ITT Q&A with Cindy Allen of DHL Global Forwarding

Has the recent increase to CBP's enforcement of Importer Security Filing (ISF or 10+2) had much effect on doing business? If so, how?

We have not seen an impact in the normal business process with the enforcement efforts by CBP. This may be attributed to the high-level of compliance that our customers have achieved over the past several years during the implementation of the program itself. At DHL Global Forwarding, we have viewed this program as an opportunity to partner with CBP and our customers to facilitate the communication process in a more efficient manner by receiving data earlier in the process, and then meeting the deadline of the ISF program. We carefully listen to the voice of our customers through ongoing contact and collaboration.

Beyond some of the traditional customs-focused operations, what other responsibilities have brokers taken on in recent years?

I see the regulatory efforts of the 47 different agencies that have authority over importation or exportation increasing over the next several years. As in years past, as new regulation has been rolled out that affects shipments in and out of the U.S., Customs brokers have stepped up to fill the gap. In the past few decades, Customs brokers have come to be known as the neutral party that can assist in the identification and implementation of regulatory challenges that impact our customers’ import and export needs. The ISF program was a good example of Customs brokers reaching beyond the typical focus into the security realm. Currently Customs brokers file the vast majority of ISFs. At DHL Global Forwarding we have a compliance department dedicated to tracking the various regulatory efforts, communicating to and educating our customers on the changes, and ensuring we are able to offer services to meet their needs. Other Government Agency (OGA) expertise will be a major need in the Customs brokerage industry, and I am happy to say DHL Global Forwarding has some of the best expertise in this area.

Should the broker exam be easier or harder?

I do not think that the major concern regarding the broker exam that our industry should address is if it should be easier or harder. I believe we need to address what the test is actually measuring. The current test determines if the individual understands the regulations that govern our industry and that we have sufficient knowledge of the laws and regulations that our customers must meet. I do not believe the test is an accurate gauge of how to perform the most basic functions of a customs broker which involve the mechanics of filing and obtaining a release and entry of merchandise. If you put a newly licensed broker in a Customs brokerage operation, they would not be able to facilitate the movement of the freight. I think there is a need for the test to measure not just the current areas, but also address the need to understand what a Customs broker does and how to perform those functions.

There's been discussion of CBP requiring 40 hours of continuing education every three years for customs brokers. Does that seem like an appropriate standard?

I am a very large proponent of continuing education of Customs brokers. At DHL Global Forwarding over 25 percent of our staff have the Certified Customs Specialist (CCS) designation from the NCBFAA. We make investments in our people through development programs. In this fast changing environment, we need to ensure that our industry remain at a very high level of compliance. We can only achieve this through encouraging education.

How do you see the job changing as CBP moves to a more virtual environment, particularly within the Centers of Excellence and Expertise (CEEs)?

As CBP moves, so must the industry. We are in a changing environment at CBP with the implementation of the virtual environment CEEs. Changing the mentality of CBP is only one step in ensuring the success of the CEE. The next step is looking at the regulatory and statutory barriers that prevent our industry from mirroring the CBP structure. This will enable our industry to structure ourselves in a manner that meets the needs of our customers, ensuring the success of our own companies. Three years ago DHL Global Forwarding aligned our Customs brokerage unit by industry sector which CBP’s CEEs closely mirror, and enabled centralization of processes. It also supports our global GoGreen efforts by facilitating electronic communication rather than supporting a paper environment. I see this as a definite trend of the future.

Do you participate in any CBP pilot programs? Has it/have they been valuable?

We were the first freight forwarder to participate in the ACAS program with CBP and TSA. This has been beneficial to our customers by reducing the risk profile they have for shipments traveling by air. At DHL Global Forwarding we have designed security strategies aligned to our customers’ transportation needs.

Which other government agencies have lately caused the most issues? Do you see that changing with new food safety and product safety regulations coming out?

Of all of the OGAs, FDA has the largest impact on importations. They regulate about 30 percent of all shipments into the U.S. in one manner or another -- and the number of shipments continues to grow. At the same time, they have been challenged with development and enforcing tighter controls and oversight on these shipments. With the current restrained budgets and resources, FDA is finding its way to a risk management approach that can achieve the needed oversight while recognizing the compliant players in the field. This is an area that needs more focus and development in all of the agencies, and can be supported with the ACE access and data that is now available to the OGAs.

With the recent emphasis on intellectual property issues, have you had any problems bringing in branded merchandise?

At DHL Global Forwarding we work very closely with our customers to identify the information up front that prevents those unwanted issues from happening downstream. We have not been directly impacted by current issues, but are carefully monitoring this area. We also partner with the regulatory authorities in this area to ensure that there is a level of knowledge of our customers’ products and traffic patterns to ensure legitimate shipments are not hindered. Our sector approach gives us a broader understanding of our customers’ regulatory requirements and, subsequently, the ability to ensure compliance through efficient, effective processes.