The U.S. Customs Broker License Exam: Tips and Perspectives

Imagine walking into a room to take an exam that you will likely fail, where the odds of success are stacked, at best, more than 3-to-1 against you?  Is it madness to willingly put yourself in that situation?  And yet, twice each year, hundreds of optimistic test-takers try to beat these long odds when they sit for the U.S. Customs Broker Licensing Exam (CBLE).  What is this thing called a customs broker license, why is it so challenging to obtain, and why is it so coveted within the trade compliance community?[1]

A customs broker license is issued to a person who has successfully passed a grueling licensing exam (after paying the exam fee), submitted a license application (along with another fee), and passed the subsequent FBI background investigation.  The open-book exam, which lasts 4½ hours and comprises 80 multiple-choice questions,[2] is ostensibly intended to measure one’s knowledge about various customs-related regulations and practices yet experience or employment in a customs-related job is not a prerequisite.  The eligibility requirements simply state that a licensee must be a U.S. citizen, must be at least 21 years old (18 on exam date), must have correctly answered 75% of the exam questions, and must not be a current employee of the federal government.  A licensee also must possess good moral character—so if a background investigation would reveal one’s history of serial killing or stealing social security checks from mailboxes, then any ambition to pursue a license would be pointless.

A licensed customs broker (LCB)[3] is legally authorized to conduct customs business on behalf of others.  But “customs business” is an often-misunderstood term of art.  It does not mean that a person who works as an employee in a customs-related job necessarily must be licensed.  For example, someone hired by an importer to perform “corporate compliance activities” typically doesn’t need a license, unless he or she will have responsibilities that fall within the definition of “customs business,” which can be found in 19 U.S.C. § 1641(a) and, here, in 19 C.F.R. § 111.1:[4]

“Customs business” means those activities involving transactions with CBP concerning the entry and admissibility of merchandise, its classification and valuation, the payment of duties, taxes, or other charges assessed or collected by CBP on merchandise by reason of its importation, and the refund, rebate, or drawback of those duties, taxes, or other charges.  “Customs business” also includes the preparation, and activities relating to the preparation, of documents in any format and the electronic transmission of documents and parts of documents intended to be filed with CBP in furtherance of any other customs business activity, whether or not signed or filed by the preparer.  However, “customs business” does not include the mere electronic transmission of data received for transmission to CBP and does not include a corporate compliance activity.

Successful exam strategy

One would think that the success rate in an open-book exam consisting of multiple-choice questions ought to be fairly high, but history tells us otherwise.  Indeed, the CBLE is perhaps the most difficult professional certification exam.  The historical pass rate over the past twenty-five years has generally been below 30%, with many pass rates in the teens (e.g., 13% for the May 2024 exam) or even dipping into single digits (e.g., 1.5% for the April 2012 exam, and 5.5% for the April 2023 exam).  Several specific factors affect one’s ability to pass this demanding exam, and these factors fall into two broad categories: knowledge and test-taking skill.

The knowledge you take into the exam room is the primary reason for successfully passing the CBLE.  As with any vocation, knowledge comes with experience.  There are few shortcuts—while classroom and self-directed learning have considerable value, our brains are hard-wired to learn most effectively from our lived experiences.  Knowledge that sticks with us permanently comes mainly from our hands-on experience in real-world situations.  The longer you’ve been working in customs-related roles, and the more varied that experience is, the more likely it is that you will pass the CBLE.[5]  Hands-on knowledge of each of the customs subjects that a licensed broker is expected to master, such as origin and value determination, HTS classification, and entry procedures, requires practice, practice, practice, practice—and, oh yeah, practice.  Cramming for two nights before a high school algebra test may have gotten you a passing grade, but it’s probably unrealistic to expect a favorable result if you try to cram for the CBLE.

But knowledge, whether gained from experience or from reading every regulation thirty times, will carry you only so far.  Regardless of how confident you are in your mastery of customs ABCs, your pursuit of a passing grade can be sabotaged by poor test-taking skills.  Test-taking skills, which are pretty much fully within your control, comprise several elements: time management, resource management, test management, and performance under pressure.  Handled effectively, each of these elements can reduce anxiety (well, at least the sources of anxiety that you can control—no one plans to get into a fender-bender driving to the exam site).  Handled poorly, though, and you’re doomed to fail, even though your knowledge may be worthy of a better outcome.

So, behold my keys to test-taking success:

• In the weeks leading up to the exam, use the previous years’ exams as practice exams. Take as many practice exams as you can, under the same time constraints you’ll face on actual exam day.  Prior exams (available on CBP’s website[6]) are a great opportunity to hone your test-taking skills—and to find your weaknesses, which you can then work to remediate to the extent that you can.  And here’s an insider’s hint: CBP has been known to recycle questions, which only adds to the importance of studying past exams.

