International Trade Law News

U.S. Customs and Border Protection (CBP) today issued an overview and assessment of the operations of the Customs-Trade Partnership Against Terrorism (C-TPAT) program in 2007.

The year end review contained the following statistics regarding the C-TPAT program during calendar year 2007:

• Supply chain security specialist visited manufacturing and logistics facilities in 79 countries, representing some of the most terrorist prone and high risk areas of the world.
• C-TPAT validated 3,011 supply chains, representing a 27 percent increase from 2006. Of the 3,011 validations conducted, 601 or 20 percent were revalidations. This was the first year that C-TPAT began re-verifying supply chains.
• C-TPAT certified 2,601 new members in accordance with SAFE Port Act requirements.
• C-TPAT Tier III status was granted to 17 companies as a result of the validation process.
• C-TPAT suspended or removed 112 companies from the program for security breaches or failure to meet C-TPAT's minimum security criteria as revealed in the validation process. Of the 112 companies, 47 were either conditionally or fully reinstated in the C-TPAT program after they demonstrated to CBP's satisfaction that immediate and sustained corrective action had been taken.

Labels: C-TPAT, Customs

U.S. Customs and Border Protection (CBP) today announced the names of the companies that have been selected to serve as third party validators in the Third Party Validation Pilot Program for purposes of conducting supply chain validations under the Customs Trade Partnership Against Terrorism (C-TPAT) in China. This one-year pilot program was necessary since the Chinese government has denied CBP’s request to allow CBP employees from performing validations in China. This program marks the first time that C-TPAT supply chain validations will be performed by commercial entities.

The following companies have been chosen by CBP to perform validations on CBP selected C-TPAT participants with operations in China:

• ABS Group
  
• CSCC/STR
  
• Cotecna
• Det Norske
• Veritas
  
• Intertek
• Omega Compliance
• Pinkerton
  
• Sharp Global
  
• SGS North America
• TUV Rheinland
  

Labels: C-TPAT, China, Customs

U.S. Customs and Border Protection has recently posted on its website a number of Frequently Asked Questions (FAQs) on the Customs-Trade Partnership Against Terrorism (C-TPAT) program. The FAQs include some basic information on the "benefits" of participation in C-TPAT for importers and carriers.

Labels: C-TPAT, Customs

U.S. Customs and Border Protection has published the minutes of the May 15, 2007 meeting of the Commercial Operations Advisory Committee (COAC). The highlights of the meeting included:

• CBP continues to move forward with the Security Filing initiative, also known “10+2”. CBP's Office of Regulations and Rulings has completed its initial work on developing the draft Notice of Proposed Rule Making and CBP is reviewing that document internally. CBP does not yet know when the formal notice will be published in the Federal Register.

• With respect to C-TPAT, CBP reported that currently there are 7,031 certified members and all new applicants are being reviewed within 90 days, as required by SAFE Port Act. CBP has completed 4,200 validations and anticipates completing the 3,000 remaining validations by the end of the year. [This does not include the approximately 300 importers who source 75% or greater from China. These 300 importers are currently confined to C-TPAT Tier 1 and receiving minimum level of benefits since the Chinese government has denied CBP’s request to allow U.S. CBP specialists from performing validations in China.]
  

• CBP is working with the COAC supply chain security subcommittee on a proposal to utilize C-TPAT third party validators. An announcement of the best-qualified validator firms is expected soon.

• The COAC provided comments that were highly critical of the draft version of the Department of Homeland Security's “Strategy to Enhance International Supply Chain Security”, which is required by Sections 201 and 202 of the SAFE Port Act. Specifically, the COAC comments stated that "we do not believe the plan is actionable. A good plan should provide a clear set of instructions that are specific as to roles, responsibilities and actions to be taken. It should be a blue print that can be referred to in both planning and execution. The plan as written is general and very high level in describing roles and responsibilities. Until the detail is populated, we do not believe the plan is useful." The COAC's comments in Word format can be found at the following link.

• CBP is developing C-TPAT criteria for Mexican Long-Haulers and reviewing Third Party Logistics Providers minimum-security criteria.

• CBP has created the Unified Business Resumption Message (UBRM) service in order to advise the trade community in the U.S and Canada in the event of an incident that affects the flow of trade. Interested persons can subscribe to the UBRM via a RSS feed on the CBP website. [Note, the easiest way to subscribe to a RSS feed is via a news reader, such as Google Reader.]
  

• The next COAC meeting will be held in Washington, DC on August 16, 2007.

Labels: C-TPAT, Customs

U.S. Customs and Border Protection has announced that it will hold a C-TPAT Supply Chain Security Training Seminar from April 3-7, 2007 in New Orleans. The program is open to certified C-TPAT members only.

According to CBP, the program will include joint Customs/Trade presentations, panel discussions and concurrent workshops on a number of supply chain security topics.

Registration will be conducted via an on-line registration process beginning January 15, 2007. Click the following link for more details on the program.

Labels: C-TPAT, Customs