CBP Expects to Pilot "C-TPAT for Exporters" with Japan, Costa Rica & Colombia

Pilot of C-TPAT for Exporters Expected to be Available in Near Future

COAC has recommended to CBP that C-TPAT status for exporters be developed. At the meeting, CBP officials told COAC that they were starting to develop a C-TPAT pilot for exporters and that Japan, Colombia, and Costa Rica have agreed to participate. CBP officials state that the ground work for a C-TPAT pilot for exporters is being laid to be available in the near future.

At the October 4 COAC meeting, a CBP official characterized C-TPAT for exporters as a critical issue and that recent progress on mutual recognition makes it a good time to look at the concept seriously.

(The President’s Export Council has recently recommended that the Administration explore alternative mechanisms to authorize exports that require a license today, such as a Trusted Exporter Program. The PEC noted that a good example already exists on the inbound side with programs such as C-TPAT. See ITT’s Online Archives 11112124 for summary of PEC recommendations.)

(See ITT’s Online Archives 11110368 for summary of a WCO report stating that Colombia has launched an Authorized Economic Operator (AEO) program. See ITT’s Online Archives 11042120 for summary on WCO’s work with Central America on AEO programs. Japan became an AEO in 2008, information available here.)

CBP Working to Increase Foreign Joint C-TPAT Validations, MRAs

As part of its efforts to expand C-TPAT membership, CBP states that the goal for C-TPAT is to increase joint validations with other government agencies by 25% over the next three years. CBP also states that it expects Mutual Recognition Agreements (MRAs) to increase by 50% over the next two years.

(See ITT’s Online Archives 09070605 for summary of Japan and the U.S. signing C-TPAT/AEO mutual recognition arrangement and 11120107 for summary on the U.S. and EU agreeing to mutual recognition by July 2012, and 11062821 for summary that provides an update on mutual recognition with Mexico.)

CBP and COAC Gathering Information on Tiering Benefits for C-TPAT Carriers

Another COAC recommendation is that CBP create a tiered security framework for C-TPAT highway carriers similar to that for importers. At the meeting, a CBP official noted that CBP wants to develop a set of tangible benefits for highway carriers before it proceeds with programming and further development and is looking for COAC input.

COAC notes that some of the possible benefits of Tier 3 status for highway carriers include: recognition from CBP and from potential customers; invitations to participate in pilot programs where available; direct communication with C-TPAT program leadership; and input in developing new security requirements and programs. COAC will be contacting some carriers and trucking associations to determine what additional benefits the industry is interested in and will report back to CBP. CBP will be considering recommended C-TPAT benefits and a tiered benefit model for highway carriers.

(CBP has previously stated that Tier 1 is certification, Tier 2 is certification and validation, and Tier 3 is best practices.)

COAC Says More Info Needed on C-TPAT for 3PLs, Foreign Based Consolidators

Although COAC had previously discussed recommending C-TPAT for additional third party logistics providers (3PLs) and foreign based consolidators, the Land Border Subcommittee indicated that additional work and information on the issues was needed.

(According to a previous 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.

See ITT’s Online Archives 11110716 for summary on COAC’s prior commitment to developing a strawman proposal for CBP to consider how to include additional 3PLs and cross-dock companies in C-TPAT.)

Stakeholder Input into Update of C-TPAT Web Portal Sought

COAC also recommended that CBP obtain user input for C-TPAT Web Portal 2.0. COAC says that as the plans for the update to the C-TPAT web portal are developed, CBP should solicit input from COAC and other C-TPAT stakeholders for improvements to the C-TPAT web portal. CBP urged COAC to make its recommendations for web portal improvements as soon as possible.

One example that COAC provided for improvement is to allow the C-TPAT member to flag another C-TPAT partner in the Search Partners section, so that the partner could be monitored by the C-TPAT member. (Currently the only way to include a monitored C-TPAT member is to input their SVI number, which COAC says is very cumbersome and prone to errors due to the number of characters in the new SVI numbers.)

COAC also Recommends SVI Query Access, Continuity Plan Access, Etc.

In addition to the COAC recommendations discussed with CBP (see above), COAC is also recommending:

1. allowing Status Verification Interface (SVI) number query access for all users,
2. sharing an external version of the National Business Continuity Management template as soon as it is available, and
3. creating a C-TPAT working group under the COAC Land Border Subcommittee

COAC Land Border Subcommittee “draft” recommendations available here. These recommendations were amended after posting to CBP’s Web site.

CBP’s C-TPAT report for December 5, 2011 meeting available here