COAC and CBP Discuss C-TPAT for Exports & Cross Docks, Etc.
At the October 4, 2011 COAC meeting, COAC and CBP officials discussed the work of the Global Supply Chain-Land Border Security Initiatives Subcommittee on issues such as expanding Customs-Trade Partnership Against Terrorism to exports and cross-dock operations and providing a tiered C-TPAT structure for truck carriers. The subcommittee also discussed an electronic FAST concept with no stopping at the bridge or booth.
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CBP Expressed Interest in Tiering for C-TPAT Truck Carriers
One of the issues being examined by the Subcommittee is a tiering structure for C-TPAT truck carriers, similar to that for C-TPAT importers. (There are currently three tiers for C-TPAT importers which ensure that minimal program benefits are afforded importer partner members until after an on-site validation is performed to confirm that the importer has in fact adopted tighter security measures.) A CBP official expressed support for the subcommittee’s consideration of this issue. The subcommittee agreed to provide its recommendations to CBP on this issue at the December 2011 COAC meeting.
Proposal to Expand C-TPAT to Allow Cross-Dock Operations, Etc.
The subcommittee has previously committed to developing a strawman proposal for CBP to consider how to include certain additional 3PLs and cross dock companies1 in C-TPAT. The subcommittee’s recommendations are expected to be presented at the December 2011 COAC meeting.
(According to a subcommittee document on this issue, only asset-based U.S. domestic 3PLs and U.S. domestic consolidators are eligible for C-TPAT. This excludes foreign based 3PLs that ship to the U.S. that may not have a staffed office in the U.S. or meet the licensing requirements, non-asset based 3PLs that manage a significant amount of freight on behalf of U.S. importers (both domestic and foreign based), as well as foreign based consolidators that ship to the U.S. that may not have a staffed office in the U.S. or meet the other obligations.)
C-TPAT for Exports Could Require CBP to Improve Regs, Systems
Another area that the subcommittee is looking at is the expansion of C-TPAT to exports. A CBP official characterized this as a critical issue for C-TPAT and the continued progress being made on mutual recognition makes this a good time to take a serious look at C-TPAT for exports. However, a CBP official cautioned that CBP’s systems and regulations in the export areas may require improvement.
Subcommittee Urges CBP to Look at Port- or Region-Specific C-TPAT Benefits
During the discussion on increasing C-TPAT benefits, the subcommittee also encouraged CBP to look at port or region-specific requirements (either port-by-port or region-by-region) to see if there are any opportunities for CBP to provide additional benefits to C-TPAT members that may be specific to a port, region, or mode of transportation.
Subcommittee Addresses Electronic FAST With No Stopping
Another area mentioned by the subcommittee is FAST Electronic Clearance, which would allow shipments to be released electronically, without having to stop at the bridge or booth. According to the subcommittee, FAST EC would (i) greatly improve efficient flow of goods across the border; (ii) reduce the wait time for known shippers and cargo, allowing CBP to focus its resources on the unknown; and (iii) reduce congestion and emissions at the port of entry.
1Cross docking is generally defined as a distribution system where items received at the warehouse are not received into stock, but are prepared for shipment to another location or for retail stores.
Subcommittee documents available here