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Expanding C-TPAT Further May be Difficult, Report Finds

Wednesday, October 16, 2013
Sandler, Travis & Rosenberg Trade Report

In a recent report on issues in homeland security policy for the 113th Congress, the Congressional Research Service suggested that participation in the Customs-Trade Partnership Against Terrorism may have peaked. The report states that while some members of Congress and some U.S. Customs and Border Protection officials favor increased participation in C-TPAT, existing benefits are not likely to draw more members and the prospects for creating meaningful additional benefits are uncertain. C-TPAT currently has approximately 10,500 participants, including importers, brokers and consolidators, carriers, marine port authorities and terminal operators, ocean transportation intermediaries and foreign manufacturers, that together account for over 50% by value of total U.S. imports.

The report points out that while many large companies have joined C-TPAT, only about 6% of all eligible import-related businesses and about 8% of eligible customs brokers are members. In part this is due to the perception that currently available benefits are not commensurate with the time and financial investment required to become certified. In particular, even with expedited processing, C-TPAT members may face delays during the import process as a result of limited coordination between CBP and the other 46 government agencies that play a role in trade enforcement.

However, the report adds, there may be no easy way to substantially expand C-TPAT benefits. In the case of land ports, the primary benefit is access to dedicated lanes where wait times may be shorter and more predictable, but adding lanes is difficult because many land ports are located in urban areas with limited space for expansion and limited ingress and egress infrastructure. In the case of maritime imports, the primary benefit is a reduced likelihood of secondary inspection, but only about 4% of all maritime containers are currently selected for such an inspection. In addition, some CBP officials have said that a further reduction in C-TPAT inspections may raise security risks because smugglers may establish clean companies and join the program in order to game the system.

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