• As the saying goes, misery loves company, so it may be helpful to find a friend or colleague who is also studying for the exam and would benefit from a study partner. This doesn’t have to be an all-the-time thing, but study sessions with one or more study buddies can be a real advantage.

• Find a mentor, someone you can reach out to for guidance on whatever areas of customs matters you may have questions about. Someone who is willing to share the insights they’ve gained over many years of practical experience.  Someone who has an interest in your success.  Maybe this is your boss, a former boss, or another experienced colleague or LCB.

• A number of law firms, consulting firms, or other service providers offer comprehensive CBLE training programs (on-line or in-person), and you might be able to find an unadvertised local program taught by an experienced LCB. The comparative success rates of these programs will vary, and there’s no definitive data on whether those who attended formal classes fared better than those who didn’t.  Committing your time and money to a CBLE training program is a personal choice based on what you think your needs are, and how much you’re willing to pay.  If you do decide to take this path, find a program that is well-regarded and has been around for a while, with a track record of success.  Getting first-hand opinions from past students is always helpful when deciding on a program.  And if you don’t think you need a soup-to-nuts CBLE program then you might look for a class or two to close the gap on a particular weakness.

• As exam day approaches, try to limit any personal distractions. Clear your calendar of any unnecessary appointments, immediately before and after the exam.  No marriage counseling, root canals, or colonoscopies.  No mortgage closings or other life-changing events.  If you sit for the exam on Wednesday but on Thursday you will be interviewing for a new job or having elective surgery, what do you think your state of mind will be during the exam?  And try, try, try to avoid any arguments with your spouse or kids until exam day is behind you.  (I’m not trying to be funny here.  Any emotional distraction can affect your performance during the exam.)

• Travel can be a source of anxiety on exam day. Not so much if you live five miles from the exam site—but what if you have to travel a couple hundred miles?  To the extent necessary, become familiar with the city or neighborhood where the exam will be held.  Plan your travel route ahead of time, considering construction activity and normal traffic bottlenecks.  Listen to the traffic, weather reports, and then plan accordingly.  Make sure your gas tank is full.  Try to have a plan for where you’re going to park for the duration of the exam without having to worry about being towed or the parking meter running out.  If possible, ask a friend or family member to go with you; it’s one less worry if they can drive and assume all the traffic and parking responsibilities so that you don’t have to.  And if you must travel a long distance by plane, train or automobile, it might be a good idea to arrive the day before the exam, giving yourself plenty of time to have a couple of relaxing meals and a good night’s sleep.

• Pack everything you need the night before the exam. Be sure to consult CBP’s website to determine what you can and cannot bring into the exam room.[7]  Make a list of the required and allowed items and check them off the list as you pack your briefcase or backpack.  This includes the HTS, the regs, and whatever other resources CBP allows (appropriately annotated and tabbed for quick access).  Bring the required forms of identification—a passport is best because it serves as both formal ID and proof of citizenship—and bring anything else that CBP or the testing facility tells you to bring.  It’s important to note that you cannot bring any electronic device into the exam room (laptops, smartphones, smartwatches, etc.).  Even though a clock might be hanging on the exam room’s wall and the computer will track the time, it’s a good idea to wear a wristwatch—as long as it’s analog!—so that you always know what time it is.  If you’re prone to allergies, headaches, or any other ailments, bring a supply of tissues and whatever medications you might need, and bring something to drink to stay hydrated, but make sure you ask whether you can keep these items with you during the exam.  And don’t forget your eyeglasses if you need them to comfortably read the computer screen and your paper resources.

• Get plenty of sleep the night before the exam. Don’t stay up past your normal bedtime trying to cram more knowledge into your anxiety-riddled brain.  In fact, crawl into your jammies and go to bed earlier.  A good night’s sleep will serve you better than midnight cramming.  Cramming leads to cramping.  Remember that in an open-book exam a shrewd test-taker is more concerned with knowing how to find information than with memorizing information.  Think positive thoughts as you drift off to sleep—be confident that your preparation will serve you well when you walk into the exam room tomorrow.

• Use two alarm clocks. If you normally use two, then use three.

• If you normally drink coffee or tea, don’t change your morning routine—make sure you feed your caffeine (or nicotine) addiction. Remember to take your medications (if any).  And eat breakfast as you normally would.

• Dress comfortably and prepare for either a hot or cold exam room, as April and October temperatures can vary a lot in some parts of the country. You won’t know the heating or air conditioning situation until you’re in the exam room, so dress appropriately.  And don’t wear new shoes.

