U.S. Customs and Border Protection is continuing to evaluate key aspects of its trusted trader pilot as it prepares to make the program operational as early as this fall.

The trusted trader concept seeks to update the Customs Trade Partnership Against Terrorism, an initiative launched in 2001 to ensure the security and safety of imported goods, into a broader authorized economic operator-type program by unifying it with the Importer Self-Assessment program, which focuses on traditional customs compliance issues such as classification, valuation, trade preferences, etc. CBP intends this change to be a step toward its long-term goal of a holistic, integrated trusted trader program across U.S. government agencies and believes it will also create an opportunity to enhance existing and future mutual recognition arrangements with foreign trading partners.

CBP announced a trusted trader pilot test in June 2014. The first phase tested the merging of CTPAT and ISA application, review, validations, and vetting and ran for approximately 18 months. In the second phase, which was launched in June 2016, CBP has been working closely with seven companies and participating government agencies on the following.

- measuring the incentives provided to pilot participants via an operational metrics dashboard and encouraging participants to develop their own lists of desired benefits

- establishing connections with PGAs to facilitate existing program incentives and evaluate additional incentives based on participant input

- preparing for the program to become fully operational and available to additional participants, possibly as early as October 2018

To take advantage of benefits under the CTPAT, ISA, and trusted trader programs, companies will have to demonstrate effective processes and procedures that meet both the updated CTPAT minimum security criteria and the ISA internal control compliance standards. CBP has recently indicated that importers should actively seek production information from their suppliers, even several steps back into their supply chains if necessary.

Importers should familiarize themselves with the latest developments on CBP’s trusted trader program and how to prepare for upcoming changes. ST&R will be conducting a webinar on these topics in the near future; more information will be posted here.

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