Trade Community Upbeat on CBP Centers of Excellence and Expertise in Initial Survey

On May 2, 2013, in Compliance, Trade Compliance News, U.S. Customs Issues, by Martin Rayner

Trade community members who have utilized the Centers of Excellence and Expertise being opened by U.S. Customs and Border Protection have largely had a positive experience, according an initial survey of CEE users conducted in March. Just over half the 769 survey respondents identified themselves as importers, and the industries most represented among respondents were [...]

Trade community members who have utilized the Centers of Excellence and Expertise being opened by U.S. Customs and Border Protection have largely had a positive experience, according an initial survey of CEE users conducted in March. Just over half the 769 survey respondents identified themselves as importers, and the industries most represented among respondents were textiles, apparel and footwear; industrial and manufacturing materials; and consumer products and mass merchandising.

Of the nine percent of survey respondents who are currently CEE participating account members, 54% are also members of the Importer Self-Assessment program and 100% are participating in the Customs-Trade Partnership Against Terrorism. Three-quarters of these respondents said they were very satisfied, and over 96% had their issues resolved, after contacting a CEE. Most said they contact the CEEs a few times a year, often to discuss C-TPAT questions and procedures, and their primary trade facilitation concerns include cargo holds and CBP requests for information (CF-28s). In addition, most respondents said they have seen benefits such as fast shipment delay resolutions, direct contact with CBP and transparency into CBP requirements.

The survey revealed similar information on the 21% of respondents that are CEE non-participating account members. These respondents primarily contact CEEs about C-TPAT questions and procedures, CBP holds and release times, and exams, and their top trade facilitation concerns were also CF-28s and cargo holds. Nearly 20% reached out to CEEs on compliance issues and 61% of those said they received adequate assistance. Benefits cited included one-point contact and transparency into CBP requirements.

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CBP Unveils New C-TPAT System of Records

On March 13, 2013, in Compliance, Logistics & Supply Chain Management, U.S. Customs Issues, by Martin Rayner

The U.S. Department of Homeland Security has unveiled a proposal to establish a new Customs-Trade Partnership Against Terrorism system of records, known as the DHS/CBP-018 C-TPAT System of Records. This new system of records collects and manages information, including personally identifiable information, about prospective, ineligible, current or former trade partners in C-TPAT and other entities [...]

The U.S. Department of Homeland Security has unveiled a proposal to establish a new Customs-Trade Partnership Against Terrorism system of records, known as the DHS/CBP-018 C-TPAT System of Records.

This new system of records collects and manages information, including personally identifiable information, about prospective, ineligible, current or former trade partners in C-TPAT and other C TPAT Logo 2013 CBP Unveils New C TPAT System of Recordsentities and individuals in their supply chains. The system also collects and maintains information, including personally identifiable information, regarding members of a foreign government secure supply chain program that have been recognized by CBP through a mutual recognition arrangement or a comparable arrangement as being compatible with the program. The C-TPAT program provides a security link portal that allows partners and applicants to access and manage their information.

CBP notes that it is publishing this new system of records notice to notify the public about the system, permit trade partners access to the information they provide, and offer a description of how and where information is collected and maintained. The new system of records will be effective on April 12 unless comments are received that result in a contrary determination.

DHS has issued a separate notice in the Federal Register seeking input by April 12 on a related proposal that would exempt portions of this new system of records from one or more provisions of the Privacy Act because of criminal, civil and administrative enforcement requirements. CBP believes that these exemptions are needed to protect information relating to DHS activities from disclosure to subjects or others related to these activities.

Source: STR Trade Report

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U.S. and Mexico Sign Joint Work Plan for Mutual Recognition of Trusted Trader Programs

U.S. Customs and Border Protection (CBP) and Mexico’s Tax Administration Service (SAT) signed a Joint Work Plan yesterday that lays out the path to mutual recognition of the two countries’ Authorized Economic Operator programs: CBP’s Customs-Trade Partnership Against Terrorism (C-TPAT) and SAT’s New Certified Companies Scheme (NEEC). The plan, expected to be implemented in two [...]

U.S. Customs and Border Protection (CBP) and Mexico’s Tax Administration Service (SAT) signed a Joint Work Plan yesterday that lays out the path to mutual recognition of the two countries’ Authorized Economic Operator programs: CBP’s Customs-Trade Partnership Against Terrorism (C-TPAT) and SAT’s New Certified Companies Scheme (NEEC). The plan, expected to be implemented in two years, was signed by CBP Deputy Commissioner David V. Aguilar and SAT Director Aristóteles Nuñez Sánchez.

The Joint Work Plan lays out the path forward to mutual recognition between the two programs. Mutual recognition allows for companies enrolled in one program to receive reciprocal benefits from the other with the result of both further securing the international supply chain and facilitating trade between the United States and Mexico.

