Textbook chapter 1
Identify who has the right to make entry
Answer first
Separate substantive importer-of-record status from documentary evidence. An owner or purchaser needs a qualifying financial interest; a nominal consignee may designate a licensed broker but does not gain an independent right merely from a shipping document. The importer of record with the right to make entry is the owner or purchaser, or a licensed customs broker designated by the owner, purchaser, or consignee. A nominal consignee may designate a licensed broker but generally may not make entry on its own behalf; the evidence rules in Part 141 and the Right to Make Entry Directive control the analysis.
Rule breakdown
Controlling rule and limits
19 CFR 141.11–141.16; CBP Directive 3530-002A, Right to Make Entry ↗The importer of record with the right to make entry is the owner or purchaser, or a licensed customs broker designated by the owner, purchaser, or consignee. A nominal consignee may designate a licensed broker but generally may not make entry on its own behalf; the evidence rules in Part 141 and the Right to Make Entry Directive control the analysis. The learning objective is to determine whether the owner, purchaser, consignee, or broker can act as importer of record for the stated facts.; exceptions and triggering facts must be identified before calculation or conclusion.
Authority navigation and proof
19 CFR 141.11–141.16; CBP Directive 3530-002A, Right to Make Entry ↗Separate substantive importer-of-record status from documentary evidence. An owner or purchaser needs a qualifying financial interest; a nominal consignee may designate a licensed broker but does not gain an independent right merely from a shipping document. Navigate the controlling material through 19 CFR → Part 141 → Subpart B → evidence of right to make entry; Directive → section 5.1 → importer of record and nominal consignee rules. Record the decisive text and fact rather than relying on memory or a search snippet.
Decision path
- 1
Set the legal gate for Identify who has the right to make entry
Determine whether the owner, purchaser, consignee, or broker can act as importer of record for the stated facts. Separate the controlling trigger from descriptive labels, then list the facts that could activate an exception or a different legal path.
- 2
Prove the rule in 19 CFR 141.11–141.16
Find the Directive's definition of importer of record and the restriction placed on a nominal consignee. Use this route: Open Directive 3530-002A and scan section 5.1 before checking the evidence provisions in Part 141.. Preserve the exact subsection, field instruction, note, or rate line that supports the answer.
- 3
Test the boundary of Identify who has the right to make entry
Separate substantive importer-of-record status from documentary evidence. An owner or purchaser needs a qualifying financial interest; a nominal consignee may designate a licensed broker but does not gain an independent right merely from a shipping document. Apply that boundary to the stated facts, identify the fact that would reverse the result, and only then adopt the worked-example conclusion: No. The nominal consignee may designate a licensed broker but may not make entry on its own behalf under the stated rule.
Worked example
Scenario: A nominal consignee wants to file the entry itself without using a licensed customs broker. Is that permitted under the Directive?
- 1.Identify the party as a nominal rather than an actual consignee, owner, or purchaser.
- 2.Locate the nominal-consignee rule in Directive 3530-002A section 5.1.
- 3.Distinguish the power to designate a broker from the right to file independently.
- 4.Conclude that the nominal consignee must use the permitted broker route described by the Directive.
- 5.Boundary check: change one decisive fact identified by this research task—Find the Directive's definition of importer of record and the restriction placed on a nominal consignee.—and explain whether the conclusion would change under 19 CFR 141.11–141.16; CBP Directive 3530-002A, Right to Make Entry.
Conclusion: No. The nominal consignee may designate a licensed broker but may not make entry on its own behalf under the stated rule.
Common traps and corrections
× Treating every named consignee as the owner or purchaser.
✓ This shortcut fails because “Treating every named consignee as the owner or purchaser.” skips a controlling distinction. Separate substantive importer-of-record status from documentary evidence. An owner or purchaser needs a qualifying financial interest; a nominal consignee may designate a licensed broker but does not gain an independent right merely from a shipping document. Re-run the source route in Open Directive 3530-002A and scan section 5.1 before checking the evidence provisions in Part 141. and state the decisive fact before selecting the result.
