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Final Phase of CBP's Implementation of the New Security Criteria for Existing C-TPAT Importers Begins Approximately September 22, 2005

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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Three-Phase Implementation of Criteria for Existing C-TPAT Importers

CBP had 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 with more time to address the measures outlined in the new minimum security criteria.

First phase (physical supply chain) began approximately May 24, 2005. Under the first phase of CBP's implementation plan, existing C-TPAT members had 60 days from March 25, 2005 (i.e., approximately May 24, 2005) to address the hardening of their physical supply chain.

Second phase (internal/procedural security) began approximately July 23, 2004. Under the second phase of CBP's implementation plan, existing C-TPAT members had 120 days from March 25, 2005 (i.e., approximately July 23, 2005) to review and enhance the more internal or procedural security elements.

Third and final phase (business partner requirements) to begin approximately September 22, 2005. Under the third and final phase of CBP's implementation plan, existing C-TPAT members have 180 days from March 25, 2005 (i.e., until approximately September 22, 2005) to address the Business Partner Requirement elements.

CBP has said 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 has 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 profiled need to be resubmitted.

CBP notes that it is understood that importers must meet or exceed the baseline security criteria by the end of each implementation phase.

CBP stated that it will continue to use validations to gauge whether or not importers have adopted these security criteria. Those importers found to be deficient may have benefits suspended or be removed from the program entirely.

All Three Phases of New Criteria Took Effect March 25, 2005 for Importers Wishing to Join C-TPAT

CBP had stated that importers wishing to join C-TPAT on/after March 25, 2005, would need to meet or exceed the new minimum security criteria before they would be 'certified' and eligible for benefits.

(See ITT's Online Archives or 06/22/05 news, 05062205, for BP reminder on the phased implementation schedule for new security criteria for existing C-TPAT importers. See ITT's Online Archives or 03/28/05 news, 05032810, for BP summary on CBP's implementation plan for the new C-TPAT security criteria for importers.)