C-TPAT Explained 

  The U.S. Customs Service recently announced an anti-terrorism move that could also allow for faster clearing of commercial cargo through border checkpoint. Known as the Customs-Trade Partnership Against Terrorism, or C-TPAT, the initiative allows participating companies to cross goods into the United States on an expedited manner.

The U.S. Customs Service provides the following questions and answers about C-TPAT.

What is C-TPAT?

  C-TPAT is a joint government-business initiative to build cooperative relationships that strengthen overall supply chain and border security. C-TPAT recognizes that Customs can provide the highest level of security only through close cooperation with the ultimate owners of the supply chain— importers, carriers, brokers, warehouse operators and manufacturers. Through this initiative, Customs is asking businesses to ensure the integrity of their security practices and communicate their security guidelines to their business partners within the supply chain.

What does participation in C-TPAT require?

  Businesses must apply to participate in C-TPAT. Participants will sign an agreement that commits them to the following actions:

  •Conduct a comprehensive self-assessment of supply chain security using the C-TPAT security guidelines jointly developed by Customs and the trade community. These guidelines, which are available for review on the Customs website, encompass the following areas: procedural security, physical security, personnel security, education and training, access controls, manifest procedures, and conveyance security.

  •Submit a supply chain security profile questionnaire to Customs.

  •Develop and implement a program to enhance security throughout the supply chain in accordance with C-TPAT guidelines.

  •Communicate C-TPAT guidelines to other companies in the supply chain and work toward building the guidelines into relationships with these companies.

What are the benefits of participation in C-TPAT?

  C-TPAT offers businesses an opportunity to play an active role in the war against terrorism. By participating in this first worldwide supply chain security initiative, companies will ensure a more secure supply chain for their employees, suppliers and customers. Beyond these essential security benefits, Customs will offer potential benefits to C-TPAT members, including:

  •A reduced number of inspections (reduced border times).

  •An assigned account manager (if one is not already assigned).

  •Access to the C-TPAT membership list.

  •Eligibility for account-based processes (bimonthly/monthly payments, e. g.).

  •An emphasis on self-policing, not Customs verifications

Who is eligible for C-TPAT?

  C-TPAT is currently open to all importers. Customs plans to open enrollment to a broader spectrum of the trade community in the near future. C-TPAT membership will be made available to all sectors of the supply chain. Customs will be consulting with the trade community to develop the most effective approach for each sector to participate in C-TPAT.

How do I apply?

  Applicants will submit signed agreements to Customs, which will represent their commitment to the C-TPAT security guidelines. Applicants will also submit a supply chain security profile questionnaire at the same time they submit their signed agreements or within a specified time thereafter.

When will benefits begin?

  Benefits will begin once Customs has completed an evaluation of the importer’s C-TPAT application package and notified the importer of its findings. Customs aims to complete these evaluations within 30-60 days after the supply chain security questionnaire has been submitted.

How will the partnership work on an ongoing basis?

  Account managers will contact participants to begin joint work on establishing or updating account action plans to reflect C-TPAT commitments. Action plans will track participants’ progress in making security improvements, communicating C-TPAT guidelines to business partners, and establishing improved security relationships with other companies. Failure to meet C-TPAT commitments will result in suspension of C-TPAT benefits. Benefits will be reinstated upon correcting identified deficiencies in compliance and/or security.

What exactly are Customs expectations for the trade on this program?

  To make a commitment toward the common goal of creating a more secure and efficient supply chain through partnership. Customs understands that it has entered a new era and requires the assistance of private industry to ensure increased vigilance throughout the supply chain. Customs recognizes businesses must ensure that their brands, employees, and customers are protected to the best of their abilities.

Will the information our company provides be confidential?

  All information on supply chain security submitted by companies applying for the C-TPAT program will be confidential. Customs will not disclose a company’s participation in C-TPAT without the company’s consent.

Is it still possible to do this partnership?

  Yes. Customs intent is to not impose security requirements that will be cost prohibitive. For this reason, we worked in concert with the trade community in developing security guidelines that reflect a realistic business perspective. Potential C-TPAT participants may find that they already have many of these guidelines in place. C-TPAT is also not intended to create any new liabilities for companies beyond existing trade laws and regulations. However, joining C-TPAT will commit companies to follow through on actions specified in the signed agreement. These actions include self-assessing security systems, submitting security questionnaires, developing security enhancement plans, and communicating C-TPAT guidelines to companies in the supply chain. If a company fails to uphold its C-TPAT commitments, Customs would take action to suspend benefits or cancel participation.

What is the overall vision for C-TPAT in the coming months and years?

  Customs recognizes that a safe and secure supply chain is the most critical part of its work in keeping our country safe. For this reason, Customs is seeking a strong anti-terrorism partnership with the trade community through C-TPAT. Trade partners will have a commitment to both trade security and trade compliance, which are rooted in the same business practices. Customs wants to work closely with companies whose good business practices ensure supply chain security and compliance with trade laws.

How will audits work in the future?

  Audits will continue to be used to assess overall trade compliance. Customs Regulatory Audit will apply the new Focused Assessment methodology, a risk-based audit program, in conducting these audits. Companies will not be required to undergo a Focused Assessment in order to participate in C-TPAT. However, to take advantage of Customs Regulatory Audit Importer Self-Assessment (ISA) program, importers must be C-TPAT participants.

As a carrier, I already participate in the Customs Carrier Initiative — is it a duplication of effort in joining C-TPAT?

  Customs will be looking for carriers to join C-TPAT to enhance existing security practices and better address the terrorism threat to international air, sea, and land shipping. It will work to ensure that C-TPAT participation does not require duplicate work for current Customs Carrier Initiative Program (CIP) participants. CIP participants already subscribe to the importance of security from a narcotics-smuggling perspective and are well positioned to expand their security focus to encompass anti-terrorism.

Is the C-TPAT program a viable consideration for medium or small size companies?

  C-TPAT is designed for the entire trade community and Customs encourages all companies to take an active role in promoting supply chain and border security. While the benefits of C-TPAT are greatest for large companies that rely heavily on international supply chains, C-TPAT is not just a big-company program. Medium and small companies may want to evaluate the requirements and benefits of C-TPAT carefully in deciding whether to apply for the program. Moreover, even without official participation in C-TPAT, companies should still consider employing C-TPAT guidelines in their security practices.