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Details of CBP's Implementation Plan for the New C-TPAT Minimum Security Criteria for Customs Brokers (Existing Members Have 90 Days)

U.S. Customs and Border Protection (CBP) has issued its minimum-security criteria for customs brokers 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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These new minimum-security criteria solidify membership expectations, and more clearly define and establish the baseline level of security measures, which must be employed by member customs brokers.

The customs broker minimum-security criteria are effective as of December 31, 2006.

(See today's ITT, 07010515, for BP summary of the new C-TPAT security criteria for customs brokers.)

For Customs Brokers Wishing to Join C-TPAT

Customs brokers wishing to join the C-TPAT program on or after December 31, 2006, will need to meet or exceed the security criteria before they will be 'certified' and eligible for benefits.

For Existing C-TPAT Member Customs Brokers(90 Day Implementation)

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

According to CBP, existing member customs brokers will have 90 calendar days from the December 31, 2006 effective date to address all of the following security areas:

  • Business Partner Requirements
  • Container and Trailer Security (container/trailer security, etc)
  • Container and Trailer Seals (seals, etc)
  • Physical Access Controls (employees, visitors, etc)
  • Procedural Security (notifying CBP, etc.)
  • Documentation Processing (transmitting information, etc)
  • Physical Security (fencing, lighting, parking, etc.).
  • Information Technology Security (passwords and accountability)
  • Security Training and Threat Awareness

Written Certification Not Required

Existing C-TPAT customs brokers will not be required to provide a written certification that the security criteria has been met, nor will previously submitted and accepted security profiles need to be resubmitted. It will be understood that customs brokers must meet or exceed these baseline security criteria by the end of the implementation timeframe.

Consequences for Non-Compliance with Minimum Security Criteria

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

C-TPAT Implementation Plan for Minimum Security Criteria for Customs Brokers (dated December 2006) available at http://www.cbp.gov/linkhandler/cgov/import/commercial_enforcement/ctpat/security_criteria/broker_imp_plan.ctt/broker_imp_plan.doc