CBP Officials Discuss Expanding C-TPAT to 3PLs, Third-Party Validation Pilot in China, Timeliness of Validation Reports, Etc.

CBP Is Working to Finalize C-TPAT Criteria for 3PLs

CBP officials provided an update on the status of efforts to expand C-TPAT to include third party logistics providers (3PLs). CBP has given COAC a draft set of C-TPAT criteria for 3PLs and is in the process of reviewing COAC's final comments.

CBP again emphasized that it is proceeding cautiously because it wants to carefully consider the impact of extending C-TPAT membership to 3PLs.

One COAC member asked CBP to post the C-TPAT criteria for 3PLs on the CBP Web site before the November 2008 COAC meeting.

Average Time for C-TPAT Members to Receive Validation Reports is Now 45 Days

CBP officials also provided an update on efforts to reduce the amount of time it takes to provide a C-TPAT member with its validation report. CBP instructed its field offices to complete validation reports within 60 days. As a result, the time that it takes CBP to get validation reports out to C-TPAT members has decreased to 45 days (from 100 days).

CBP Has Concluded its 3rd Party Validation Pilot, Preparing Report for Congress

According to CBP officials, the one-year voluntary third party validation pilot in China, which was mandated by the Security and Accountability for Every (SAFE) Port Act (P.L.109-347), has concluded.

CBP noted that of the approximately 300 importers eligible to participate in the pilot, only 28 importers elected to do so.

CBP officials stated that the validations of those 28 importers have taken place, including the data gathering by the third party validator, and the information has been given to CBP.

CBP noted that the lack of participation in the third-party validation pilot in China may have been due to concerns regarding costs and the sharing of proprietary data.

According to CBP, initially only 4 of the 28 participating importers passed the validation process. CBP stated that it continues to work with the 24 importers who initially failed their validation to resolve outstanding issues.

CBP's report on the pilot is currently undergoing review by the Department of Homeland Security and will be forwarded to the Congressional committees that requested it.

(See ITT's Online Archives or 08/01/07 news, 07080105, for BP summary listing the 11 validators selected for CBP's third-party validation pilot.)

CBP Has Prepared a "Draft" Booklet on the Benefits of C-TPAT

CBP officials stated that they have prepared a "draft" booklet on the benefits of C-TPAT membership and are seeking input from COAC. The final version of the booklet is expected to be made available to the public.

Statistics on C-TPAT Membership, Suspensions, Validations, Etc.

According to CBP officials, as of July 21, 2008, there were 8,527 C-TPAT certified companies, of which approximately 600 were added in 2008.

CBP has seven C-TPAT field offices. The newest field offices in Buffalo and Houston are operational and are now conducting validations. CBP states that although the new offices will focus on Canada and Mexico, respectively, they will also be performing validations throughout the world.

CBP has also completed 8,519 validations, 1,285 of which were re-validations. CBP has so far completed 1,619 validations in 2008 and has a goal of completing 3,200 validations by the end of 2008.

CBP officials stated that they have suspended/removed 593 members from C-TPAT, half of which are Mexican and Canadian highway carriers.

CBP further announced that C-TPAT has 267 Tier 3 importer partners. (Tier 3 is the highest level of C-TPAT benefits provided.)