CBP Posts its Answers to Trade Questions from the November 2005 Trade Symposium (Part III)

This is Part III of a multi-part series of summaries on this document and highlights CBP's answers to questions on trade partnership benefits. See future issues of ITT for additional summaries.

Will the C-TPAT office publish Q&A, descriptions, best practices and application requirements? CBP states that the C-TPAT Best Practices catalog will be published in January 2006 and will provide specific security best practices.

What are some of the C-TPAT validated members doing to control seals? CBP states that the C-TPAT Best Practices catalog will be published in January 2006 and will provide specific security best practices for seal control.

Of the 119 Tier 3 importers, how many are non-U.S. corporations? CBP states that none of the 119 Tier 3 importers are non-U.S. corporations.

Of the C-TPAT validated members, what percent are Tier Two and what percent are Tier Three? CBP states that as of November 28, 2005, 78% of the validated members receive Tier 2 benefits and 22% of validated members receive Tier 3 benefits.

When can C-TPAT members expect to receive reports of specific benefits they have received rather than general statements? CBP states that Customs-Trade Partnership Against Terrorism (C-TPAT) is in the process of gathering quantitative data demonstrating the return on investment received by members.

Will CBP extend the benefit of C-TPAT being a mitigating factor for compliance violations? CBP states that it has no plans to expand C-TPAT membership mitigation beyond specific Trade Act of 2002 violations outlined in its July 6, 2005 guidelines on penalties/liquidated damages for failure to comply with advance electronic cargo information requirements (published in CBP's July 6, 2005 Customs Bulletin.) (See ITT's Online Archives or 07/20/05 news, 05072017, for the final part of CBP's series of summaries on the guidelines, with links to previous summaries in series.)

When will C-TPAT be expanded to allow other parts of the supply chain - such as public warehouses to apply for C-TPAT? CBP states that C-TPAT has no current plans to expand beyond the current enrollment sectors.

Does CBP have data regarding reduced exams for C-TPAT members that import trade sensitive products (textiles, wearing apparel, electronics, etc.)? CBP states that C-TPAT members receive the lowest level of trade Compliance Measurement examinations, and the negation of most ACS cargo selectivity which generates a trade examination. On average, C-TPAT members receive 6 times fewer enforcement examinations, and 4 times fewer trade examinations, than non C-TPAT members.

If you fulfill the C-TPAT requirements, is there any chance to get the EC-status "Authorized Economic Operator" without an additional check? CBP states that eventually, it is envisioned that countries with comparable supply chain security programs, built along the World Customs Organization's (WCO's) Framework of Standards, may provide mutual recognition of these programs, but mutual recognition is not in the near future.

Is it possible for CBP to provide a list of all C-TPAT carriers? CBP states that at this time, C-TPAT cannot publish a list of certified carriers. However, CBP states that in the near future, a certified member may be able to query the Status Verification Interface (SVI) system by name. At present, CBP is reviewing Privacy Act concerns to determine if querying the SVI system by name is acceptable. Once a decision is reached, a message will be broadcast to all certified members.

(See ITT's Online Archives or 12/30/05 and 01/05/06 news, 05123005 and 06010510, for Parts I and II in this multi-part series of summaries.)

CBP answers to Trade Symposium questions (dated 12/23/05) available at http://www.cbp.gov/linkhandler/cgov/import/communications_to_trade/trade_2005/answers_qcards.ctt/answers_qcards.doc.