C-TPAT in 2007 — A Historical Page

It has been several years since we originally posted about C-TPAT. Here is one of our older (most likely outdated) pages of information.

The following is for historical reference from 2007.

What is Customs-Trade Partnership Against Terrorism (C-TPAT)?

C-TPAT is a voluntary government-business initiative to build cooperative relationships that strengthen and improve overall international supply chain and U.S. border security. C-TPAT recognizes that U.S. Customs and Border Protection (CBP) can provide the highest level of cargo security only through close cooperation with the ultimate owners of the international supply chain such as importers, carriers, consolidators, licensed customs brokers, and manufacturers. Through this initiative, CBP is asking businesses to ensure the integrity of their security practices and communicate and verify the security guidelines of their business partners within the supply chain.

U.S. Importers of record U.S./canada Highway Carriers U.S./mexico Highway Carriers Rail Carriers Sea Carriers Air Carriers U.S. Marine Port Authority/terminal Operators U.S. Air Freight Consolidators, Ocean Transportation Intermediaries and Non-Vessel Operating Common Carriers (NVOCC) Mexican and Canadian Manufacturers Certain Invited Foreign Manufacturers Licensed U.S. Customs Brokers

How were these trade participation categories selected?

CBP is responsible for screening all import cargo transactions. Utilizing risk management principles, C-TPAT seeks to enroll compliant low-risk companies who are directly responsible for importing, transporting, and coordinating commercial import cargo into the United States. The goal is to identify compliant trusted import traders who have good supply chain security procedures and controls to reduce screening of their imported cargo. In turn, this enables CBP to focus screening efforts on import cargo transactions involving unknown or high-risk import traders.

How do eligible companies apply to participate in C-TPAT?

Businesses must apply to participate in C-TPAT. Participants complete an online electronic application on www.cbp.gov that includes submission of corporate information, a supply chain security profile, and an acknowledgement of an agreement to voluntarily participate. In completing the supply chain security profile, companies must conduct a comprehensive self-assessment of their supply chain security procedures using the C-TPAT security criteria or guidelines jointly developed by CBP and the trade community for their specific enrollment category. The criteria or guidelines, available for review on the CBP website, encompass the following areas: Business Partner Requirements, Procedural Security, Physical Security, Personnel Security, Education and Training, Access Controls, Manifest Procedures, Information Security, and Conveyance Security.

A reduced number of CBP inspections (reduced border delay times) Priority processing for CBP inspections. (Front of the Line processing for inspections when possible.) Assignment of a C-TPAT Supply Chain Security Specialist (SCSS) who will work with the company to validate and enhance security throughout the company's international supply chain. Potential eligibility for CBP Importer Self-Assessment program (ISA) with an emphasis on self-policing, not CBP audits. Eligibility to attend C-TPAT supply chain security training seminars.

How will the partnership work on an ongoing basis?

Upon satisfactory completion of the C-TPAT Online application and supply chain security profile, participants will be assigned a CBP C-TPAT Supply Chain Security Specialist (SCSS). A SCSS will contact the participant to begin the C-TPAT validation process.

What happens if a company fails to meet the C-TPAT minimum security criteria or guidelines?

Failure to meet C-TPAT commitments will result in suspension or removal of C-TPAT certification status and associated benefits. Benefits may be reinstated upon correcting identified deficiencies in compliance and/or security.

C-TPAT information is maintained on the www.cbp.gov web site.

What exactly are CBP expectations for the C-TPAT participant?

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

Will the information our company provides to C-TPAT be confidential?

All information on supply chain security submitted by companies applying for the C-TPAT program will be confidential. CBP will not disclose a company's participation in C-TPAT.

As a company, we are very interested in C-TPAT but we are not interested in spending a lot of money or increasing our liabilities if something goes wrong. Is it still possible to participate in C-TPAT?

All eligible companies that import into the U.S. or provide import cargo movement or handling services should assess their supply chain security procedures to determine if they can qualify. CBP 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 criteria and 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, CBP would take action to suspend benefits or cancel participation.

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

CBP recognizes that a safe and secure supply chain is the most critical part of our work in keeping our country safe. For this reason, CBP 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 rooted in their business practices. CBP wants to work closely with companies whose good business practices ensure supply chain security and compliance with trade laws.

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

CBP encourages all companies to take an active role in promoting supply chain and border security. 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.

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

C-TPAT participation requires that a Carrier Initiative Program (CIP) participant implement and document specific C-TPAT supply chain security guidelines or criteria. CIP participants should 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.

In the less-than-truckload motor carrier environment, is each C-TPAT importer required to place a new ISO 17712 compliant seal on the trailer when the pickup and delivery (P&D) driver picks up freight?

Trailer and container integrity must be maintained to protect against the introduction of unauthorized material and/or persons. In the less-than-truckload, pickup and delivery environment, the use of a secured padlock or similar locking device is sufficient to meet the importer C-TPAT sealing requirements. Only a limited number of individuals should have access to open this padlock. However, after the freight from the P&D trucks is sorted, consolidated and loaded onto line haul trailers which are then destined to cross the U.S. border, these trailers must then be sealed with a high security seal which meets or exceeds the current PAS ISO 17712 standards for high security seals. Written procedures should stipulate how seals are controlled, to include procedures for recognizing and reporting compromised seals and/or trailers to CBP or the appropriate foreign authority. Only designated employees should distribute container seals for integrity purposes.

For trucking operations where a truck makes several pickups and then heads straight for the U.S. border, what kinds of sealing or locking devices will be required?

For P&D operations that do not use a hub to sort or consolidate freight prior to crossing the U.S. border, the importer and/or trucking company must use ISO 17712 high security seals for the trailer at each stop, and to cross the border. Written internal procedures must be in place to record the change in seals, as well as stipulate how seals are controlled and distributed, and how discrepancies are noted and reported. As CBP develops the minimum security criteria for truck carriers, this requirement will be discussed in greater detail and may or may not be modified.

What about tank trucks and flatbeds and other equipment that cannot be sealed?

Tank trucks and flatbeds hauling goods for C-TPAT importers that are incapable of being sealed do not need to be sealed or padlocked.

What other kinds of locking or sealing devices are acceptable for use by P&D drivers in an LTL environment?

The intent of this security element is to maintain the integrity of the trailer and prevent unauthorized access. CBP does not stipulate exactly what kind of device is required, but instead provides general criteria which affords the importer the flexibility in how to meet this standard.

Seals must be applied to the trailer to prevent and detect any unauthorized access.

Will CBP suspend or remove me from the C-TPAT program if I do not implement a sealing program for trailers destined for the United States?

Retaining membership in the C-TPAT program is contingent upon a continued, demonstrated commitment to enhancing supply chain security, and on meeting the outlined minimum security criteria. At present, only C-TPAT importers are governed by the minimum security criteria, but development of the minimum security criteria governing sea carriers, air carriers, and truck carriers is underway. Container security measures, including sealing requirements, are crucial aspects to supply chain security and C-TPAT members who do not adopt acceptable practices may be suspended. CBP will continue to work in partnership with members to address individual business models and company concerns. Any decisions to suspend or remove a C-TPAT member from the program are taken seriously, are only made by senior C-TPAT program managers, and are initiated only after discussions with the C-TPAT member have failed to resolve the security deficiency.

For More Information: Contact Industry Partnership Programs at (202) 344-1180 or fax (202) 344-2626 or email us, at industry.partnership@dhs.gov