1.3 million dollars in extra duties, with roughly 8.9 million in penalties in the pipeline.

Why start an exam course with the news? Because everything in those stories — filing windows, bonds, importer of record, entry summaries — is today's lesson, working a real job. One caution before we dive in: proposed rules and enforcement headlines are context, not exam doctrine. The exam tests the regulations as CBP publishes them for your exam date. Everything I teach as doctrine today comes from Title 19 of the Code of Federal Regulations, Parts 141 and 142, as they stand right now.

Welcome to At the Port: The Customs Broker Exam Course. Here's the deal. Every Monday, in twenty minutes or less, we take one slice of the Customs Broker License Exam, following a study calendar that ends at the April 2027 sitting. The exam: 80 multiple-choice questions, four and a half hours, open book, 75 percent to pass. And open book sounds generous until you do the math — about three minutes and twenty seconds a question. This exam doesn't reward memorizing customs law. It rewards knowing where the answer lives and getting there fast.

Every episode runs the same play: what's happening in trade right now, the rule itself, a visit to a working broker's desk, how the exam turns it all into questions, a quick retrieval drill, and your assignment. Episode one starts where every import starts: entry. Entry. One word, and the whole customs system hangs on it.

Start at section 141.4: all merchandise imported into the United States must be entered, unless specifically excepted. Everything. The exceptions are a short list — certain vessels, instruments of international traffic, some railway equipment, and the exemptions in General Note 3 of the tariff schedule. If your shipment isn't on that list, it gets entered. And no, informal entries don't dodge this — informal entry is still an entry, just a simplified one. That's Part 143, later in the season.

Now the first clock. Section 141.5 — and section 142.2 says it again: merchandise must be entered within 15 calendar days after landing from the vessel, aircraft, or vehicle that brought it. Miss that window and your goods go to general order — think government warehouse, storage charges, and eventually a government auction of your stuff. Sections 4.37 and 142.8, and Part 127 if you want the full horror story. Fifteen calendar days. Tattoo it.

Here's the idea that organizes everything else: entry is two filings, not one. Section 141.0a defines the pair. "Entry" is the documentation filed to secure the release of your merchandise from CBP custody. "Entry summary" is the documentation CBP uses to assess duties, collect trade statistics, and confirm the rest of the law was followed. Release first, duty assessment second. Two steps, two documents, two deadlines.

Step one, the entry. Section 142.3 tells you what's in the release package. CBP Form 3461 — or its electronic equivalent in ACE. For merchandise from Canada or Mexico, Form 7533 can stand in. Evidence of the right to make entry — hold that thought, we're coming back to it. A commercial invoice. A packing list, where appropriate. Whatever else CBP or another agency demands for that shipment — FDA, USDA, whoever has a hand in it. And identification of the ultimate consignee: name, street address, and the I.D. number required by section 24.5.

Step two, the entry summary. That's CBP Form 7501 — the document every working broker calls the seventy-five-oh-one. Section 142.12 sets the deadline: the entry summary, with estimated duties attached, is due within 10 working days after the time of entry. Working days. Not calendar. The exam adores that swap. There's also an option to file the entry summary at the time of entry itself — one filing doing both jobs. So who gets to make entry at all? Not just anyone with a pulse and a package. Under section 484 of the Tariff Act and CBP's Right to Make Entry directive, entry can be made by the owner of the merchandise, the purchaser, or the consignee — or by a licensed customs broker acting for one of them. And section 141.11 spells out the proof for goods arriving by common carrier: a properly endorsed bill of lading or air waybill, a certified extract, a certified duplicate, or a carrier's certificate. The bill of lading isn't a shipping receipt — it's the paper that carries the legal right to enter the goods.

Now the most important person in the transaction: the importer of record. Section 141.1 makes it personal. Duties become owed when the vessel arrives at the port intending to unload, and that liability is a personal debt of the importer to the United States. Read this next part twice, because the exam writes questions about it: paying your broker does not relieve you. Hand your broker a check for the duties, and if the broker never pays CBP, you still owe. The bond filed with the entry protects the government's revenue — it doesn't make the importer whole either. And the liability is also a lien on the merchandise itself while it's in government custody.

One more gatekeeper before release: the bond. Section 142.4 — merchandise does not leave customs custody unless a bond on CBP Form 301 is in place. Single-entry bond or continuous bond, from an approved surety, or secured with cash or U.S. obligations. No bond, no release. Bonds get their own episode — Part 113 — but file this away now: the bond is a condition of release, not paperwork you catch up on later.

