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CBP Selects Ten Validators for the C-TPAT Third Party Validation Pilot

U.S. Customs and Border Protection has posted a notice to its Web site announcing its final selection of "validators" for the Customs-Trade Partnership Against Terrorism third-party validation program.

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(CBP notes that as a result of its inability to gain access into China to validate C-TPAT importer supply chains, the Security and Accountability for Every (SAFE) Port Act (P.L.109-347) mandated CBP to develop a 1 year voluntary C-TPAT third-party validation pilot program. In spring 2007, CBP began accepting applications from entities wishing to act as "third party" validators for C-TPAT importers that buy over 75% of their imports from China (approximately 300 C-TPAT importers are expected to be eligible1).)

According to CBP, the selected third party validators are limited to conducting C-TPAT supply chain validations in China only. CBP has previously stated it will determine the facilities to be visited, including the point of stuffing, drayage of the container to the port of export, and the port of export. In addition, CBP has stated that it will retain all decisions over the C-TPAT status of the importer.

CBP Selects 10 Entities as C-TPAT Third-Party Validators

Listed below are the 10 entities selected by CBP to perform validations on CBP selected C-TPAT importers that buy over 75% of their imports from China:

ABS GroupIntertek
Det NorskeVeritasSharp Global
PinkertonCotecna
TUV RheinlandOmega Compliance
CSCC/STRSGS North America

CBP states that it does not endorse or authorize any of the entities listed to engage the importer in services other than conducting supply chain security validations in China.

(In May 2007, CBP officials had stated that they expected to have their third-party validator list available by the end of May 2007. See ITT's Online Archives or 05/21/07 news, 07052105, for BP summary of CBP officials' discussion of the C-TPAT third party validator pilot for China at the May 15, 2007 COAC meeting.)

Eligible C-TPAT Importers Will be Notified of Opportunity for Pilot Program

CBP states that eligible C-TPAT importers will be given written notification by CBP of their opportunity to be selected for the third party validation pilot program. That notification will include the contact information for the third party validators. Those opting to participate will be required to select one of the third party entities within 30 days to initiate the validation process. Both the third party firm and the C-TPAT importer will be required to sign a conflict of interest form prior to the initiation of any contract and the start of the validation.

1CBP has previously stated that those selected will include 55 C-TPAT importers that source 100% of their imports from China, and 245 additional C-TPAT importers that source over 75% of their imports from China.

(See ITT's Online Archives or 04/27/07 news, 07042705, for BP summary of CBP's procurement notice regarding the C-TPAT third-party validation pilot program.)

CBP notice available at http://www.cbp.gov/linkhandler/cgov/import/commercial_enforcement/ctpat/third_ptyselec.ctt/third_ptyselec.doc.