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CBP Cataloging Possible Benefits for Revamped C-TPAT, Schmelzinger Says

ATLANTA -- CBP has created a “catalog” for operational and proposed benefits for its Trusted Trader pilot, CBP's Customs-Trade Partnership Against Terrorism Director Elizabeth Schmelzinger said Dec. 6 during her agency’s East Coast Trade Symposium. She called the list a “real repository” that includes “benefits that have been proposed for a very long time that are awaiting either a chance for automation, funding for automation,” and benefits for which “there’s a required regulatory change to make that implementation happen, or a legislative change to make that implementation happen.”

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Other benefits CBP would like to test include a program called “C-TPAT Defender,” which is intended to protect requesting C-TPAT participants’ identities when imports come into the U.S., Schmelzinger said. CBP plans to start testing the program this month, she said. “If it works, it’ll be huge,” she said. “It’ll be a great little benefit. You’ll get an email that says … ’Is this you importing these widgets?’ And if you say, ‘I’m not importing widgets,’ then what do we do with those widgets?”

The C-TPAT catalog “will never be finished,” is intended to be a repository “for things people are working on,” and should detail both proposals that are workable and past proposals that weren’t acted upon, Schmelzinger said. “If it is off the table or determined not to be feasible, you’ll know that,” she said. The planned transition of importer security assessment participants (ISA) into C-TPAT “is not necessarily going to be glamorous,” Schmelzinger acknowledged. “We will transition our current ISA members. You will receive whatever benefits we settle on at the end of the pilot, and then subsequently, we will continue the dialog with the trade on the development of new benefits, hopefully with measures, so that you can articulate to your CFOs and CEOs the value of the partnership arrangement that you’ve engaged in.”

CBP has a loose deadline of the end of 2018 for transitioning ISA participants into C-TPAT (see 1709070010). Schmelzinger said her agency will take a phased approach to applying C-TPAT benefits, ideally at the start of fiscal year 2019, and mentioned that the C-TPAT Reauthorization Act of 2017, pending in the Senate Finance Committee after approval in the House (see 1710240040), would require CBP to give at least 90 days’ notice of new benefits before they take effect. “That is not a hard bar,” she said. There should be “reasonableness in terms of exposing the requirements and a lot of education, a lot of webinars, and opportunity for the trade,” Schmelzinger added. “You won’t be wondering.”

The Commercial Customs Operations Advisory Committee Minimum Security Criteria Working Group will reconvene in the beginning of 2018, with hopes of developing a way to solicit feedback beyond the working group itself, Schmelzinger said. That working group offered some recommendations about a year ago (see 1611150030).Schmelzinger announced some likely components of the minimum security requirements during the C-TPAT conference earlier this year (see 1709150036).