• Arrive at the exam site early, at least thirty minutes before the exam starts. It’s a psychological advantage to be able to choose your seat rather than be forced into the last available seat.

• Use the restroom as close to the start of the exam as possible.

• Follow all Don’t make assumptions; ask questions if you’re not sure about the rules.  You don’t want to give CBP any reason to disqualify you.

• You must effectively manage the clock once the exam begins. The exam lasts 4.5 hours, or 270 minutes, which averages out to 3 minutes and 22.5 seconds per question.  Some people may think it’s better to dive into the more difficult questions first while their mind is fresh, but that’s a losing strategy.  The worst thing you can do is eat up 10 minutes answering the first question and then start to panic.  You want to build some positive momentum, so you should start by looking for all the low-hanging fruit, which are the questions you can answer with the greatest level of confidence and speed.  This means playing to your strengths; you should tackle the questions you’re typically stronger at (maybe you’re a drawback guru) before you tackle your weaker subjects (maybe valuation).[8]  This will give you confidence and put your head in a good place for success.  If you can answer, say, half of the questions in the first hour or so, then you’ve maximized the time available to answer the more difficult questions.  But, if you allow yourself to cross that line at which you begin to lose your cool and your concentration, and panic begins to overcome you—tick tock tick tock tick tock—then your chances for success will go down the drain.  Panic and self-doubt are almost impossible to fight once you let them get inside your head.

• Read questions carefully to avoid dumb mistakes. We all get a little dumber under pressure.  Watch carefully for negatives or double negatives; little words like no or not can flip the meaning of a question.  Some questions may contain a lot of unnecessary information or they might be oddly constructed, so, to the extent you can, try to get to the essence of each question by mentally editing out all red-herring and superfluous information.  This is where the experience you gain from the practice exams can pay dividends.

• Answer all Even if you are clueless about a question, a blind guess has a 25% chance of being correct, which by my calculation is better than the 0% chance if you skip the question.[9]  And that percentage goes up if you can reasonably eliminate one (33.3%) or two (50%) answers from consideration.  Try to leave yourself a few minutes before the exam ends to ensure that you’ve answered all questions.  You won’t be a happy camper if you chose to not answer a couple questions but then learn that you failed the exam by one lousy question.

• Don’t strive for perfection. Your goal is simple: to correctly answer 60 questions.  Everyone, of course, wants their score to be as high as possible but this should not be at the expense of spending too much time on each question.  Everyone who passes the exam gets the same license, whether their score is 75% or 100%.  Keep your eye on the prize.

• Don’t second-guess yourself on every answer. This will drive you crazy, drain your confidence, kill your momentum, and eat up valuable minutes.  If you happen to finish early then of course it makes sense to take another look at the questions you were truly unsure about, but as a general rule you are better off, statistically and psychologically, if you trust your gut on most questions.

Some of these suggestions may seem frivolous or obvious, but nothing should be left to chance in the pursuit of correctly answering 60 questions (75% of the 80 questions).  Any one of these factors could mean the razor’s-edge difference between the agony of 59 and the euphoria of 60.

If a test-taker unfortunately falls short of a passing grade, but he or she thinks that credit was incorrectly denied for one or more questions, or that a question ought to be invalidated, then a formal appeal can be filed with CBP following the process outlined on CBP’s website.[10]  CBP advises that an appeal must include “a compelling argument why his or her answer is correct or why the appealed question has no possible correct answer.”  If the appeal fails, then a second appeal can be filed.  If the second appeal fails, then the matter can be taken to the U.S. Court of International Trade (CIT), and then on appeal to the Court of Appeals for the Federal Circuit (CAFC).  Judicial resolutions are not common; the most recent case was Byungmin Chae v. United States.[11]

Does a license equate to omniscience in all things customs-related?

A number of years ago I inherited an employee (let’s call him Bob) who had gotten his license a couple of years earlier.  One day a customer called to question the HTS classification—determined by Bob—that we used on a NAFTA certificate.  I asked Bob to review his classification decision with me.  He refused.  He told me, in deadpan seriousness, that there was no need for me to review it because he was an LCB and therefore the classification was correct.  This, on top of several other performance issues, became a clean-out-your-desk moment for Bob.