× Confusing possession of shipping documents with substantive right to make entry.
✓ This shortcut fails because “Confusing possession of shipping documents with substantive right to make entry.” skips a controlling distinction. Separate substantive importer-of-record status from documentary evidence. An owner or purchaser needs a qualifying financial interest; a nominal consignee may designate a licensed broker but does not gain an independent right merely from a shipping document. Re-run the source route in Open Directive 3530-002A and scan section 5.1 before checking the evidence provisions in Part 141. and state the decisive fact before selecting the result.
× Applying Identify who has the right to make entry without proving both the decisive fact and the controlling source edition.
✓ Separate substantive importer-of-record status from documentary evidence. An owner or purchaser needs a qualifying financial interest; a nominal consignee may designate a licensed broker but does not gain an independent right merely from a shipping document. Navigate the controlling material through 19 CFR → Part 141 → Subpart B → evidence of right to make entry; Directive → section 5.1 → importer of record and nominal consignee rules. Record the decisive text and fact rather than relying on memory or a search snippet. For the October 2026 CBLE, use the designated edition; for live work, separately date and verify the current source rather than blending the two lanes.
Frequently asked questions
Which fact controls first when applying Identify who has the right to make entry?
Separate substantive importer-of-record status from documentary evidence. An owner or purchaser needs a qualifying financial interest; a nominal consignee may designate a licensed broker but does not gain an independent right merely from a shipping document. Start with 19 CFR 141.11–141.16, identify the trigger and any exception, and use the decision path before calculating or choosing a familiar label.
Where should I verify Identify who has the right to make entry for the exam and for live work?
Use the cited exam-edition source cards for the October 2026 CBLE and preserve their pinpoint text. For a live transaction, separately re-check the current statute, eCFR, HTS, or CBP operational source listed for this chapter; a newer source does not silently rewrite the exam edition.
Official sources and editions
- 19 CFR Part 141 (2025): Title 19 CFR, 2025 Annual Edition, Part 141
October 2026 CBLE-designated 2025 Annual CFR; current eCFR must be checked separately for live transactions.
Last reviewed: 2026-08-19
- 19 CFR Part 142 (2025): Title 19 CFR, 2025 Annual Edition, Part 142
October 2026 CBLE-designated 2025 Annual CFR; current eCFR must be checked separately for live transactions.
Last reviewed: 2026-08-19
- 19 CFR Part 143 (2025): Title 19 CFR, 2025 Annual Edition, Part 143
October 2026 CBLE-designated annual rules for informal and special filing routes; live operations require a current check.
Last reviewed: 2026-08-19
- ACE Entry Summary Instructions 2.4a: ACE Entry Summary Instructions ↗
October 2026 CBLE-designated Version 2.4a; later operational CATAIR material is a separate current-practice source.
Last reviewed: 2026-08-19
- CBP Directive 3530-002A: Right to Make Entry Directive
CBP-designated directive for the October 2026 examination; read with the designated CFR edition.
Last reviewed: 2026-08-19
- 19 U.S.C. 1484: Entry of Merchandise ↗
Official U.S. Code source for the statutory entry baseline; exam answers remain tied to designated reference editions.
Last reviewed: 2026-08-19
- 19 CFR 141.11–141.16: 19 CFR → Part 141 → Subpart B → evidence of right to make entry
Current legal baseline; confirm the edition designated for the exam sitting Reviewed for this textbook chapter on 2026-08-19.
Last reviewed: 2026-08-19
- CBP Directive 3530-002A, Right to Make Entry: Directive → section 5.1 → importer of record and nominal consignee rules
Current legal baseline; confirm the edition designated for the exam sitting Reviewed for this textbook chapter on 2026-08-19.
Last reviewed: 2026-08-19