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 recognized that U.S. Customs and Border Protection 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.

Source: U.S. Customs & Border Protection Agency

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Annual C-TPAT Conference Closes

Unified Global Security: The Challenge Ahead U.S. Customs and Border Protection (CBP) hosted the annual Customs-Trade Partnership Against Terrorism (C-TPAT) conference last week to discuss the unified approach to securing the global supply chain and best practices to address challenges ahead. More than 1,200 participants from the private sector joined the conference which was held [...]

Unified Global Security: The Challenge Ahead

U.S. Customs and Border Protection (CBP) hosted the annual Customs-Trade Partnership Against Terrorism (C-TPAT) conference last week to discuss the unified approach to securing the global supply chain and best practices to address challenges ahead. More than 1,200 participants from the private sector joined the conference which was held in National Harbor, Md.
C TPAT Logo 2013 Annual C TPAT Conference Closes
“C-TPAT is really at the heart of where we are going with the country’s national effort on global supply chain security,” said CBP Acting Chief Operating Officer Thomas S. Winkowski. “The program allows us to work together to address risk at the earliest point of the supply chain process while expediting trade. It keeps our nation safe and promotes economic competitiveness.”

Richard Reed, deputy assistant to the president for Homeland Security, also shared his thoughts on the value of programs like C-TPAT for both government and industry to enhance not only the security of critical infrastructure, but also resiliency and response. Reed cited Hurricane Sandy as an example of the private/public partnership working hand-in-hand to re-constitute trade and travel at our ports of entry. Additional keynote speakers at the conference included CBP Acting Assistant Commissioner for the Office of Field Operations, Kevin K. McAleenan, who announced the selection of Ms. Lauren M. Kaufer as the new C-TPAT director.

After the 9/11 tragedy, the biggest challenge CBP faced was securing imports from terrorist infiltration via smuggling of weapons, terrorists, or weapons of mass effect. 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 recognized that U.S. Customs and Border Protection 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. The C-TPAT program is one layer in CBP’s multi-layered cargo enforcement strategy. Today, the program has nearly 10,500 members, 700 of which joined this past year.

Source: U.S. Customs & Border Protection Agency

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U.S., Taiwan Sign Mutual Recognition Arrangement on Supply Chain Security Programs

On December 4, 2012, in Compliance, International Trade, by Martin Rayner

The U.S. and Taiwan have signed an agreement under which they will recognize each other’s supply chain security programs. This is the seventh such mutual recognition arrangement the U.S. has signed, following partnerships with New Zealand, Canada, Jordan, Japan, Korea and the European Union. These agreements are designed to provide faster customs clearance for companies [...]

The U.S. and Taiwan have signed an agreement under which they will recognize each other’s supply chain security programs. This is the seventh such mutual recognition arrangement the U.S. has signed, following partnerships with New Zealand, Canada, Jordan, Japan, Korea and the European Union. These agreements are designed to provide faster customs clearance for companies that comply with specified practices.

A press release from U.S. Customs and Border Protection states that under this MRA the U.S. and Taiwan have agreed to mutual standards in Taiwan’s AEO program, which reportedly has more than 500 members, and C-TPAT, whose membership exceeds 10,000 companies. The arrangement also recognizes the compatibility between the two programs and acknowledges that each side will accept the security status of members of the other program.

Source: STR Trade Report

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CBP Reviews Import Trade Trends for First Half of FY 2012

On October 15, 2012, in U.S. Customs Issues, by Martin Rayner

U.S. Customs and Border Protection has issued a report on import trade trends for the first half of fiscal year 2012. Among other things the report includes the following statistics on import value, revenue, source countries, entry summaries, consignees, compliance rates and trade partnership programs for the period Oct. 1, 2011, through March 31, 2012. • total [...]

U.S. Customs and Border Protection has issued a report on import trade trends for the first half of fiscal year 2012. Among other things the report includes the following statistics on import value, revenue, source countries, entry summaries, consignees, compliance rates and trade partnership programs for the period Oct. 1, 2011, through March 31, 2012.

• total import value was $1.18 trillion, on pace to exceed the $2.27 trillion total for FY 2011;

• the percentages of imports that were of dutiable value (31%), conditionally free value (21%) and duty-free value (48%) were unchanged from FY 2011 and have varied only slightly over the past five years;

• total revenue collected was $19.1 billion and total duty collections were $15.3 billion, both on pace to exceed the FY 2011 totals;

• estimated under-collections totaled $149 million, compared with $342 million for all of FY 2011;

• antidumping duty deposits ($193 million) and countervailing duty deposits ($15 million) are both on pace to exceed FY 2011 totals ($329 million and $27 million, respectively);

• a total of 14.8 million entry summaries were filed (on pace to exceed the 29.5 million for FY 2011), the paperless entry summary rate edged up to 92.3%, and the paperless cargo rate fell slightly to 57.4%;

