Minimum Security Criteria for "Existing" C-TPAT Customs Brokers Take Effect on May 2nd

Below are "highlights" of the minimum-security criteria and its associated implementation plan:

Minimum Security Criteria for "Existing" C-TPAT Brokers Take Effect on May 2nd

In its implementation plan, CBP had stated that Customs brokers who were members of the C-TPAT program before December 31, 2006 would have 90 days from that date (approximately March 31, 2007) to meet the minimum security criteria. CBP subsequently postponed the effective date to May 2, 2007. (See ITT's Online Archives or 03/12/07 news, 07031205, for BP summary.)

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

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 Customs brokers:

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

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

CBP had stated it would 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.

(See ITT's Online Archives or 01/05/07 news, 07010515, for BP summary of the details of the minimum security criteria for Customs brokers.)

Questions regarding these security criteria may be submitted to Industry.Partnership@dhs.gov

Revised implementation plan for customs brokers reflecting the May 2, 2007 date (dated March 2007) available at http://www.cbp.gov/linkhandler/cgov/import/commercial_enforcement/ctpat/security_criteria/broker_imp_plan.ctt/broker_imple_plan.doc

C-TPAT minimum security criteria for customs brokers (dated 01/01/07, reposted 03/20/07) available at http://www.cbp.gov/linkhandler/cgov/import/commercial_enforcement/ctpat/security_criteria/broker_sec_criteria_final.ctt/broker_sec_criteria_final.doc

BP Note

According to trade sources, the National Customs Brokers & Forwarders Association of America (NCBFAA) has objected to certain broker minimum security criteria (e.g., the requirement to file entries 24 hours prior to arrival at the first port of entry). Sources indicate CBP acknowledged that some of the minimum security may be incorrect and a revised version may be made available. However, it is not known when or if CBP will issue a revised version of its C-TPAT minimum security criteria for customs brokers.

Trade sources also state that once the minimum security criteria has been met, it would be advisable to update the company's profile in the Web portal to reflect the adoption of the new criteria.