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C-TPAT Membership Opens to Exporters on May 17

Thursday, May 14, 2015
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection has announced that on May 17 it will begin accepting applications from exporters for membership in the Customs-Trade Partnership Against Terrorism. More information and access to the exporter application are available here.

Eligibility

For C-TPAT purposes, an exporter is defined as a person or company who, as the principal party in interest in the export transaction, has the power and responsibility for determining and controlling the sending of the items out of the United States.

Entities that wish to participate in the C-TPAT exporter program must meet this definition as well as the following eligibility requirements.

- be an active U.S. exporter out of the U.S. with a documentable employer identification number or Dun & Bradstreet number

- have a business office staffed in the U.S.

- have a documented export security program and a designated officer or manager who will act as the C-TPAT program main point of contact

- commit to maintaining the C-TPAT supply chain security criteria

- create and provide CBP with a C-TPAT supply chain security profile that identifies how the exporter will maintain and enhance internal policy to meet C-TPAT exporter security criteria

- have an acceptable level of compliance for export reporting for the latest 12-month period and be in good standing with federal agencies such as the Department of Commerce, Department of State, Department of the Treasury, Nuclear Regulatory Commission, Drug Enforcement Administration and Department of Defense

CBP states that in reviewing exporter eligibility for C-TPAT it will utilize its systems to check for outbound compliance and violations and to review the frequency of cargo being shipped outbound to ensure the company is an active exporter. Supply chain security specialists will conduct on-site validations/visits to verify the company’s existence and that its security profiles and risk assessments have been completed and updated annually.

Minimum Security Criteria

While C-TPAT allows for flexibility and the customization of security plans based on the member’s business model, CBP has issued a document (attached below) setting forth the minimum security criteria that must be met throughout the export participant’s supply chain. These criteria deal with business partners; container security, inspection, seals and storage; conveyance tracking and monitoring procedures; physical access controls; personnel, procedural and physical security; export training and threat awareness; and information technology security. Where an exporter outsources or contracts elements of its supply chain, such as to a warehouse, logistics provider or carrier, it must work with these business partners to ensure that effective security measures are in place and adhered to throughout the entire supply chain.

Benefits

CBP states that exporters who have been certified and validated in C-TPAT and are in good standing as an exporter entity can receive the following benefits.

Reduced examination rates and time. C-TPAT exporters will receive trade facilitation benefits such as prioritized examination over non C-TPAT members.

Front of the line processing. To the extent possible, C-TPAT shipments are moved ahead of any non-C-TPAT shipments.

MRAs. Participants receive heightened facilitation from foreign partners with which CBP has signed a mutual recognition arrangement, which indicates that the security requirements and validation or audit procedures of the foreign industry partnership program are the same or similar as those of C-TPAT. Benefits provided by foreign customs authorities will vary based on location but typically include priority treatment, less frequent physical inspections and less intrusive inspections.

Improved internal procedures. In the process of vetting their outbound supply chains, participating exporters are able to streamline their processes, which may lead to opportunities to save time, money and efforts in the transportation of their cargo abroad.

Business resumption. In the event of a significant disruption or delay in CBP cargo processing operations, actions are taken to maintain communication and coordination with C-TPAT partners.

Supply chain security specialist. Each C-TPAT partner is assigned an SCSS who is available to discuss security issues and review problems.

C-TPAT Portal. The portal provides a means of communication with the SCSS and a way to easily correct company information.

Common standard. Application of a common set of security requirements facilitates international trade by minimizing the duplication of efforts and procedures.

Marketing. The C-TPAT logo and membership are a useful marketing tool because business partners are confident that C-TPAT partner cargo is more secure.

Training and seminars. C-TPAT partners are eligible to attend C-TPAT training and seminars such as the annual C-TPAT conference, which provides opportunities to network with other C-TPAT members.

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