• over 500,000 entry summaries were filed in the Automated Commercial Environment, far exceeding the total for all of FY 2011, and one of every 15 entry summaries is now filed in ACE;

• the total number of consignees was 513,144, compared to 728,651 for FY 2011;

• the major transactional discrepancy trade compliance measurement rate was 97.7%, up from 96.7%;

• Importer Self-Assessment program: 1.6 million ISA entry summaries (11% of the total) covering $285 billion in import value (24% of the total), both on pace to exceed FY 2011 totals;

• Customs-Trade Partnership Against Terrorism: 3.5 million entry summaries filed (24% of the total) covering $361 billion in import value (31% of the total);

• $624 billion in import value was from the top five source countries, on pace to hit the highest annual total in five years; and

• $9 billion in duties were paid on imports from the top five duty-paying source countries (China, Japan, Germany, Vietnam and Indonesia).

Source: STR Trade Report

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CBP Expanding Eligibility for Importer Self-Assessment Program

On October 4, 2012, in Compliance, Strategy, Trade Compliance News, U.S. Customs Issues, by Martin Rayner

U.S. Customs and Border Protection has issued a general notice making the Importer Self-Assessment program (ISA) available to more participants. Effective immediately, a company that has successfully undergone a CBP Focused Assessment (FA) audit may be eligible to transition into ISA without further CBP review within 12 months from the date of the FA report wherein CBP [...]

U.S. Customs and Border Protection has issued a general notice making the Importer Self-Assessment program (ISA) available to more participants.

Effective immediately, a company that has successfully undergone a CBP Focused Assessment (FA) audit may be eligible to transition into ISA without further CBP review within 12 months from the date of the FA report wherein CBP has determined that the company represents an acceptable risk.  Under this policy any interested company that has successfully completed an FA in the last 12 months (i.e., since October 2011) may apply to transition into ISA.
High Quality CBP Expanding Eligibility for Importer Self Assessment Program
To qualify for ISA the company must be a U.S. or Canadian resident importer (CBP sources confirmed that Canadian resident companies that import into the U.S. are included in this description), obtain membership in the Customs-Trade Partnership Against Terrorism, develop a risk-based self-testing plan, and agree to meet all ISA requirements. The application review meeting normally conducted for ISA applicants will not be required.

ISA is a joint government-business initiative designed to build cooperative relationships that strengthen trade compliance. It is based on the premise that companies with strong internal controls achieve the highest level of compliance with customs laws and regulations. CBP states that benefits of participation in this program include removal from the audit pool established for Focused Assessment, expanded opportunity to file prior disclosures of certain violations, mitigation of civil penalties and liquidated damages, expedited cargo release, and priority consideration for applications to participate in the Centers of Excellence and Expertise tests.

CBP is proposing the change outlined in this notice because the FA is a more rigorous and thorough method of examining a company’s internal systems for compliance with customs laws and regulations than the ISA review process. The notice sets forth the process that companies that have successfully completed an FA can use to apply to transition into ISA, the requirements they will have to meet after making that transition, and the reasons a company may be removed from ISA.

Note: Sandler & Travis Trade Advisory Services will be conducting a webinar on ISA Oct. 23 to review the requirements and benefits of this program, including the newly expanded eligibility.

 

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Improvements Needed in C-TPAT Validation Process, Report Finds

The Department of Homeland Security’s Office of Inspector General issued recently a report identifying the need for certain improvements to U.S. Customs and Border Protection’s administration of the Customs-Trade Partnership Against Terrorism. C-TPAT requires participants to document and demonstrate their supply chain security procedures according to applicable security requirements. The Security and Accountability for Every [...]

The Department of Homeland Security’s Office of Inspector General issued recently a report identifying the need for certain improvements to U.S. Customs and Border Protection’s administration of the Customs-Trade Partnership Against Terrorism.
9967012 s 300x300 Improvements Needed in C TPAT Validation Process, Report Finds
C-TPAT requires participants to document and demonstrate their supply chain security procedures according to applicable security requirements. The Security and Accountability for Every (SAFE) Port Act of 2006 required CBP to review and certify security profiles within 90 days of submission, complete C-TPAT validations within one year of certification and revalidate within four years of the initial validation. To help implement this requirement CBP established standard operating procedures for its supply chain security specialists (SCSSs), who travel around the world to visit partners and their facilities to validate that supply chain security practices and procedures meet the program’s minimum security criteria and agreed-upon security standards.

The report finds, however, that the documentation maintained by SCSSs for the initial C-TPAT validation process for highway carriers did not always confirm the accuracy and effectiveness of security measures declared in a carrier’s security profile. In addition, SCSSs did not always follow the SOPs and did not include adequate details in the validation worksheet explaining how they verified evidence of implementation for critical business partner and conveyance security procedures. OIG also determined that SCSSs did not always conduct secondary vetting procedures to confirm that no significant customs violations had taken place, complete the initial validation within one year of certification, or obtain signed certification letters.

