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CBP Moving Ahead with C-TPAT for Exporters

Tuesday, September 16, 2014
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection posted to its Web site recently materials indicating that it is extending eligibility for the Customs-Trade Partnership Against Terrorism to exporters. This move will help expand C-TPAT into a broader authorized economic operator-type program and, according to CBP, is consistent with the National Export Initiative to facilitate export cargo shipments.

Sandler, Travis & Rosenberg will be conducting a webinar to review the latest developments in C-TPAT on Oct. 2. Click here for more details.

Eligibility. A fact sheet released during the week of Sept. 8 states that CBP will begin accepting C-TPAT applications from exporters but gives no specific date. Those wishing to participate in the C-TPAT Exporter program must meet its definition of an exporter (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) 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 (the participant should have an alternate point of contact as well)

- commit to maintaining the C-TPAT supply chain security criteria, as outlined in the C-TPAT

exporter agreement (see attached)

- 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

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

- heightened facilitation from foreign partners, depending on the mutual recognition arrangements in place

- marketing advantages stemming from confidence among business partners that C-TPAT company cargo is more secure

- reduced examination rates and prioritized exams over non-C-T-PAT members

- priority processing over non-C-T-PAT shipments

- actions to maintain communication and coordination with C-TPAT partners during shipping disruptions

- access to an individually-assigned supply chain security specialist who is available to assist with questions regarding supply chain security

- eligibility to attend C-TPAT training and seminars such as the annual C-TPAT conference

- access to the C-TPAT Portal System, which provides a means of communication with the assigned SCSS and various multimedia security materials

- application of a common set of security requirements facilitates international trade by minimizing the duplication of efforts and procedures

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