Episode 9: Inside CBP: Priority Trade Issues, Reasonable Care and Customs Data
Former Deputy Executive Assistant Commissioner - CBP
John Leonard is an international trade and customs expert with 34 years of experience at U.S. Customs and Border Protection (CBP) and the U.S. Customs Service. He currently serves as a Senior Advisor at Kim & Chang in South Korea, advising clients on tariffs, free trade agreements, trade remedies, customs classification, valuation, and regulatory compliance. As former Deputy Executive Assistant Commissioner of CBP’s Office of Trade, John oversaw major trade enforcement and facilitation initiatives. His extensive global experience includes leading port operations in San Francisco and serving as CBP Attaché in Singapore.
John Leonard joined the US Customs Service in 1989 and retired from CBP in 2024 as Deputy Executive Assistant Commissioner of the Office of Trade. Now a senior advisor at Kim & Chang in Seoul, he explains the seven Priority Trade Issues, how CBP manages requirements for nearly 50 partner agencies, what reasonable care means for importers, how to judge a customs broker, the shift from free trade to enforcement, and where AI still gets customs questions wrong.
5 Key Findings
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Seven Priority Trade Issues are written into law
The Trade Facilitation and Trade Enforcement Act of 2015 codified CBP's priorities: antidumping and countervailing duties, forced labor, intellectual property, revenue, import safety, textiles and apparel, and agriculture. Revenue collection is now the top focus.
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CBP enforces rules for many smaller agencies
Close to 50 federal agencies have requirements at the border, from FDA and USDA to the Consumer Product Safety Commission. Ten industry-based Centers of Excellence and Expertise hold the commodity knowledge, including what each agency requires.
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Reasonable care rests with the importer
Under 19 USC 1484 the importer is liable for duties and must show it did its homework, consulted experts and kept current. Importers who exercise reasonable care generally stay out of trouble.
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Thirty-five years from free trade to tariffs
John watched the US go from one free trade agreement, with Israel, to fourteen, ending with KORUS in 2012. Since TFTEA and Trump's first term the direction has reversed toward enforcement and tariff collection.
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Single windows show what digitization can do
Singapore launched TradeNet in 1989, linking every trade agency on one system. The ASEAN Single Window now connects the customs systems of ten countries, pushing some to automate faster than they would have on their own.
Advice to the Professional
From John Leonard
Choose a customs broker by the questions they ask in the first conversation. A good broker digs into your products, likely classification, value and terms of sale before filing anything. Brokerage is price-sensitive, but the cheapest option is often not the best one.
Use AI as a starting point for classification and other customs questions, then check the regulations and the tariff schedule yourself. John has seen AI give confident wrong answers on origin rules, classification and Korean and US law. Keep up with policy changes, because importers carry the liability.
Conclusion
John’s career spans the move from free trade toward tariff enforcement. For importers today, his message is to know the law, use a careful broker, apply reasonable care and verify any answer produced by a machine.