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U.S., Japan Pledge Closer Cooperation on Supply Chain Security

On May 9, 2012, in Compliance, International Trade, Logistics & Supply Chain Management, by Martin Rayner

Following a recent meeting of heads of state in Washington, the U.S. and Japan issued a joint statement  pledging closer cooperation on ensuring the security of global supply chains. Stating that “there is an urgent need to better address manmade and natural disruptions which could adversely impact our security, economic prosperity, and ways of life” [...]

Following a recent meeting of heads of state in Washington, the U.S. and Japan issued a joint statement  pledging closer cooperation on ensuring the security of global supply chains. Stating that “there is an urgent need to better address manmade and natural disruptions which could adversely impact our security, economic prosperity, and ways of life” while also facilitating trade, the two countries said they intend to take the following bilateral actions.
US Japan Quotes U.S., Japan Pledge Closer Cooperation on Supply Chain Security
• enhance the trade facilitation benefits provided to members of the Customs-Trade Partnership Against Terrorism and Japan’s authorized economic operator program

• accelerate discussions on an air cargo security mutual recognition arrangement

• coordinate capacity•building in the Asia•Pacific region to strengthen border, port, maritime and aviation security, within existing resources

• support the development and deployment of new technologies to enhance global supply chain security

• pursue joint counterproliferation investigations through relevant law enforcement agencies

• promote dialogue, information exchange and sharing of best practices between public and private sectors

The joint statement also commits the U.S. and Japan to multilateral efforts within the World Customs Organization, the International Civil Aviation Organization, the International Maritime Organization, the Universal Postal Union and the Asia-Pacific Economic Cooperation forum on global supply chain issues, including the following.

• supporting the development and maintenance of risk management guidelines

• assisting in the development of robust global pre•departure information requirements in alignment with the discussions on the WCO SAFE Framework of Standards

• developing common definitions, standards and recommended practices for high-risk air cargo

• actively reporting shipping information and intelligence through the WCO’s Global Shield program and facilitating the expansion of regional participation in this program

• advancing the development of AEO programs consistent with the WCO SAFE Framework of Standards

• guiding the establishment of international standards for trade recovery collaboration and information requirements

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EU-US Mutually Recognize ‘Safe Traders’

The EU and the United States of America formally agreed to recognise each other’s safe traders, thereby allowing these companies to benefit from faster controls and reduced administration for customs clearance, as a result of a mutual recognition decision signed by both parties. EU and U.S. certified trusted traders will enjoy lower costs, simplified procedures [...]

The EU and the United States of America formally agreed to recognise each other’s safe traders, thereby allowing these companies to benefit from faster controls and reduced administration for customs clearance, as a result of a mutual recognition decision signed by both parties. EU and U.S. certified trusted traders will enjoy lower US EU Connection 126x300 EU US Mutually Recognize ‘Safe Traders’costs, simplified procedures and greater predictability in their transatlantic activities. Mutual recognition will also improve security on imports and exports, by enabling customs authorities to focus their attention on real risk areas.

What this means in practical terms is that the U.S.-EU Mutual Recognition Decision officially recognizes the compatibility of the U.S. Customs-Trade Partnership Against Terrorism (C-TPAT) and the EU’s Authorized Economic Operator (AEO) program. USCIB has long encouraged an agreement between the U.S. and EU that would recognize compatibility between the U.S. and EU cargo security programs.

There are currently some five thousand companies approved as Authorised Economic Operators (AEOs) in the EU – a number which is growing year on year. The EU and USA are strategic trade partners, with imports and exports accounting for almost €500 billion in 2011. The joint decision will start to be implemented from 1 July 2012.

Commissioner Semeta said: “[The] agreement is a major step forward in the EU-U.S. trade relationship. At a time when businesses need all the support they can get, this will make life easier and cheaper for many transatlantic traders. It will also help to ensure that security checks on traded goods are more focussed and effective, further improving the protection that customs provides for each and every citizen.”

Vice President of Government and Trade Relations with HanesBrand, Inc., and chair of USCIB’s Customs and Trade Facilitation Committee Jerry Cook said: “We congratulate CBP and the EU Taxation and Customs Union Directorate for delivering on the commitment of a mutual recognition agreement, and for continuing to build working partnerships of responsible industry leaders, governments and citizens.”

Expressing this sentiment, U.S. Ambassador to the EU William Kennard tweeted that the signing of the accord was an “Important step toward securing, facilitating trade.”

Mutual recognition of trade partnership programs prevents the proliferation of incompatible standards, and promotes harmonisation of customs practices and procedures worldwide.

