Details of CBP's Implementation Plan for the New C-TPAT Security Criteria for Foreign Manufacturers

Currently, C-TPAT for foreign manufacturers is open to manufacturers in Mexico and other foreign manufacturers by invitation only. (See ITT's Online Archives or 08/31/06 news, 06083105, for BP summary announcing the availability of this plan.)

These new minimum-security criteria help solidify membership expectations, and more clearly define and establish the baseline level of security measures, which must be employed by member foreign manufacturers.

The foreign manufacturer minimum-security criteria are effective as of August 29, 2006.

(See ITT's Online Archives or 08/31/06 news, 06083105, for BP summary announcing the availability of these criteria. See today's ITT, 06090110, for BP summary of the new C-TPAT security criteria for foreign manufacturers.)

For New Foreign Manufacturers Wishing to Join C-TPAT

Foreign manufacturers wishing to join the C-TPAT program on or after August 29, 2006, will need to meet or exceed the security criteria before they will be 'certified' and eligible for benefits. Applications for new membership will only be accepted electronically, via the C-TPAT web-based online application for foreign manufacturers with the submission of a completed, comprehensive security-profile that is required at time of application.

For Existing C-TPAT Member Foreign Manufacturers

For foreign manufacturers who are already members of the C-TPAT program, a 90-day implementation approach will be followed which provides existing members with sufficient time to address the security measures outlined in the criteria.

Existing member foreign manufacturers will have 90 calendar days from the August 29, 2006 effective date to address all of the following security areas:

Container and Trailer Security (seals, container/trailer security, etc.)

Physical Access Controls(employees, visitors, etc.)

Physical Security (fencing, lighting, parking, etc.)

Personnel Security (background checks, employee hiring, etc.),

Procedural Security(documentation, manifesting procedures, etc.)

Security Training and Threat Awareness

Information Technology Security (passwords and accountability)

Business Partner Requirements

Certifications. Existing C-TPAT member foreign manufacturers will not be required to provide a written certification that the security criteria have been met, nor will previously submitted and accepted security profiles need to be resubmitted. It will be understood that foreign manufacturers must meet or exceed these baseline security criteria by the end of the implementation timeframe. CBP will continue to use validations to gauge whether or not Foreign Manufacturers have adopted these security criteria. Those foreign manufacturers found to be deficient, may have their benefits suspended, or removed from the program entirely.

Foreign manufacturers in Canada and Mexico failing to meet security criteria as evidenced through a validation, or because of a resulting seizure due to compromised supply chain security, will be have their Free and Secure Trade (FAST) program benefits immediately suspended until notification from the C-TPAT office.

Lastly, as a voluntary, incentive based supply chain security program, the new C-TPAT security criteria for foreign manufacturers are risk based, flexible, and designed to help CBP achieve its twin goals of security and facilitation. CBP will continue to work with members who demonstrate a commitment towards strengthening their entire supply chain and benefits will be provided accordingly

To assist in the implementation of these security criteria, the trade is encouraged to submit questions to Industry.Partnership@dhs.gov.

Implementation plan for foreign manufacturers (dated 08/22/06) available at http://www.cbp.gov/xp/cgov/import/commercial_enforcement/ctpat/security_criteria/security_criteria_foreign_manuf/foreign_mfc_implementation_plan.xml

New minimum security criteria for foreign manufacturers, and additional details on C-TPAT for foreign manufacturers, available at http://www.cbp.gov/xp/cgov/import/commercial_enforcement/ctpat/security_criteria/security_criteria_foreign_manuf/ and http://www.cbp.gov/xp/cgov/import/commercial_enforcement/ctpat/fast/us_mexico/mexico_manuf/foreign_manuf.xml