Trusted Trader Pilot Facing Further Legal Review, Though Most Features Still 'Intact'
NEWPORT, R.I. -- A notice announcing the long-discussed "Trusted Trader" pilot is now facing additional legal reviews, which continue to delay a Federal Register notice that was expected to be out last month (see 14031203), said Elena Ryan, CBP director of Centers of Excellence and Expertise (CEEs) Transition Team, The pilot would combine Customs-Trade Partnership Against Terrorism (C-TPAT) with Importer Self-Assessment (ISA). "We were hoping to have that out by now but we did need to go through some additional legal reviews," she said at a Coalition of New England Companies for Trade conference on April 1. "A lot of the things you have been hearing about now for a while are all still largely intact," including a multiphase approach, she said.
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For companies that are already ISA "there really isn't any need to join" because the ISA program will be enveloped over time to eventually receive the additional benefits, she said. Companies that are C-TPAT certified or are not part of either program should consider the pilot, she said. ISA will be subsumed into the C-TPAT program at some point, though CBP "is still not sure when that is going to happen," she said. "We are also looking at some more industry specific benefits," she said. For instance, there are things CBP could provide to the petroleum industry that would not impact a pineapple importer, she said. Also, CBP will look to leverage what is already being produced on the trade compliance side, reducing the need for a "full-blown audit" as is done under the ISA program, Ryan said.
Ryan is "very vehemently opposed" to the idea of requiring customs brokers to get additional permits in order to do business with the CEEs. Still, "how we structure that is causing people a little headache," she said. "Do we just automatically issue everyone a national permit so you can file wherever? A lot of brokers have some concerns about that, feeling that they are going to lose their local edge and now suddenly have to be playing on a national scale." Such a change would not be "seismic," as it is still required for Remote Location Filing, "but I understand it's a little complicated," said Ryan.
Another open question within the CEEs transition is how to handle broker management, considering CBP does not want to take away that physical presence from the ports, but "we think we can look at some efficiencies," she said. Putting some forms into electronic format would allow CBP to do more in terms of broker outreach rather than dealing with form changes, as is often the case now, said Ryan. CBP's background investigations will also continue to happen at the local port level, she said.