Source: New Europe Online

 

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CBP: A Year of Merging Security and Prosperity

Following is the feature article from the CBP FY 2011 Report on Import Trade Trends Say the words, “September 11, 2001,” and images of death and destruction come immediately to mind. With nearly 3,000 people killed in those terrorist attacks, on that day “the highest priority became preventing terrorists and terrorist weapons from entering our [...]

Following is the feature article from the CBP FY 2011 Report on Import Trade Trends

Say the words, “September 11, 2001,” and images of death and destruction come immediately to mind. With nearly 3,000 people killed in those terrorist attacks, on that day “the highest priority became preventing terrorists and terrorist weapons from entering our country,” then-U.S. Customs Service Commissioner Robert C. Bonner said.

Less visible, but with longer-term effects, was the attacks’ crippling impact on the U.S. economy. By driving two passenger planes into the twin towers — targeting the financial capital of the U.S.—al-Qaida symbolically targeted not only Americans, but the American way of life, specifically travel and trade. A 2002 Congressional Research Service report noted that the long-term costs of increased security would likely be “greater impediments to the free movement of goods, services, and capital….(which) have contributed immeasurably to the integration of the world economy and its efficient functioning.”
Money Security CBP: A Year of Merging Security and Prosperity
After the founding of U.S. Customs and Border Protection in 2003, responding to terrorism effectively became a thorny challenge for the agency charged with defending America’s borders. On the one hand, total vigilance would seem to demand virtually closing down the borders for a total inspection of every person, package and container coming through. As one CBP officer remarked, “I don’t want to be the one responsible for letting someone in [who would go on to commit an attack].”

Yet if nothing and no one can enter the country without a full, hands-on inspection, the terrorists would win a shattering victory of another kind. The dual imperatives to keep dangerous people and things out while allowing legitimate travel and trade to flow in led agency officials to adopt the phrase, “a balanced approach to security and facilitation.” It became almost axiomatic that these two goals were opposed, in a sense, and that managing them was a delicate dance. Leaders of the agency tried to reassure the trade in particular that security would not trump competitiveness. In 2006, then-Commissioner W. Ralph Basham articulated a CBP theme of increasing importance, that security could be a win for industry.

In his words, “Companies are realizing collateral benefits from improved security…and are moving more goods across international borders faster and more efficiently.”

Intuitively, the mission of revenue collection does not exactly mesh with the enforcement of border security. When CBP Commissioner Alan D. Bersin assumed leadership in 2010, the contradiction dissolved completely. As he stated to the U.S. Chamber of Commerce in 2011, “At CBP, we believe security and facilitation of international travel and trade are actually the same phenomenon.”

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CBP Report Outlines Costs, Savings Associated with C-TPAT Program

On March 12, 2012, in Compliance, Logistics & Supply Chain Management, by Martin Rayner

U.S. Customs and Border Protection posted to its Web site recently its 2011 C-TPAT Costs & Savings Survey.  CBP concludes from the review that C-TPAT “has become a vital part of supply chain security in the post-9/11 world” and that the program membership “continues to be a critical source of feedback and recommendations for improvement.” CBP [...]

U.S. Customs and Border Protection posted to its Web site recently its 2011 C-TPAT Costs & Savings Survey.  CBP concludes from the review that C-TPAT “has become a vital part of supply chain security in the post-9/11 world” and that the program membership “continues to be a critical source of feedback and recommendations for improvement.”

CBP states that the “overarching theme” of this survey is that “the value of C-TPAT membership cannot be measured adequately in terms of dollars and cents.” On the one hand, there are indeed implementation costs and maintenance costs, which are offset by savings in only a minority of cases.
Cost Savings CBP Report Outlines Costs, Savings Associated with C TPAT Program
In addition, a “non-ignorable minority of respondents” said they have not seen the expected improvements in processes that impact their profitability, such as faster border crossings, front-of-the-line programs and less-frequent inspections. At the same time, CBP said, “it is clear that C-TPAT members take pride in their membership, see it as an industry best practice and value it for reasons that go beyond a purely monetary frame of reference.” These reasons include a best-practice approach to security issues that creates a business culture of more secure operations for all and constant improvements in security, the assurance that shipments will move predictably, reduced exposure to legal or financial risk, and the indirect benefits of efficiency and safety resulting from security activities that reveal equipment or personnel issues that do not directly impact security.

Other information revealed through this survey includes the following.

• Small numbers of importers and carriers reported their estimates of the costs of border delays in four different modes of transport. The median costs were $200 for land delays, $500 for air delays, $1,000 for rail delays and $1,500 for sea delays.

• CBP asked what percentage of contracts for supply chain relationships these days require bidders to be C-TPAT certified. Eight percent of respondents said all of them while 9% said none. About 40% of respondents put the figure between 1% and 45% and about 30% said it was between 50% and 99%.

