CBP Update on the Customs-Trade Partnership Against Terrorism
The Departmental Advisory Committee on Commercial Operations of the Bureau of Customs and Border Protection (COAC) held a quarterly meeting on June 18, 2004 in Washington, DC to discuss and receive updates from U.S. Customs and Border Protection (CBP) officials on various trade and customs issues.
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This is Part III of a multi-part series of summaries on the June 18, 2004 COAC meeting and highlights CBP's update on issues related to the Customs-Trade Partnership Against Terrorism (C-TPAT). See future issues for additional summaries. (See ITT's Online Archives or 06/22/04 and 06/23/04 news, 04062205 and 04062315, for Parts I and II.)
Certified C-TPAT participants are less likely to be examined. During the meeting, CBP officials provided statistics on the rates of exams for C-TPAT participants. According to CBP officials, certified C-TPAT participants are 3-5 times less likely to be examined for trade or compliance measurement reasons and 5-8 times less likely to be examined for enforcement-related reasons.
720 C-TPAT validations have been initiated, 288 of which have been completed. CBP officials also provided COAC members with an update on its C-TPAT validation process. (The purpose of C-TPAT validation is to ensure that the supply chain security measures contained in the C-TPAT participant's security profile have been implemented and are being followed.)
According to CBP officials, 720 C-TPAT validations have been initiated, with 288 of those validations having been completed. (CBP states that they define "completed" to mean that CBP has held its validation close-out meeting with the C-TPAT participant and notes that the actual validation report is not issued until sometime later.) CBP officials state that the goal is to complete 400 C-TPAT validations by the end of 2004 and that they expect to reach this goal.
C-TPAT currently has 6,565 participants. According to CBP officials, as of June 15, 2004, C-TPAT had 6,565 participants. This number includes:
- 873 importers
- 236 carriers
- 203 Customs brokers, consolidators, forwarders, and non-vessel operating common carriers (NVOCCs)
- foreign manufacturers in Mexico
- U.S. Marine Port Authorities/Terminal Operators
CBP officials state that of those 6,565 C-TPAT participants, over 4,000 participants are certified. (CBP officials note that a participant does not receive C-TPAT benefits until it is certified.)
No timetable for opening up C-TPAT to foreign manufacturers worldwide. Although C-TPAT was expanded in August 2003 to include certain foreign manufacturers in Mexico, CBP officials state that they have no immediate timetable for opening it up to foreign manufacturers worldwide. However, CBP officials note that they are considering various options and would probably first expand C-TPAT to foreign manufacturers in related-party type situations involving U.S. importers.
CBP rejects 16% of the C-TPAT security profiles it receives. Of the security profiles it receives as part of the C-TPAT application process, CBP officials state that approximately 16% are rejected for reasons such as the fact that they contain insufficient information, the company does not qualify for C-TPAT, etc. However, CBP officials state that many of the C-TPAT security profiles originally rejected are corrected and resubmitted by the participant and are then accepted by CBP.
COAC is reviewing C-TPAT in light of trade experiences. During the June 18, 2004 meeting, COAC members stated that a COAC subcommittee has been reviewing C-TPAT in light of the experiences that the trade has had with this program. This COAC subcommittee has presented DHS and CBP with a draft framework document containing baseline recommendations for improvements to C-TPAT and has requested their input. After such input has been received, the subcommittee states that it hopes to present a final draft framework document that reflects both COAC and DHS/CBP input at the next COAC meeting.
Second group of C-TPAT Supply Chain Security Specialists completed training. According to CBP officials, the second group of C-TPAT Supply Chain Security Specialists have completed training. As a result, CBP states that it now has a C-TPAT Supply Chain Security Specialist staff of 41 that are located throughout the four C-TPAT field offices in Miami, New York, Los Angeles, and Washington, DC. (CBP officials have previously stated that C-TPAT Supply Chain Security Specialists will be dedicated to C-TPAT and will be responsible for doing C-TPAT validations.)