Reminder on Phased Implementation Schedule for New Security Criteria for "Existing" C-TPAT Importers
In March 2005, U.S. Customs and Border Protection (CBP) implemented its new minimum-security criteria for importer participants in the Customs-Trade Partnership Against Terrorism (C-TPAT).
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New Criteria Took Effect March 25, 2005 for Importers Wishing to Join C-TPAT
CBP had stated that importers wishing to join the C-TPAT program on or after March 25, 2005, would need to meet or exceed the new minimum security criteria before they would be 'certified' and eligible for benefits.
Three-Phase, Gradual Implementation for "Existing" C-TPAT Importers
CBP had also stated that importers who were already members of C-TPAT (i.e., who had completed and received the memorandum of agreement signed by CBP) as of March 25, 2005, would be subject to a three-phase implementation approach, which would provide existing members more time to address the measures outlined in the new minimum security criteria.
The three phases of implementation for "existing' C-TPAT Importers are:
Phase 1 - hardening the physical supply chain (approximately May 24, 2005)
Under the first phase, existing member importers had 60 days from the March 25 effective date (i.e., until approximately May 24, 2005) to address the following three security criteria:
- Container security (seals, inspections, storage)
- Physical Security (fencing, lighting, parking, building structure, locking devices and key controls, lighting, alarm systems, video surveillance cameras)
- Physical access controls (employees, visitors, deliveries, challenging and removing unauthorized persons)
Phase 2 - internal supply chain management practices (approximately July 23, 2005)
CBP stated that within 120 days of the March 25 effective date (i.e., approximately July 23, 2005), existing C-TPAT member importers would have to review and enhance the more internal or procedural security elements:
- Personnel security (pre-employment verifications, background checks, personnel termination procedures)
- Procedural security (documentation processing, manifest procedures, shipping and receiving, cargo discrepancies)
- Information technology security (password protection, accountability)
- Security training and threat awareness
Phase 3 - business partner requirements (approximately September 22, 2005)
CBP stated that during the final phase of implementation, existing C-TPAT member importers would be afforded 180 days from the March 25 effective date (i.e., until approximately September 22, 2005) to address the Business Partner Requirement elements. CBP stated that importers must have written and verifiable processes for the selection of business partners including manufacturers, product suppliers, and vendors, and documentation substantiating that business partners throughout their supply chain are meeting C-TPAT security criteria, or equivalent supply chain security program criteria administered by a foreign Customs administration.
(CBP had also stated that existing C-TPAT member importers would not be required to provide a written certification that the new minimum security criteria had been met, nor would previously submitted and accepted security profiles need to be resubmitted.)
(See ITT's Online Archives or 03/28/05 and 03/31/05 news, 05032810 and 05033105, for previous BP summaries on CBP's new C-TPAT security criteria and its implementation plan.)
C-TPAT security criteria implementation plan for importers (dated 03/25/05), available at