COAC Asks CBP to Forge New Process with Safety-Related PGAs, Achieve Single Release by All Agencies, Etc.

The following are highlights of COAC's comments:

COAC Says Strategy Forms Sound Basis to Build Implementation Plans

COAC states that overall, the Trade Strategy is a good high-level strategic plan that forms a sound basis on which to build implementation plans that would contain specific actions with timelines. COAC adds that it appreciates the opportunity to comment on this document and to collaborate on the implementation plans that will execute this strategy.

COAC Asks if CBP Took Administration Change into Account

COAC states that one issue of concern is that a new administration will be responsible shortly after the Trade Strategy is adopted. COAC asks if CBP has taken this into account and the potential impact on the plan.

CBP Should Form a Collaborative Process with Safety-Related PGAs, Achieve Single Release by All Agencies

COAC states that the trade strategy should strongly commit CBP to a more central leadership or facilitative role with Participating Government Agencies (PGAs). Specifically, the trade requests CBP to forge a collaborative process with PGAS, especially import safety related agencies, to work toward a common vision of interacting with the importing community on targeting, advance data, the International Trade Data System (ITDS) single window, and a common concept of operations for pre-entry, border exams and release, and post-entry activities.

In essence, the trade would like CBP to dedicate sufficient resources to achieve a single window for import data submissions and a single release by all agencies.

COAC adds that with the central role of CBP in ACE, ITDS, and staffing at ports of entry, CBP is positioned to sponsor a collaboration initiative in partnership with other Federal agencies.

CBP Should Engage in Dialogue on Convergence of Trade & Security Programs

COAC states that CBP should engage in a dialogue on the "convergence of trade and security programs."

COAC notes that there are a number of dynamics underway that blur the distinction between trade and security programs for CBP and industry, for example:

most of the 10+2 data elements for the Importer Security Filing are entry or commercial data

foreign manufacturer verifications will now extend beyond Customs-Trade Partnership Against Terrorism (C-TPAT) and encompass product safety - is this commercial or security?

C-TPAT is for security but Authorized Economic Operator (AEO) is for both trade compliance and security

COAC adds that advance data submitted by many companies all come from the same source - the company's supply chain information system - whether the data is for trade or security. It is likely that CBP targeting systems also do not distinguish between trade and security data and instead simultaneously perform security and trade compliance checks on any data submitted by industry.

Export Initiatives Not Mentioned in the Trade Strategy

COAC asks where the trade strategy for exports is. COAC notes that the plan is clear on import strategic initiatives, but does not mention any export initiatives, whether they are trade or security related.

COAC states that the plan should identify the current and planned programs with other U.S. government agencies and its plans for effective export control. The Trade Strategy should also highlight CBP's involvement with other WCO members and its impact on export trade.

COAC Questions Why Standardizing Field Operations is Not in Trade Strategy

COAC states that it has discussed the fact that the document did not include as a goal or objective the issue involving standardizing CBP field operations practices when implementing policy. COAC questions if this issue should be part of the 5 year trade strategy?

(See ITT's Online Archives or 02/17/09 news, 09021750 2, for BP summary announcing the availability of this report, and other documents from the November 2008 COAC meeting.

See ITT's Online Archives or 11/04/08 news, 08110405, for BP summary of the trade strategy.)

COAC's comments (posted 02/12/09) available at http://www.cbp.gov/linkhandler/cgov/trade/trade_outreach/coac/meetings/11202008_meeting/com_trade.ctt/com_trade.doc