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Trusted Trader Program Application Still Being Developed by CBP

Wednesday, September 02, 2015
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection is reopening through Oct. 1 the period for public comments on its proposal to revise the existing information collection associated with the Customs-Trade Partnership Against Terrorism to include information collection requirements for the Trusted Trader Program.

C-TPAT applies to U.S. importers and exporters, customs brokers, consolidators, port and terminal operators, and carriers as well as foreign manufacturers. The C-TPAT application requests an applicant’s contact and business information, including the number of company employees, the number of years in business and a list of company officers.

The Trusted Trader Program will involve a unification of the supply chain security aspects of C-TPAT and the internal controls of the Importer Self-Assessment program. The goals of this program are to strengthen security by leveraging the C-TPAT supply chain requirements and validation, identify low-risk trade entities for supply chain security and trade compliance, and increase the overall efficiency of trade by segmenting risk and processing by account. This program applies to importer participants who have satisfied C-TPAT supply chain security and trade compliance requirements.

The Trusted Trader application will request the name and contact information of the applicant; business information, including business type, CBP bond information and number of employees; information about the applicant’s supply chain security profile; and the trade compliance profile and operating procedures of the applicant. CBP is developing an online application for this program that will be available through the C-TPAT portal; a draft may be viewed here.

After an importer obtains Trusted Trader Program membership it will be required to submit an annual notification letter to CBP confirming that it is continuing to meet program requirements. This letter should include personnel changes that impact the program, organizational and procedural changes, a summary of risk assessment and self-testing results, a summary of post-entry amendments and/or disclosures made to CBP, and any importer activity changes within the last 12-month period.

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