Next, the question that looks easy and isn't: what exactly is the "time of entry"? Section 141.68 gives different answers depending on how you filed. If the entry documentation went in without an entry summary, the time of entry is normally when CBP authorizes release. But the importer can ask — right on the entry documentation — for it to be the time the documentation was filed, if the goods have already arrived. Filed before arrival? You can request the arrival time. And when the entry summary does double duty as both entry and summary, the time of entry is the moment that summary is filed in proper form with estimated duties attached. Same rule under the immediate delivery procedure. Notice the pattern: proper form, duties attached. And nothing counts as filed until the merchandise has actually arrived within port limits.

Last piece: the power of attorney. When a broker makes entry for an importer, the broker acts under a power of attorney — not as one. Sections 141.31 through 141.46 run this show. Customs Form 5291 is the standard form. A P.O.A. names the ports or the Center where the agent may act. Most P.O.A.s can run for an unlimited period — though a partnership's P.O.A. caps out at two years — and any P.O.A. can be revoked at any time by written notice to CBP. A nonresident principal's P.O.A. only counts if the agent is a resident authorized to accept service of process. And here's a favorite exam detail: a licensed broker must have your P.O.A., but does not file it with CBP — the broker keeps it with their books and records. That's 141.46. If you plan to pass this exam and then actually practice, this subpart becomes your daily bread. Time for our first trip to the broker's desk. Our guest is Marta Delgado — a fictional character, played by an A.I. voice — who's written as a licensed customs broker with twenty-five years of entries behind her. Marta, welcome.

Thanks for having me. Twenty-five years, and I still start every morning the same way: checking what arrived overnight and what needs an entry today.

Walk us through a real day. How much of what we just covered is theory, and how much is the job?

It's all the job. Almost nothing happens on paper anymore — entries and entry summaries move through ACE, the Automated Commercial Environment. The forms you just heard about exist as electronic equivalents. My day is a pipeline: get the entry data in before the vessel arrives whenever possible, because pre-arrival filing is how cargo walks off the dock instead of sitting on it. Then every entry gets an entry summary inside that ten-working-day window, with the estimated duties attached, and I track each one until liquidation.

Where do importers get in trouble?

Same three places, every year. One: they assume paying me discharges their duty debt. It doesn't — fourteen one point one. If the money doesn't reach CBP, they still owe. Two: deadline math. Ten working days is not ten calendar days, and people count wrong — or they start the clock on arrival day instead of the time of entry. Three: sloppy consignee data. Wrong name, wrong I.D. number, and now CBP can't tell who's actually responsible for the shipment.

And the proposed rule from the cold open — informal entries filed before arrival, bonds on everything, a broker required when the consignee isn't the owner. Does that change your life?

It hands me more work, honestly. If a carrier or a forwarder can't stand as importer of record anymore, someone with my license has to. CBP is saying it wants entry data earlier and a licensed professional standing behind the liability. That's this profession's core product: getting goods entered correctly, on time, with the right party holding the debt.

Marta Delgado, fictional broker, real wisdom. Thanks for stopping by.

Anytime. Well — anytime you type me up. Exam mode. On the October 2025 exam, Entry and Entry Summary was questions 41 through 65 — 25 of the 80, the biggest single category on the test. This isn't a warm-up topic. It's the main event.

Trap one: entry versus entry summary. The question describes a filing and asks what it does. Entry secures release. Entry summary assesses duties. The answer lives in 141.0a.

Trap two: the clocks. Fifteen calendar days to make entry — 141.5 and 142.2. Ten working days to file the entry summary after the time of entry — 142.12. Calendar versus working is exactly the swap they test. When a question mixes them, slow down.

Trap three: time of entry. They hand you a fact pattern — documentation filed before arrival, an entry summary doing double duty — and ask which date controls. Every answer choice maps to a subsection of 141.68. Know that it has subsections, know roughly what each one covers, and you're thirty seconds from the answer.

Trap four: who can make entry. Owner, purchaser, consignee, or their broker — with the evidence in the bill-of-lading family from 141.11. Watch for choices inventing other parties: the foreign seller, the freight forwarder acting on its own.

Trap five: liability. The importer paid the broker, CBP never got the money — who owes? The importer owes. That's 141.1, and the same section kills the choice claiming the bond made the importer whole.

Your navigation targets for this episode: 141.0a, 141.1, 141.4, 141.5, 141.11, 141.31 through 141.46, 141.68, 142.2, 142.3, 142.4, 142.11, and 142.12. Twelve tabs. They'll pay for themselves in March.

Drill time. Five questions, rapid fire. Pause if you want to answer out loud.

One. Merchandise lands from a vessel on March 1st. Deadline to make entry? ... Fifteen calendar days after landing — March 16th. Section 141.5.

