CBP to Take New Look at Benefits Listed in Trusted Trader Pilot
CBP is close to beginning the second phase of its trusted trader pilot program that aligns the Customs-Trade Partnership Against Terrorism and Importer Self-Assessment programs, said Liz Schmelzinger, director of C-TPAT at CBP, during the April 27 Commercial Customs Operations Advisory Committee meeting. The second phase involves the "attribution of the benefits" listed within the 2014 Federal Register notice that announced the pilot (see 14061320), she said. The agency will next consider the "effectiveness and the utility of those benefits" because some of those benefits may not be relevant any more, she said. Though initially drafted as a combination of C-TPAT and ISA, the agency has since tweaked the plans (see 1511040066).
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CBP will closely review the listed benefits over the next six months, she said. "At the end of all of this work, it will be very transparent in terms of what was recommended and what was found," she said. CBP is about done with the pilot's first phase and the C-TPAT and ISA programs are now under the same umbrella within CBP, she said. "The end game of trusted trader pilot is really to develop the trade compliance portion of the trusted trader portfolio for CBP," said Schmelzinger. While C-TPAT is "securely" in the supply chain security realm, CBP hopes to transition ISA into a "trade compliance program" that is "scalable and looks and feels a little more realistic" and has tangible benefits, she said. The vehicle to complete that is through the pilot and "I know it's taken a while," but it will be useful to review the benefits and potentially add some "new innovation" in the "trade compliance portion of those programs," she said.
Meanwhile, the COAC Trusted Trader subcommittee is close to finishing a framework document meant to help guide future work. The document "outlines the future vision of an enhanced Trusted Trader Program based on the foundation of a 'continuum of activity; a consistent level of engagement between the trade and regulatory government partners that demonstrates the highest level of commitment in practice; to security, compliance, and partnership within the global supply chain,'" the subcommittee said (here). The "master principles" document covers framework, objectives, scalability and involvement of the partner government agencies, said subcommittee co-chair Michael Young, vice president of Business Processes and Systems for Orient Overseas Container Line. The framework will mark a "significant movement forward," he said.
The COAC also recommended that "CBP focus Trusted Trader strategic and tactical objectives on developing compelling benefits for voluntary participation in Trusted Trader Programs, and should outweigh the cost of participation," it said. Such benefits "are essential for the advancement of Trusted Trader Programs and must be articulated in specific facilitation metrics." Benefits must be aligned with section 101 of recently passed customs reauthorization legislation, which sets requirements for improving partnership programs, it said.