Background

U.S. Customs and Border Protection has issued a strategy outlining how it will work to accelerate the global transition to green trade and decrease its own environmental footprint as part of an effort to address climate change. This strategy incorporates four broad goals: incentivizing green trade, strengthening environmental enforcement, accelerating green innovation, and improving climate resilience and resource efficiency.

According to CBP, recent studies have estimated that global supply chains may account for as much as 80 percent of the world’s total carbon emissions. In addition, environmental crime represents between $85 billion and $265 billion in criminal revenue each year and is often linked to money laundering and the funding of transnational criminal organizations. CBP states that it is “well-positioned to help develop and enforce a cleaner, more sustainable international trading environment through the agency’s influence on global supply chain practices and enforcement of laws against environmental crimes.”

Among the more notable measures directly affecting the trade community that CBP plans to take or consider taking to advance this strategy are the following.

- streamlining cargo clearance through processes similar to Advanced Qualified Unlading Approval (AQUA lanes) and unified cargo processing and encouraging the use of eco-friendly modes of transport such as electric vehicles and low-emission vessels

- adding environmental criteria to existing trusted trader programs such as CTPAT and working to implement similar programs in other countries to increase the overall return on investment for those who comply

- reimagining the entry process and other trade processes to make them more resource-efficient

- working with partner government agencies to apply existing penalties in a more aggressive manner or exploring other consequence options

- expanding the collection of supply chain data and intelligence to target polluters and parties involved in trading illicit environmental goods such as ozone-depleting substances, illicit timber, and critical minerals

- sharing environmental enforcement information with the trade community to enable them to police their own supply chains

- upgrading trade infrastructure at ports of entry to withstand severe weather events and rising sea levels

- encouraging the inclusion of environmental requirements and other climate commitments in trade agreements

Internally, CBP may pursue steps such as (1) allowing more employees to work remotely where operationally feasible, (2) enhancing the energy efficiency of office buildings and transitioning to an electric vehicle fleet, and (3) making agency operations compatible with emerging technologies and environmentally-friendly methods of commerce.

CBP notes that the measures outlined in this strategy “are only a starting point” and that it will make adjustments as needed to respond to new challenges, priorities, and opportunities.

The CBP strategy was released concurrently with the “Green Customs Global Conference” organized by the World Customs Organization to discuss customs agencies’ role in addressing climate change and related environmental issues. One of the panels highlighted “strong demand” for more granular Harmonized System codes for environmental goods, and the WCO said it will be organizing a series of symposia in the second half of this year to discuss this and other trade policy issues in depth. Other panels discussed customs challenges associated with the circular economy (i.e., recycling, reuse, repair, and refurbishment of goods) and the use of technology to manage environmental risks.

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