A broker license is a valuable professional credential that shows competence and expertise in customs matters.  But does this mean that an LCB necessarily is a better employee than a non-licensed employee at handling customs issues?  No.  In my forty-plus years in trade compliance I’ve known many non-licensed colleagues to whom I would confidently entrust with a sticky customs problem.  Like any other certification exam, the broker exam measures one’s test-taking ability under pressure as much as it measures one’s knowledge of customs matters.  Unfortunately, though, many highly knowledgeable people wilt under the pressure of the CBLE, which is the main reason why it often takes several attempts before a passing grade is achieved.  And many folks who have deep and practical expertise in customs matters may, for whatever reasons, choose to never take the exam—and yet go on to have long and successful careers in trade compliance.  So, in my admittedly anecdotal (but long) experience, I cannot say that an LCB employee necessarily possesses competence and skill in customs matters that are superior to a non-LCB employee.  There, I said it—but before you condemn me to a pit of everlasting hellfire for blasphemy against my fellow LCBs, let me explain myself …

Having your license does not mean that you’re more knowledgeable than your non-licensed colleagues.  It means you paid the required fees, you passed the exam, you passed an FBI background check, and you remember to jump through the triennial renewal hoops (which now include continuing education requirements).  This is not meant to disparage the fact that a broker license is a tremendously valuable credential to have on your résumé, because it may indeed help you get a job interview, a promotion, or a salary increase.  More, and better, opportunities in trade compliance will come your way because of your license.

Many companies—without really knowing why, I think—make a broker license a non-negotiable requirement when searching for new trade compliance talent.[12]  This is often a mistake.  It’s a requirement that has become embedded in the typical job description template (along with meaningless clichés like “self-starter” and “team player”).  But when I needed to hire someone (to replace Bob, for instance) I always told HR that the job description should say “broker license preferred” rather than “broker license required” (unless it was for a role that actually required an LCB).  Had I made it a requirement then I would have unnecessarily eliminated a large pool of otherwise well-qualified candidates.  And frankly, given the choice between an LCB with five years of experience (like Bob) and a non-licensed candidate with fifteen years of strong and varied experience, and assuming all other factors are pretty much equal, I might go with the non-LCB candidate.

When I conducted an interview (before retiring and getting into consulting), I didn’t focus primarily on whether you were or were not an LCB (or what subject your college degree was in, or where you went to school)—you had to demonstrate some practical knowledge of customs-related subjects, and I wanted to hear a little about what you accomplished and learned in trade compliance and in business.  You needed to give me a reason to hire you, to show me something that set you apart from the other candidates (other than your license).  I wanted to hear stories about decisions you made, good and bad (we’ve all made both), and how you learned to make better decisions.  A generation ago, trade compliance was a far more siloed and insular function than it is today; simply auditing entries and paying brokerage bills was enough to justify a paycheck.  But today trade compliance is a crucial element of a company’s strategic decision-making processes—sourcing decisions as a consequence of Section 301 duties are a prime example.  So did you understand the big picture, meaning that you were sensitive not only to the specific black-and-white responsibilities on your job description but also more broadly to the company’s business needs and goals?  Could you explain the role of trade compliance in growing a business and enhancing its competitive advantage?  Did you have the skills and mindset to proactively collaborate with your trade compliance teammates, and with the folks in other functions and levels within our company, to implement effective compliance practices, particularly as our business model adapted to new markets and supply chains?  And I wanted to know how you would prioritize competing compliance risks, manage an insanely busy workload, bring issues to closure, and whether you had the self-motivation to improve your skills and knowledge beyond your comfort zone, beyond what was minimally required for the job.  The fact that a candidate was or was not an LCB did not answer any of these questions.

A license doesn’t mean that you’ll be a better employee.  It’s not a measure of the intangible qualities that make you a unique human being, qualities like your common sense, your integrity and work ethic, your dedication, your creativity and curiosity, your meticulousness, your enthusiasm, your power to persuade, your skill at dealing with corporate roadblocks and crackpots, or whether you have the resolve to say no when the pressure is on to say yes.  Certainly, a license is evidence of some of these traits, and it’s not my intent to minimize the value of a credential earned by fewer than three out of ten people who sit for the exam, but a license doesn’t tell the whole story about you (or me)—not even close.  A license doesn’t fundamentally change who you are.  I found that the older I got the less stock I put in a candidate’s formal credentials and the more weight I gave to their personal character, work experience, accomplishments, and common sense.  And I always looked for a good sense of humor and a cheerful demeanor.  As the Scottish philosopher Thomas Carlyle said a couple hundred years ago, “Wondrous is the strength of cheerfulness, and its power of endurance—the cheerful man will do more in the same time, will do it better, will preserve it longer, than the sad or sullen.”  Nobody wants to work with an unpleasant person.

