November 26, 2002

It looks as if the Customs Service is making another big push to sign up importers for its C-TPAT program (Customs-Trade Partnership Against Terrorism). 

While the C-TPAT program is said to be “voluntary”, Customs is clearly turning up the pressure on importers to join.  In its newest effort, local Customs offices around the country are sending importers Requests For Information; known as CF 28’s.  These official requests are requiring importers to provide Customs with information about the company’s supply chain security, and whether the company has evaluated its supply chain security in light of the C-TPAT recommendations suggested by Customs.  The form also asks importers whether they have taken any steps to make sure that their vendors and service providers have implemented supply chain security procedures as recommended by Customs.

For those interested, here’s how to answer the forms.  Typically, U.S. companies will have many of the access control, procedural, and physical security systems suggested in Customs’ C-TPAT recommendations, as the same procedures apply for theft and pilferage prevention.  So, while your company may not have all of the CTPAT elements (it is O.K. to answer "no" to the questions), it is appropriate to follow with a brief description of your company’s security program.

Likewise, in part 2 of the form Customs asks if you took any steps to make sure that your vendor and service providers have implemented supply chain security.  For most companies, the answer will be "no."  However, if you want to follow with something positive, you can state that your company will be sending Customs’ Supply Chain Security recommendations to your suppliers in the near future.  For your larger vendors, it is also possible they have robust access, and procedural and physical security programs already in place. If someone in your company has visited these locations, they may know about these security arrangements, and you may wish to provide Customs with a brief description of them.

Other C-TPAT News

On November 20-22, 2002, Customs held its Trade Symposium 2002, which included discussions on the Customs-Trade Partnership Against Terrorism (C-TPAT), the Importer Self-Assessment (ISA) Program, the Automated Commercial Environment (ACE), the Container Security Initiative (CSI), and the 24-hour advance manifest regulation.

According to Commissioner Bonner, over 1,000 companies have signed up to participate in C-TPAT (Importers, Brokers and Shippers).  The Commissioner emphasized that Customs wants to make sure that there is real substance to C-TPAT and that the program does not get diluted with uncommitted participants.

The Commissioner also reaffirmed his commitment to making sure that C-TPAT partners receive meaningful benefits and noted that the vetted members of C-TPAT are already receiving benefits, including reduced inspections and reductions in the National Targeting Center scoring that identifies high risk cargo shipments.

In addition, Commissioner Bonner stated that in the coming weeks and months Customs will begin working with individual C-TPAT participants to validate their supply chain security to make sure that C-TPAT does, in fact, result in a meaningful increase in supply chain security. 

The Commissioner emphasized that this validation process is not an audit, but would consist of Customs personnel familiar with supply chain security, along with company security and logistics personnel and management, evaluating the measures being taken under C-TPAT agreements. 

For additional information on Customs C-TPAT program, please click on the link to our CTPAT page.

Please let is know if we can assist you with any questions. We can be reached by phone at (415) 986-8780 or by e-mail at geo@tuttlelaw.com.