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Sign inApr2018 · Q25 · Entry & Entry Summary
When a nominal consignee cannot secure a licensed customs broker: under Directive 3530-002A section 5.5.1, entry is denied and the consignee notifies the owner or purchaser either to designate a licensed broker or to make entry on their own behalf as importer of record
Use only Customs Directive 3530-002A of June 27, 2001, which the April 2018 exam lists as a required reference. Step 1, who has the right to make entry: section 2 and 5.1.2 say that under Section 484 of the Tariff Act of 1930, as amended, only the importer of record may make entry, and the importer of record is the owner or purchaser of the goods, or, when designated by the owner, purchaser or consignee, a licensed customs broker. Step 2, who a nominal consignee is: 5.3.1 says 'owner' and 'purchaser' include any party with a financial interest in the transaction, but not a nominal consignee who has no other right, title or interest in the goods beyond what a bill of lading, air waybill or other shipping document gives. Under 5.1.3 a nominal consignee may designate a broker but may not make entry on its own behalf. Step 3, the rule when no broker can be secured: 5.5.1 says that if a nominal consignee cannot secure the services of a licensed customs broker, entry of the merchandise must be denied. Step 4, what the nominal consignee can do: it may (1) notify the owner or purchaser to designate a licensed customs broker to make entry for them, or (2) notify the owner or purchaser that they could make entry on their own behalf as importer of record. Both paths run through the owner or purchaser. Step 5, what it cannot do: in no case can the nominal consignee make entry in its own name, even through a licensed customs broker, or serve as the ultimate consignee. Permission from the actual owner does not turn the nominal consignee into an owner or purchaser with a financial interest; 5.9.1 makes the same point for freight consolidators, who cannot make entry with or without the owner's permission. Step 6, the broker's role: under 5.1.3 and 5.2.1, when a broker makes entry for a nominal consignee, the broker must appear as importer of record on the entry and entry summary. Step 7, scope: 5.13.1 says informal entries, I.T. entries and T&E entries are not subject to Section 484, and 19 CFR 143.26 lists who may make informal entry. So this is the formal-entry rule under Section 484, not a universal rule for every kind of entry. The lesson matches the preserved official answer D and key line 25 ('Customs Directive Right to Make Entry # 3530-002A § 2, 5.1, 5.5.1'). Not taught: any option-by-option walkthrough, answer letter or question number; any claim that the June 2003 review date ended the directive; any 2026 proposed rule as current law.
What you will learn
Use only Customs Directive 3530-002A of June 27, 2001, which the April 2018 exam lists as a required reference. Step 1, who has the right to make entry: section 2 and 5.1.2 say that under Section 484 of the Tariff Act of 1930, as amended, only the importer of record may make entry, and the importer of record is the owner or purchaser of the goods, or, when designated by the owner, purchaser or consignee, a licensed customs broker. Step 2, who a nominal consignee is: 5.3.1 says 'owner' and 'purchaser' include any party with a financial interest in the transaction, but not a nominal consignee who has no other right, title or interest in the goods beyond what a bill of lading, air waybill or other shipping document gives. Under 5.1.3 a nominal consignee may designate a broker but may not make entry on its own behalf. Step 3, the rule when no broker can be secured: 5.5.1 says that if a nominal consignee cannot secure the services of a licensed customs broker, entry of the merchandise must be denied. Step 4, what the nominal consignee can do: it may (1) notify the owner or purchaser to designate a licensed customs broker to make entry for them, or (2) notify the owner or purchaser that they could make entry on their own behalf as importer of record. Both paths run through the owner or purchaser. Step 5, what it cannot do: in no case can the nominal consignee make entry in its own name, even through a licensed customs broker, or serve as the ultimate consignee. Permission from the actual owner does not turn the nominal consignee into an owner or purchaser with a financial interest; 5.9.1 makes the same point for freight consolidators, who cannot make entry with or without the owner's permission. Step 6, the broker's role: under 5.1.3 and 5.2.1, when a broker makes entry for a nominal consignee, the broker must appear as importer of record on the entry and entry summary. Step 7, scope: 5.13.1 says informal entries, I.T. entries and T&E entries are not subject to Section 484, and 19 CFR 143.26 lists who may make informal entry. So this is the formal-entry rule under Section 484, not a universal rule for every kind of entry. The lesson matches the preserved official answer D and key line 25 ('Customs Directive Right to Make Entry # 3530-002A § 2, 5.1, 5.5.1'). Not taught: any option-by-option walkthrough, answer letter or question number; any claim that the June 2003 review date ended the directive; any 2026 proposed rule as current law.
Customs Directive 3530-002A, Right to Make Entry, header and sections 2, 5.1.2 and 5.1.3; Customs Directive 3530-002A, sections 5.2.1 and 5.3.1 (broker listed as importer of record; owner or purchaser defined); Customs Directive 3530-002A, section 5.5.1 (consignee's inability to secure service of an agent); Customs Directive 3530-002A, sections 5.9.1 and 5.13.1 (consolidators without owner permission; informal, I.T. and T&E exceptions); April 2018 CBLE directions (required references), question 25 stem and official answer key line 25 (historical original excerpt) · Historical Customs Directive 3530-002A, Right to Make Entry, dated June 27, 2001 (supersedes 3530-002 of 11/6/84; review date June 2003), which the April 2018 exam directions list as a required reference (original-options-key.txt line 11). This lesson uses the cached original text in video-pilot/source-evidence/2024may/Directive3530-002A-resume5658.txt, read in full: section 2 (policy), 5.1.2 and 5.1.3 (importer of record and nominal consignee), 5.2.1 (broker listed as importer of record), 5.3.1 (owner or purchaser defined), 5.5.1 (consignee's inability to secure a broker) and 5.13.1 (informal, I.T. and T&E exceptions). The June 2003 review date is a scheduled review date, not an expiration date. The cached original is not a fresh 2026 CBP fetch. The proposed 2026 low-value shipments rule (2026-20650, published as a proposal on October 8) is not current law and is not part of this historical lesson.
Explained using the historical edition for this exam.