CBP Official Discusses C-TPAT - China, Exporters, Tier 3, Re-Validations, Etc.

CBP Hopeful to Conduct Third Round of Joint Validations, No Permission Yet

Skinner stated CBP is hopeful that China will allow CBP to conduct a third round of joint C-TPAT validations in China. So far, CBP has not gotten confirmation from China that they will be allowed to conduct such validations.

If not, CBP will have to consider how to move forward with C-TPAT benefits for members bringing in goods from China. One strategy could be resuming the third party validation pilot in China. (This program was shut down after its one year mandated pilot due to lack of interest.)

CBP to Conduct Unannounced Visits of Members Previously Involved in Security Incidents as a Condition of Reinstatement

Skinner announced that CBP will begin conducting unannounced visits of C-TPAT members previously involved in a security incident who had their benefits suspended.

Skinner explains this would be for companies that after having their C-TPAT benefits suspended, expressed a willingness to work with CBP and develop a corrective action plan. As a condition for being reinstated into C-TPAT, CBP is requiring that the companies allow CBP to conduct unannounced visits to ensure that they are following through on their corrective action plans and they are meeting their minimum security criteria.

CBP Has Accelerated Mandated C-TPAT Re-Validation Schedule

Skinner noted that while the Security and Accountability for Every (SAFE) Port Act of 2006 requires CBP to validate companies within one year of their date of certification and re-validate C-TPAT members every four years, CBP has accelerated that schedule to re-validate members once every three years. Skinner added that CBP is re-validating Mexican highway carriers each year.

CBP is Conducting Pilot of C-TPAT for Exporters

In response to questions on whether or not CBP will be expanding C-TPAT to exporters, Skinner remarked that C-TPAT has been and will continue to be an import focused program.

Within the program, CBP undertook a pilot, which continues, where they asked certain C-TPAT members that are importers but also export to help CBP design a module for exporters. CBP says they are learning from the pilot and will continue working on the pilot.

CBP Wants to Reduce Time Average Time for Conducting Post Incident Analysis

Skinner stated that CBP is looking to reduce the average time for conducting a post incident analysis to 15 days (from 30).

CBP Working to Sign MRAs with Singapore and Japan in 2009

CBP is working to sign mutual recognition agreements (MRAs) with Japan and Singapore in 2009.

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

According to Skinner, as of March 12, 2009 there were 9,098 certified C-TPAT companies.

In 2008 CBP conducted 3,478 C-TPAT validations: 1,632 of which were re-validations and 1,846 were initial validations. As of March 12, 2009, CBP completed 422 C-TPAT validations: 232 of which were revalidations and 190 were initial validations.

CBP has suspended 455 members from C-TPAT, 233 of which are Mexican and Canadian highway carriers. CBP has removed 335 members from C-TPAT, 149 of were are Mexican and Canadian highway carriers.

Also, C-TPAT has 267 Tier 3 importer partners. (Tier 3 is the highest level of C-TPAT benefits provided.)

(See ITT's Online Archives or 02/05/09 news, 09020520, for BP summary of C-TPAT "Year in Review" for 2008.

See ITT's Online Archives or 12/01/08 news, 08120140, for BP summary of CBP's 2008 fiscal year in review, which covers C-TPAT, etc.)

C-TPAT achievements handout available via email by sending a request to documents@brokerpower.com