CBP Officials Now Hope for Notice on C-TPAT/ISA Trusted Trader Pilot by End of March
CBP officials are now targeting March for the beginning of its combined Trusted Trader Pilot, they said during a panel discussion at the CBP Trade Symposium on March 7. A Federal Register notice announcing the program was originally scheduled for September 2013, but was pushed back to the end of 2013 before again being postponed to allow for participation by the Food and Drug Administration and the Consumer Product Safety Commission (see 13052032, 13111920 and 14021819). The long-delayed voluntary program would combine the supply chain security elements of the Customs-Trade Partnership Against Terrorism (C-TPAT) with Importer Self-Assessment (ISA) trade compliance requirements, and CBP has said it would allow for a single validation and management approach (see 12120321).
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“To be quite candid, we reassessed it, we pulled it back, and we’re working with the trade just to make sure that benefits are commensurate with the investment,” said Todd Hoffman, acting executive director-Cargo and Conveyance Security at CBP. “I set a goal here to have this done by the end of March,” he said. “Quite frankly, we’re moving this along with [partner government agency] participation, and an enhanced benefit package,” said Hoffman. The notice announcing the pilot is currently with impacted offices for review. “We think when we’re ready to launch we’ll have a very good [Federal Register notice] that everyone will be happy with.”
The decision to include FDA is a “huge step in the right direction,” said Domenic Veneziano, director of FDA Import Operations. The sharing of information will allow FDA to reduce the risk score associated with products whose importers have been certified as compliant under the program, he said. Eventually, FDA’s vision for the Trusted Trader program includes incorporating FDA’s own trusted trader programs. “The vision moving forward is to incorporate the Voluntary Qualified Importer Program under the Food Safety Modernization Act, the Secure Supply Chain Pilot Program, and extending that to other commodities that FDA regulates like medical devices."
Industry has played a key role in making sure that the program has enough incentives to elicit participation from the trade, said Diane DeJarnett of Toyota. The Trusted Trader program benefits will only apply to participants -- companies that elect to remain only in C-TPAT will not get them. CBP has already said those benefits include retroactive flagging for all four flagging types and exemptions from non-intrusive inspection (see 13091829).
One benefit that DeJarnett is particularly optimistic about is the release of cleared partial shipments to Trusted Trader program participants when other containers within the shipment are being held. C-TPAT program participants get conditional release of non-affected containers when CBP has concerns about only part of a shipment. But though the importer saves demurrage fees by being able to remove the containers from the port, the containers still have to remain sealed. For just-in-time companies like Toyota, the ability to actually do something with the product in the containers “is a huge incentive,” said DeJarnett. “CBP has finally said [it] can give you a release on the balance of the containers and just hold the container that [it’s] interested in,” she said. “This is something that we’ve been asking for for probably ten years plus.”