• For the 75% of respondents who reported a dollar value for implementation costs related to C-TPAT membership, those costs ranged from $280 to $4 million, with a median of $17,370. For the 62% who reported a dollar value for maintenance costs, those costs ranged from $45 to $815,000, with a median of $9,000.

• For the 26% of respondents who reported a number of person-hours for time savings related to C-TPAT membership, those savings ranged from 25 to 48,000 person-hours annually with a median of 373. For the 24% who reported a dollar value for cost savings, those savings ranged from $50 to $52 million, with a median of $5,350.

• Asked to summarize the financial costs and savings related to C-TPAT membership as net positive, neutral or net negative, respondents fell about equally into each category.

Source: STR Trade Report
 

C-TPAT Budget-Saving Plans

On February 29, 2012, in Compliance, Logistics & Supply Chain Management, by Martin Rayner

Extending the re-validation cycle for companies in the Customs-Trade Partnership Against Terrorism by a year will not adversely impact supply chain security, according to Shawn Beddows, the U.S. Customs official directly in charge of the program. The Obama administration’s budget plan for fiscal year 2013 calls for a $5 million reduction in C-TPAT spending, with [...]

Extending the re-validation cycle for companies in the Customs-Trade Partnership Against Terrorism by a year will not adversely impact supply chain security, according to Shawn Beddows, the U.S. Customs official directly in charge of the program.

The Obama administration’s budget plan for fiscal year 2013 calls for a $5 million reduction in C-TPAT spending, with the money diverted instead to pay for frontline inspection operations. Most of the savings are to be achieved by scheduling follow-on verifications of trusted shippers’ supply chain security practices every four years, instead of three. […]
C TPAT Logo C TPAT Budget Saving Plans
Another possible change to C-TPAT is the addition of an export component. CBP officials, acquiescing to private sector demands for a program that would make it easier to comply with the cargo security programs of foreign governments, in recent months have said they are contemplating a security program for exporters.

Customs is expected to consider several approaches for export verification, including flipping the C-TPAT import criteria to exports or using a security checklist that is equivalent to ones used by European Union governments for their Authorized Economic Operator programs. Read more here (subscription required).

Source: Eric KulischAmerican Shipper Magazine

Delayed Implementation of New Mechanical Seal Standard for Cargo Containers

On February 17, 2012, in Compliance, Logistics & Supply Chain Management, U.S. Customs Issues, by Martin Rayner

U.S. Customs and Border Protection (CBP) informed members of the Customs-Trade Partnership Against Terrorism (C-TPAT) Feb. 15  that implementation of the updated International Organization for Standardization (ISO) mechanical seal standard will not be viable by March 1 as previously announced. CBP has learned that the tamper evidence element (clause 6) of the new standard (ISO [...]

U.S. Customs and Border Protection (CBP) informed members of the Customs-Trade Partnership Against Terrorism (C-TPAT) Feb. 15  that implementation of the updated International Organization for Standardization (ISO) mechanical seal standard will not be viable by March 1 as previously announced. CBP has learned that the tamper evidence element (clause 6) of the new standard (ISO 17712:2010) cannot be met and that to date no accredited independent laboratories have been willing to test and certify seals as complying with this requirement. While the ISO is working to resolve this issue, implementation of the new standard will be delayed until CBP receives definitive information that this has been accomplished.

CBP notes that since the ISO 17712: 2010 (18 mm) certification for high-security seals is attainable without the clause 6 testing portion of the standard, C-TPAT partners are encouraged to buy seals that meet this part of the standard. If they do so, however, they should request documentation to confirm that the purchased seals comply with the current testing requirements for ISO 17712: 2010 (18 mm) certification.

Source: STR Trade Report
 

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New Mechanical Seal Standard for Cargo Containers Takes Effect March 1

On February 14, 2012, in Compliance, Logistics & Supply Chain Management, U.S. Customs Issues, by Martin Rayner

U.S. Customs and Border Protection recently advised members of the Customs-Trade Partnership Against Terrorism that effective March 1 the current International Organization for Standardization (ISO) mechanical seal standard (ISO/PAS 17712) will be replaced with new standard ISO 17712:2010. CBP is not requiring C-TPAT participants to discard any high-security container seals that may not comply with [...]

U.S. Customs and Border Protection recently advised members of the Customs-Trade Partnership Against Terrorism that effective March 1 the current International Organization for Standardization (ISO) mechanical seal standard (ISO/PAS 17712) will be replaced with new standard ISO 17712:2010.

CBP is not requiring C-TPAT participants to discard any high-security container seals that may not comply with the new standard that are currently in stock but is encouraging them to purchase compliant seals when their existing stocks are exhausted. CBP also states that when C-TPAT companies transition to new seals they should request documentation (lab reports) to confirm that the seals comply with the new standard.
ISO Compliant Mechanical Seals New Mechanical Seal Standard for Cargo Containers Takes Effect March 1
CBP states that the updated standard includes the following requirements: testing to determine a seal’s classification for physical strength (as a barrier of entry), process auditing of the manufacturer’s security-related business practices, testing (pass/fail) of a seal’s ability to indicate evidence of tampering, and a new 18mm minimum width diameter for bolt seals.

