CBP Outlines its Trade Strategy Actions, Wants Ideas Emailed

Trade Strategy Was Issued in 2008

In November 2008, CBP released its "comprehensive" trade strategy for fiscal years 2009-2013 at its annual Trade Symposium. According to CBP, this strategy was created to guide the agency’s trade facilitation and security related work during the next five years.

The Trade Strategy has four goals (see below), and seven priority trade issues: antidumping/countervailing duty, agriculture, intellectual property rights (IPR), import safety, penalties, revenue, and textiles and wearing apparel.

Actions CBP Has Taken to Meet Trade Strategy’s Four Goals

The official discussed the four goals of the Trade Strategy, and the current actions that CBP is taking to meet the goals:

Goal 1: Facilitate Legitimate Trade and Ensure Compliance

To meet this goal, CBP is currently taking the following actions:

Improving risk assessment and targeting based on advance information to identify and facilitate compliant imports. CBP is looking at advanced risk modeling methodologies -- ways in which to put risk models into place that learn from previous experiences (such results from previous examinations, reviews that have been done, etc.).

The goal is to get to a point where when CBP does stop cargo, there is a high likelihood of CBP finding what they are looking for, which will reduce the number of unproductive examinations and/or reviews.

Expanding pre-entry and post-release verification programs to reduce cargo delays at the border. CBP is working to push back any activities that they can away from the physical borders, either through requests for rulings, post-summary reviews, focused assessments, etc.

Strengthening partnerships with the trade community, other U.S. government agencies and international organizations to ensure compliance.

Goal 2: Enforce Trade Laws and Collect Accurate Revenue

To meet this goal, CBP is currently taking the following actions:

Improving risk analysis and targeting through information sharing with the trade community, other U.S. government agencies, and international organizations to identify trade law violations. For example, in October 2010, CBP met with leaders from nine federal agencies for an Interagency Import Safety Conference. At the meeting, some agencies signed a Memorandum of Understanding to improve targeting and enforcement efforts at the Commercial Targeting and Analysis Center (CTAC).

(See ITT’s Online Archives or 10/22/10 news, 10102210, for BP summary of the October 2010 meeting. See ITT’s Online Archives or 04/15/11 news, 11041518, for BP summary of agencies describing how they interact with CBP on import safety, with CBP expecting cooperation to be the wave of the future.)

Applying consistent, swift, and effective enforcement actions to deter and address trade law violations and ensure lawful revenue collection. CBP reviews all enforcement actions and findings from across the country to help with its risk modeling and targeting and also to see if they are applying enforcement actions in a uniform manner. They also look to see if they are driving an increase in compliance by taking enforcement actions or if they are seeing repetitive actions being taken for repetitive violations.

Employing trade expertise to set priorities, assist in establishing national trade policy, and verify compliance. CBP has set seven PTIs (listed above), the areas of trade which CBP focuses much of its resource and energy on in the commercial trade enviroment¹. A working group has been created for each of the PTIs, comprised of personnel from various offices -- not only within CBP, but, depending on the issue, with other government agencies. This provides CBP with the opportunity to gather expertise and spread information out to its field officers.

Goal 3: Advance National and Economic Security

To meet this goal, CBP is currently taking the following actions:

Protecting U.S. consumers through the secure and trusted import of safe agriculture and goods. The primary focus here has been on working with other government agencies to ensure import safety -- such as the October 2010 interagency meeting discussed above.

Protecting domestic industry from unfair trade practices related to IPR, textiles, and AD/CVD trade law evasion. An example of CBP’s actions in this area is the creation of the e-Allegations system. This system allows external parties to provide CBP with information regarding suspected non-compliance and possible IPR infringement. Last year CBP received and reviewed over 1,600 submissions from the trade community.

Advancing DHS and CBP security priorities and assisting other U.S. government agencies with primary concerns.

Strengthening national trade policy by influencing the development of actionable trade laws and regulations that enable CBP to more effectively administer trade policy.

Goal 4: Intensify Modernization of CBP’s Trade Processes

To meet this goal, CBP is currently taking the following actions:

Streamlining trade processes and enhancing delivery of services to stakeholders though automated, account-based, and paperless processes and technology. CBP continues to work on ACE and enhance its capabilities, while also trying to get other government agencies involved.

(See ITT’s Online Archives or 03/08/11 news, 11030832, for BP summary of CBP officials discussing ACE’s designation as a moderately high risk investment and the program being put on an accelerated development schedule.)

Strengthening trade expertise and ensuring a skilled workforce capable of effectively executing CBP’s mission. CBP recognized that trade expertise is an issue and the agency is utilizing different electronic means to get information to the field quicker. CBP is utilizing technology, such as webcasts, shared workspace, and conference calls, in order to allow CBP officers to work together on issues and share information.

Ensuring organizational preparedness and commitment to change to realize the benefits of modernization. CBP is looking at how it can modernize its trade processes and procedures.

Seeks Comments, Suggestions Regarding Trade Strategy via New Email Address

The official stated that CBP is seeking comments and suggestions regarding its Trade Strategy. While it believes that its goals and objectives of the strategy are still valid, the strategy is three years old and changes or adjustments may need to be made. Specific questions that CBP is looking for answers to are as follows:

• What strategies can CBP use to try to achieve these objectives?
• What activities can CBP implement to support these objectives?
• What strategies are CBP currently using that actually create obstacles to trade facilitation?
• If you could suggest one strategy CBP can use to meet each of these objectives, what would it be?

CBP has created an email address for the public to submit comments and suggestions on the Trade Strategy: CBPTradeStrategy@dhs.gov.

(CBP has previously said that members of the trade could submit ideas to help CBP improve to traderelations@dhs.gov. CBP sources emphasized that this email address is only for members of the trade and is not for the general public. See ITT’s Online Archives or 04/04/11 news, 11040430, for BP summary.)

(See ITT’s Online Archives or 11/04/08 news, 08110405, for BP summary of CBP releasing its 2009-2013 Trade Strategy.)

CBP Trade Strategy is available here.

Trade Symposium presentation on the Trade Strategy is available here.