Is my customs broker license at risk?
Quick answer
No. Tariffi's architecture is designed specifically to protect your license. You remain Filer of Record, apply all professional judgment, and transmit via your own ABI filer code. Compensation is a flat per-filing fee per 19 CFR § 111.36(c) — no percentage splits that would trigger § 111.36(b) scrutiny. Our structure follows CBP Ruling HQ H326926.
Detailed Answer
License protection is the central design constraint of Tariffi's broker partnership architecture. Every architectural decision traces back to 19 CFR Part 111 and the relevant CBP rulings.
Why your license is safe:
- You are the Filer of Record. Every CAPE declaration filed through the partnership bears your license number, your ABI filer code, and your professional signature. There is no ambiguity about who performed the customs business.
- You apply professional judgment. All 10-digit HTSUS statistical-suffix determinations are yours per CBP Ruling HQ H350722. Tariffi's platform may suggest classifications at the 6-digit HS heading/subheading level, but the final determination on every line is your call. You can modify, override, or reject any classification.
- Flat fee, not percentage. Your compensation is a flat per-filing filer integration fee per 19 CFR § 111.36(c). This is a legitimate data-service fee that compensates you for your review and filing work. It is never a percentage of the importer's refund — a structure that would raise § 111.36(b) scrutiny.
- Tariffi never accesses CBP. Our platform has no ACE credentials, no ability to transmit declarations, and no interface with CBP systems. The boundary between data preparation (Tariffi) and customs business (you) is architecturally enforced, not just policy-enforced.
- CBP Ruling HQ H326926. Our partnership structure maps to this ruling, which describes the legitimate relationship between a technology platform that prepares data and a licensed customs broker who reviews and files.
The partnership agreement includes:
- Explicit bar on Tariffi soliciting your clients for customs brokerage services
- Tenant isolation guaranteeing other broker partners cannot see your client data
- Commitment to refer any inbound customs-brokerage inquiries from your clients back to you
- Regulatory compliance representations from both parties
Bottom line: Tariffi makes your CAPE filing workflow more efficient. It does not create regulatory exposure for your license.
Related Questions
How does the Tariffi broker partnership work?
Tariffi prepares CAPE declaration data from importers' ES-003 files and routes it to your broker portal for review. You remain Filer of Record on every filing under your own ABI filer code. Tariffi never touches CBP servers. You earn a flat per-filing filer integration fee per 19 CFR § 111.36(c) — never a percentage.
How are brokers compensated?
Brokers receive a flat per-filing filer integration fee per 19 CFR § 111.36(c). The fee is paid by Tariffi on the importer's behalf and invoiced promptly after filing confirmation. It is never a percentage of the importer's refund, never a referral bounty, and never volume-based — structures that would violate § 111.36(b).
Will Tariffi file anything under my license?
No. Tariffi is a data-preparation platform — we never access CBP servers or file anything under your license. You review every CAPE declaration in your broker portal, approve it with your professional judgment, and transmit it via your own ABI filer code through ACE. You are always the Filer of Record.
What about client confidentiality?
Each broker partner has an isolated tenant — you see only CAPE filings assigned to your Filer Code. Tenant isolation is enforced at the database layer with role-scoped access and audit logging. No cross-broker visibility, no aggregated client lists, and the partnership agreement bars Tariffi from soliciting your clients for customs brokerage services.
Need help?
Upload your ES-003 to see how much you could recover, or talk to our team.