The Customs-Trade Partnership Against Terrorism is an attempt to develop, enhance, and maintain effective security processes throughout the global supply chain. The U.S. Customs & Border Protection office has issued the following recommendations for foreign manufacturers to help ease the importing process.

    Foreign manufacturers should develop and implement a comprehensive plan to enhance security procedures throughout their operations. These are general recommendations that should be followed on a case-by-case basis depending on the company’s size and structure and may not be applicable to all. The company should have written security procedures in place that addresses the following:

    Physical security. All buildings should be constructed of materials which resist unlawful entry and protect against outside intrusion. Physical security should include:

    •Adequate locking devices for external and internal doors, windows, gates and fences.

    •Segregation and marking of international, domestic, high-value and dangerous goods cargo within the facility by a safe, caged or otherwise fenced-in area.

    •Adequate lighting provided inside and outside the facility to include parking areas.

    •Separate parking area for private vehicles separate from the shipping/loading dock and cargo areas.

    •Having internal/external communications systems in place to contact internal security personnel or local law enforcement.

    Access controls. Unauthorized access to the shipping, loading dock and cargo areas should be prohibited. Controls should include:

    •The positive identification, recording and tracking of all employees, visitors and vendors.

    •Procedures for challenging unauthorized/unidentified persons.

    Procedural security. Measures for the handling of incoming and outgoing goods should include the protection against the introduction, exchange, or loss of any legal or illegal material. Security controls should include:

    •Having a designated security officer to supervise the introduction/removal of cargo.

    •Properly marked, weighed, counted and documented products.

    •Procedures for affixing, replacing, recording, tracking and verifying seals on containers, trailers and railcars.

    •Procedures for detecting and reporting shortages and overages.

    •Procedures for tracking the timely movement of incoming and outgoing goods.

    •Proper storage of empty and full containers/trailers/railcars to prevent unauthorized access.

    •Procedures to notify Customs and Border Protection in cases where anomalies or illegal activities are detected or suspected by the company.

    Personnel security. Companies should conduct employment screening and interviewing of prospective employees to include periodic background checks and application verifications in accordance with applicable statutes and regulations.

    Education and training awareness. A security awareness program should be provided to employees and include instruction on how to recognize internal conspiracies, maintaining product integrity, and determining and addressing unauthorized access. These programs should offer incentives for active employee participation in security controls.

    Threat awareness. A threat awareness program should be established and maintained by security personnel to recognize and foster an awareness of the threat posed by terrorists and contraband smugglers at each point in the foreign-based logistical chain. This program should include routine briefings and issuance of memoranda illustrating smuggling trends, seizures and information on terrorist threats along routes or areas along the logistical chain.

Facilitating applications

    To ease the application process, within 90 days of signing the C-TPAT Agreement for Foreign Manufacturers, provide an executive summary outlining the process elements of the security procedures that you have in place. At a minimum, address the security elements below. In addition, describe measures that fulfill the requirements of the C-TPAT Agreement for Foreign Manufacturers. If any of the requirements are not yet in place, include a plan and implementation date for achieving those requirements.

Security program

    •Facilities security

    •Theft prevention

    •Shipping and receiving controls

    •Information security controls - integrity of automated systems

    •Internal controls - process established for reporting and correcting problems

Personnel security

    •Pre-employment screening & periodic background reviews

    •Employee training on security awareness and security procedures

    •Internal codes of conduct

    •Internal controls - processes established for reporting and managing problems related to personnel security

    •Service Provider Requirements (carriers and forwarders)

    •Written standards for service providers’ physical plant security.

  •Quality controls on production processes to ensure system integrity.

  •Financial assessment process to determine service provider’s fiscal soundness and ability to provide adequate security.

  •Internal controls for the selection of service providers.

  •Indicate if your service providers participate in customs industry.  Partnership Programs: the Customs-Trade Partnership Against Terrorism (C-TPAT), the Carrier Initiative Program (CIP), the Super Carrier Initiative Program (SCIP) and/or the Business Anti-Smuggling Coalition (BASC). Indicate that the specific detailed procedures noted above are available to Customs and Border Protection (CBP) in a verifiable format at an identified location upon request.

    •Include an assessment of your security processes, as well as information on what changes you envision making to correct identified weaknesses.

    •Identifying perceived weaknesses will not necessarily prohibit participation in C-TPAT. CBP is committed to working with you to identify effective, corrective measures and adjustments to your processes that will result in a more secure supply chain.