Reminder: Minimum Security Criteria for Existing C-TPAT Foreign Manufacturers Takes Effect Soon
On August 22, 2006, U.S. Customs and Border Protection (CBP) issued its minimum security criteria for foreign manufacturers already enrolled in the Customs-Trade Partnership Against Terrorism (C-TPAT) program, or for those wishing to join the voluntary, incentive-based supply chain security program.
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Minimum Security Requirement for Existing C-TPAT Foreign Manufacturers Takes Effect on Approximately November 27, 2006
In its implementation plan, CBP had stated that foreign manufacturers who were members of the C-TPAT program before August 29, 2006 would have 90 days from that date (approximately November 27, 2006) to meet the security criteria.
(See ITT's Online Archives or 09/01/06 news, 06090115, for BP summary of the implementation plan for the new C-TPAT security criteria for foreign manufacturers (both new and existing).)
Minimum Security Criteria That Must be Met
CBP has previously stated that the following types of minimum security criteria must be met by C-TPAT foreign manufacturers (partial list):
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
(CBP has also previously stated that existing C-TPAT member foreign manufacturers would 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 would be understood that foreign manufacturers must meet or exceed these baseline security criteria by the end of the implementation timeframe.
CBP stated that it 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. Canadian and Mexican foreign manufacturers will have their Free and Secure Trade (FAST) program benefits immediately suspended until notification from the C-TPAT office.)
Questions regarding these security criteria may be submitted 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/fast/us_mexico/mexico_manuf/foreign_manuf.xml