CBP Commissioner Speech on Three "Tiers" of C-TPAT Benefits

Tiered system of C-TPAT benefits, based on level of security, best practices, etc.Commissioner Bonner stated that he believes that there should be a tiered system of C-TPAT benefits, based on the level of security, validation results, and use of C-TPAT best practices, which he envisions as follows:

First Tier (certified). Tier 1 would consist of certified companies who receive the following C-TPAT benefits:

reduced Automated Targeting System (ATS) scoring, which results in fewer security inspections and fewer compliance inspections;

access to Free and Secure Trade (FAST) lanes on the land borders;

eligibility for the Importer Self-Assessment Program (ISA), for training classes, and assistance with security issues; and

access to a future C-TPAT Web page that would allow CBP to communicate securely with C-TPAT members. This Web page would contain a list of C-TPAT members, unless a member prefers not to be listed and would notify C-TPAT partners of elevations of the threat level, threat assessments, and non-classified information pertinent to supply chain security.

Commissioner Bonner notes that certified companies are those that have submitted their security plans; have committed to meet C-TPAT minimal security criteria and have had those plans evaluated and approved by CBP supply chain security specialists; and based upon vetting, have had no history of significant compliance or law enforcement problems.

Second Tier (certified, validated). Tier 2 would consist of validated C-TPAT companies who would get even further ATS reduction in their scoring, and even fewer inspections.

CBP has already validated the supply chains of 10% of all certified partners and another 20% are in the process. In 2005, CBP is increasing dramatically the number of people it has conducting validations.

Third Tier "Green Lane" (certified, validated, C-TPAT best practices). Tier 3 would consist of those certified and validated C-TPAT partners who exceed the minimum standards, who have adopted C-TPAT best practices. Commissioner Bonner states that the third tier is his vision for the highest level for C-TPAT, i.e, the "Green Lane."

C-TPAT partners who meet the "gold standard" of best practices - that is, for example, certified, validated C-TPAT importers using C-TPAT best security practices would get the "Green Lane" - no inspections for security. They would be subject to only relatively infrequent random inspections.

Among the added benefits for validated C-TPAT partners will be moving the shipments of C-TPAT members to the front of the inspection line when a shipment does need to go to secondary, either for a random inspection or due to other agency requirements.

C-TPAT membership will be factored into CBP contingency response to terrorist attack. Commissioner Bonner states that C-TPAT membership will also be factored into CBP's planning for contingency response in the event of a terrorist attack, that impacts U.S. ports, transportation and cargo facilities. In reestablishing normal operations, C-TPAT members will receive priority in moving their freight into the country, depending on an analysis of existing intelligence regarding continuing threats.

C-TPAT now has over 9,000 private sector participants. According to Commissioner Bonner, there are currently 9,083 private sector companies that have joined C-TPAT, consisting of over 5,000 importers, 2,200 carriers, 1,400 brokers, and nearly 400 foreign manufacturers.

CBP is tightening C-TPAT. Commissioner Bonner also stated that CBP is tightening up on C-TPAT, noting that during the application process for certified status, 20% of the security profiles submitted for C-TPAT membership have been rejected because of failure to meet minimally acceptable C-TPAT security levels. CBP has decertified and suspended almost 100 companies because of their negative validations, for failure to meet their commitments, or because their supply chain security was compromised.

Bonner further states that CBP will be increasing its validations to further assure that security commitments by C-TPAT partners are being met.

Next steps for CBP (including Smart Box, etc.). Commissioner Bonner notes that there is much more to do, including implementing the Smart Box, continuing to expand the Container Security Initiative (CSI) to ports in strategic locations, and internationalizing the core elements of CBP's cargo security strategy (through the World Customs Organization-sponsored Framework to Secure and Facilitate Global Trade that will be presented to the WCO Council in June 2005).

(See ITT's Online Archives or 04/22/05 news, 05042205, for BP summary of ACE presentation from the Miami C-TPAT seminar.

See ITT's Online Archives or 03/31/05 news, 05033105, for BP summary on CBP's new C-TPAT security criteria for importers.)

Commissioner Bonner's remarks (dated 04/21/05) available at

http://www.cbp.gov/xp/cgov/newsroom/commissioner/speeches_statements/apr21_2005_miami.xml.

CBP press release on Commissioner Bonner's remarks (dated 04/21/05) available at

http://www.cbp.gov/xp/cgov/newsroom/press_releases/04212005.xml.