CBP adds that benefits of complying with the revised standard include a reduced possibility of cargo theft or tampering, fewer shipping delays resulting from missing or broken seals, and easier detection of compromised seals.

Source: STR Trade Report
 

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EU-U.S. ‘Trusted Trader’ Customs Agreement Reached

On December 1, 2011, in Compliance, International Trade, Trade Compliance News, by Martin Rayner

A new EU-US agreement that aims to simplify and speed up customs procedures for shipments of goods crossing the Atlantic was finalized at the Transatlantic Economic Council (TEC) in Washington DC, on November 29th. The agreement, several years in the making, requires both sides to mutually recognize each other’s ‘trusted trader’ programs that cover some [...]

A new EU-US agreement that aims to simplify and speed up customs procedures for shipments of goods crossing the Atlantic was finalized at the Transatlantic Economic Council (TEC) in Washington DC, on November 29th.

The agreement, several years in the making, requires both sides to mutually recognize each other’s ‘trusted trader’ programs that cover some 4,600 EU businesses and 10,000 US firms. The mutual recognition arrangement will essentially treat the United States’ Customs-Trade Partnership Against Terrorism and the EU’s Authorized Economic Operator program as equivalent.
Transatlantic Handshake EU U.S. ‘Trusted Trader’ Customs Agreement Reached
The final sticking point to be resolved concerned data protection rules. The accord becomes operational once the information technology systems are in place and “no later than June 2012,” said the EU’s Taxation and Customs Union Commissioner Algirdas Semeta at the conclusion of the TEC, which the U.S. State Department hosted.

The TEC was set up in 2007 to guide and stimulate transatlantic economic convergence. The regulatory work of the TEC focuses on economically relevant issues of mutual interest, in order to identify issues where EU-U.S. cooperation could produce results in a reasonable time horizon and to engage in a strategic discussion on selected global economic issues.
 

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Free Webcast: New ‘Trusted Shipper’ Program in Mexico

On November 24, 2011, in Compliance, Events, International Trade, Logistics & Supply Chain Management, by Martin Rayner

Earlier this year, Mexican Customs (Administración General de Aduanas) began a pilot for its new trusted shipper program designed to accelerate the crossing and inspection process at international bridges. The Nuevo Esquema de Empresas Certificadas, or NEEC, is a voluntary trusted shipper program that offers participating companies fewer inspections and faster clearances for meeting specified [...]

Earlier this year, Mexican Customs (Administración General de Aduanas) began a pilot for its new trusted shipper program designed to accelerate the crossing and inspection process at international bridges.
The Nuevo Esquema de Empresas Certificadas, or NEEC, is a voluntary trusted shipper program that offers participating companies fewer inspections and faster clearances for meeting specified requirements at international ports of entry.
Mexican Border Crossing Free Webcast: New ‘Trusted Shipper’ Program in Mexico
The program is modeled after the U.S. C-TPAT (Customs-Trade Partnership Against Terrorism) certification program that allows bridge-crossers to use the FAST lanes, skipping to the front of long lines and potentially bypassing time-consuming inspections. Short for Free and Secure Trade, the post-9/11 program was a joint effort between the U.S. government, the truck driver, the carrier, the manufacturer and the importer.

While C-TPAT has been in place for northbound traffic from Mexico since 2002, there has not been a similar program for southbound traffic. The Tax Administration Service, or SAT, the Mexican agency that oversees customs, worked to develop its own program; one that U.S. trade officials say will benefit trucks carrying U.S. exports across the border.

The NEEC, program is expected to officially open up to all interested participants later this month. Companies with business operations in Mexico that are already C-TPAT certified will be well positioned to take advantage of participation in NEEC – but is your company ready for this?

To find out more about the NEEC and if your company is ready to participate, join Karen Lobdell, Director – Global Solutions at Integration Point Inc. for a one-hour webcast on November 30th, as she discusses:

• Program history and objectives
• Requirements for participation
• Minimum security standards
• Application procedures and scope
• Next steps
• Tools available to assist with participating in the NEEC and other security programs

This webcast will be held on Wednesday, November 30, 2011 at 11:00 a.m. EST/ 8:00 a.m. PST.

For more information and to register, click here.
 

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Steering Through Canadian Cabotage Laws

On November 4, 2011, in Compliance, Logistics & Supply Chain Management, by Martin Rayner

In August 2011 the Canada Border Services Agency (“CBSA”) issued a notice on the enforcement of cabotage laws restricting the movement of domestic goods by foreign-based commercial transportation businesses. If officials have not have strictly enforced the laws in the past, this may be changing. Consequences for non-compliance include detentions, the assessment of duties, taxes, [...]