I don’t want to leave you with the impression that I have low regard for a broker license.  Far from it.  My license opened doors for me in my own career, as it will continue to open doors for many in our profession.  But that’s all it does—it opens a door.  What walks through the door is not a broker license.  A person with a unique blend of skills and knowledge, experiences, accomplishments, ambitions, and sensibilities walks through the door.  So, if you have your license, by all means put it in a spiffy mahogany frame and hang it proudly on the wall—I’m looking at mine now as I type this sentence—but keep it in perspective.  Or if your career plan includes sitting for the CBLE, whether next year or five years down the road, keep the pursuit of your license in perspective.  It’s a credential to be really REALLY proud of, and it may open career doors that might otherwise remain closed, but it is after all only one line on your résumé.  Just ask Bob.

[1] Although this article was written with the U.S. broker license in mind, many other countries also issue broker licenses based on varying degrees of eligibility and competence.

[2] Exams up to and including the April 1997 exam had 100 questions, with a 75% pass|fail threshold.  The October 1997 exam had 85 questions, although the official answer key shows that questions 78–82 were “experimental, not scored”.  The exam has had 80 questions since the April 1998 exam.  The CBLE is always conducted in-person at various testing facilities around the country.  While it was traditionally a paper exam, it is now conducted electronically.

[3] LCB is the suffix that some people choose to add to their names.  CHB is also used, but generally the fewer gray hairs one has the more likely one is to opt for LCB rather than CHB.  LCB was not in common use back in the 70s or 80s.

[4] A single definition cannot address all of the activities that may or may not fall within the scope of “customs business”, but fortunately CBP has clarified the scope in many insightful rulings, such as HQ H290535 (09/29/22) or HQ H045695 (10/15/10).  19 C.F.R. § 111.1 also includes the definition for “corporate compliance activity”.  See, too: The “Customs Business” Rule—What’s That All About? by Bruce Leeds: https://www.braumillerlaw.com/the-customs-business-rule-whats-that-all-about/.

[5] And yet, I know a few people who passed the CBLE without any real-world experience.  I recall many years ago that the wife of a co-worker took the exam and passed it.  She was a dental hygienist who, as far as I know, had never worked in a customs-related job.

[6] CBP currently posts on its website all exams and answer keys going back only to April 2022.  Until recently, exams and answer keys were posted going back to 1997.  CBP’s decision to remove pre-2022 exams from their website is a disservice to anyone studying for the exam, and is contrary to the spirit of “informed compliance” under the Mod Act.  See: https://www.cbp.gov/document/publications/past-customs-broker-license-examinations-answer-keys.  Fortunately, these older exams can be found on other websites.

[7] According to the most recent guidance published on CBP’s website, the following resources may be used during the CBLE:  HTSUS, 19 C.F.R., ACE Entry Summary Instructions, Right to Make Entry (RTME) Directive 3530-002A, and ACE Entry Summary Business Rules and Process Document.  Both paper and electronic versions may be used.  See: https://www.cbp.gov/trade/programs-administration/customs-brokers/license-examination-notice-examination.

[8] Beginning with the April 2005 exam, questions have been formally grouped under common subjects (like classification in questions 26–40 in the October 2024 exam) which has eliminated the stress of changing mental gears by jumping from one subject to another with each question.

[9] Beginning with the October 2023 exam, the number of potential answers for each question was reduced from five to four.  This change has benefitted test-takers in general, but especially so when guessing because the odds of a random guess being correct improved from 20% to 25%.  For what it’s worth, I’ve tallied the answers for the three most recent exams—i.e., those that offered four choices instead of five for each question—and I found that the correct answer was A for 50 questions, B for 61 questions, C for 67 questions, and D for 60 questions.  While these findings are interesting (CBP made A the correct answer with significantly less frequency), a useful guessing strategy cannot be drawn from a sample size this small.

[10] See https://www.cbp.gov/trade/programs-administration/customs-brokers/how-appeal.

[11] Byungmin Chae v. United States, 2024 CIT 126 (Ct. Int’l Trade 2024).  See https://www.cit.uscourts.gov/sites/cit/files/24-126.pdf.  I completely understand filing an appeal (and a second appeal), but it baffles me why one would go through the time, effort, and expense of litigation rather than simply sitting for the next exam.  In Chae’s case, the process ate up six years (and a baker’s-dozen opportunities to re-take the exam).  I would have taken the odds of passing a subsequent exam rather than the odds of successful litigation.

[12] To be fair, it’s often a good idea to have at least one licensed broker on staff, depending on a company’s size or circumstances.  The need is obviously more critical for a company that, say, self-files its entries or that otherwise conducts “customs business”.  But blindly making it a boilerplate prerequisite for every position is counterproductive.