Two. Your client signs a power of attorney and you file the entry as their broker. Who is personally liable for the duties? ... The importer. Always the importer. 141.1.

Three. What form is the entry summary? ... CBP Form 7501. Section 142.11.

Four. After the time of entry, how long to file the entry summary with estimated duties? ... Ten working days. Section 142.12.

Five. Name three parties with the right to make entry. ... Owner, purchaser, consignee — plus a licensed broker acting for any of them.

Missed one? That's the drill doing its job. These come back in later episodes until they're automatic. Your assignment this week, straight from the study calendar. Read Part 141, subparts A and C — sections 141.1 through 141.11, and the power-of-attorney sections 141.31 through 141.46 — then 142.1 through 142.16. After that, do 15 entry questions from any recent posted exam on CBP's website, and keep your error log: question, topic, why you missed it, where the answer lives. That log is gold in March.

Next week: broker basics — Part 111. What counts as customs business, when you need the license, permits, and responsible supervision and control.

You've been listening to At the Port: The Customs Broker Exam Course — an A.I.-voiced study aid. Always confirm against the current regulations CBP names for your exam. See you next Monday, at the port.

Exam takeaways

1. Entry and entry summary are two different filings: entry secures release (CBP Form 3461), entry summary assesses duties (CBP Form 7501). 19 CFR 141.0a. 2. Two clocks: 15 calendar days to make entry after landing (19 CFR 141.5, 142.2); 10 working days after the time of entry to file the entry summary with estimated duties (19 CFR 142.12). 3. Only the owner, purchaser, or consignee — or a licensed broker acting for one of them — may make entry; proof is the bill of lading family of documents (19 U.S.C. 1484; 19 CFR 141.11). 4. Duties are the importer's personal debt: paying your broker does not discharge it, and the bond protects the government, not you (19 CFR 141.1). No bond on CBP Form 301, no release (19 CFR 142.4). 5. "Time of entry" changes with the filing pattern — know 19 CFR 141.68 subsection by subsection. Brokers act under a power of attorney (Customs Form 5291), which they retain but do not file with CBP (19 CFR 141.31-141.46).

Retrieval drill (answers in the audio)

1. Merchandise lands from a vessel on March 1st. Deadline to make entry? (March 16 — 15 calendar days, 19 CFR 141.5) 2. You file entry as broker under a POA. Who is personally liable for the duties? (The importer — 19 CFR 141.1) 3. What form is the entry summary? (CBP Form 7501 — 19 CFR 142.11) 4. After the time of entry, how long to file the entry summary with estimated duties? (10 working days — 19 CFR 142.12) 5. Name three parties with the right to make entry. (Owner, purchaser, consignee — plus a licensed broker acting for any of them)

This week's assignment

- Read 19 CFR Part 141 subparts A and C (141.1-141.11, 141.31-141.46) and Part 142 (142.1-142.16). - Do 15 entry questions from any recent posted exam at cbp.gov. Keep an error log: question, topic, why you missed it, where the answer lives. - Next week: Part 111 — broker basics.

Sources

- 19 CFR Part 141 (Entry of Merchandise) and Part 142 (Entry Process), eCFR current text: https://www.ecfr.gov/current/title-19/chapter-I/part-141 and https://www.ecfr.gov/current/title-19/chapter-I/part-142 - 19 U.S.C. 1484 (Entry of Merchandise); CBP Right to Make Entry Directive 3530-002A - CBP, General CBLE Information (exam format, eligibility, categories): https://www.cbp.gov/trade/programs-administration/customs-brokers/license-examination-notice-examination/general-cble-information - October 2025 CBLE, official exam PDF (category breakdown; Entry/Entry Summary = Q41-65, 25 of 80): https://www.cbp.gov/sites/default/files/2025-11/october_2025_cble_exam_0.pdf - CBP proposed rule "Low-Value Shipments," published Oct 8, 2026 (91 FR 64532, docket USCBP-2026-0298, comments due Dec 7, 2026), as summarized by EY Global Trade: https://globaltaxnews.ey.com/news/2026-2153-us-customs-and-border-protection-proposes-revision-of-entry-rules-for-informal-low-value-shipments-comments-due-7-december-2026 - CBP extension of international-mail informal entry procedures to Jan 20, 2027 (announced Oct 14, 2026), via Thompson Hine SmarTrade: https://www.thompsonhinesmartrade.com/2026/10/cbp-delays-implementation-date-of-de-minimis-exemption-for-mail-shipments/ - CBP newsroom, tuna country-of-origin enforcement action (Oct 8, 2026, Miami): https://www.cbp.gov/newsroom/local-media-release/cbp-trade-enforcement-action-protects-millions-us-revenue-following

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