In August 2011 the Canada Border Services Agency (“CBSA”) issued a notice on the enforcement of cabotage laws restricting the movement of domestic goods by foreign-based commercial transportation businesses. If officials have not have strictly enforced the laws in the past, this may be changing.

Consequences for non-compliance include detentions, the assessment of duties, taxes, interest, penalties, cancellation of a carrier’s enrolment trusted trader programs such as Free and Secure Trade and Customs Self Assessment, forfeiture, ascertained forfeiture and/or criminal liability.

This article by Daniel L. Kiselbach of Miller Thomson LLP describes what commercial trucking and transportation businesses need to know about Canada’s cabotage laws.

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Logistics Security & Trade Compliance

On September 26, 2011, in Compliance, Logistics & Supply Chain Management, Strategy, by Martin Rayner

Earlier this month, Simon Kaye, CEO of Jaguar Freight Services, a New York based supply chain solution provider (or “freight architect” as the company somewhat fancifully styles itself), wrote a very incisive piece on the IFW website broadly describing the contours of today’s security environment relative to logistics. Essentially, the gist of his article was [...]

Earlier this month, Simon Kaye, CEO of Jaguar Freight Services, a New York based supply chain solution provider (or “freight architect” as the company somewhat fancifully styles itself), wrote a very incisive piece on the IFW website broadly describing the contours of today’s security environment relative to logistics. Essentially, the gist of his article was that companies which fail to incorporate the most advanced technology and standardized security processes into their supply chain leave themselves needlessly vulnerable to the growing risk of cargo theft (see footnote below).

To combat the problem, Kaye recommended that companies implement a formal methodology such as the comprehensive and widely accepted International Organization for Standardization (ISO) 28000 framework for dealing with supply chain security management combined with deployment of the required technology needed to ensure its practical efficacy. Depending on circumstance, this technology may involve sophisticated electronic tracking and “geofencing” systems utilizing RFID and GPS technology or the implementation of more basic physical security devices such as communication enhanced electronic seals.

Aside from the obvious benefit of curtailing the risk of loss from theft that may be derived from taking such security precautions, Kaye also pointed out the important linkage that has developed in recent years between logistics security and customs compliance as regulatory agencies in North America and around the world increasingly utilize electronic communication between customs and business users to correlate and verify import/export declaration data.

Sophisticated technology is integral to unified customs/security processes for many major importing countries. The U.S. Customs and Border Protection agency (CBP) has created an Importer Security Filing (ISF) on maritime cargo that requires importers to submit advance security-related shipment information electronically, including detailed line item identification.

Similarly CBP’s Customs-Trade Partnership Against Terrorism (C-TPAT) is a cooperative cargo security effort encompassing the full supply-chain to ensure the integrity of security practices, and communicate and verify shipment information electronically. And U.S. government standards mandate 100% security screening of all cargo transported on aircraft, with select forwarders approved by the Transportation Security Administration (TSA) to use electronics to document the integrity of a shipment through stringent chain of custody methods.

With respect to trade compliance, Kaye’s conclusion is most pertinent to us here:

The international economy relies on the secure and efficient movement of goods through an increasingly extended multimodal transport system. The information required by ISO standards and complex customs regulations demands that shippers and logistics companies use sophisticated electronic tools. Government security and customs agencies are generally in synch with logistics organizations that know how to collect freight tracking and compliance data in a way that creates a provable, thorough and secure electronic trail.

That last sentence (highlighted for effect) is not only critically important to appreciating the mindset of regulatory administrations as regards to determining what constitutes a “trusted trader” for the purposes extending preferential customs treatment and expedited release at the border, but is essential for companies to take on board as a best practice when it comes to minimizing their exposure to risk by means of verifiable compliance standards and accountability measures.

Footnote: According to FreightWatch’s 2010 Annual Cargo Theft Report, industry-wide cargo theft rose by 4.1% in 2010. The food and beverage industry was the hardest hit, accounting for nearly 21% of the total theft activity, with an average loss value of $125,000 per incident. Electronics accounted for 19% of all cargo theft with an average loss per incident of $512,000.
 

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C TPAT and the Supply Chain

On April 5, 2011, in Videos, by Nigel Fortlage

Courtesy of Supply Chain Brain This is a great video from Supply Chain Brain where they interview a security specialist about the importance of C-TPAT in the supply chain. You must have established a FREE account with Supply Chain Brain in order to view this video. Link to CTPAT Video from Supply Chain Brain

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Courtesy of Supply Chain Brain

This is a great video from Supply Chain Brain where they interview a security specialist about the importance of C-TPAT in the supply chain.

You must have established a FREE account with Supply Chain Brain in order to view this video.

Link to CTPAT Video from Supply Chain Brain

pixel C TPAT and the Supply Chain
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