Bureau of Customs and Border Protection (Customs) recently held
a C-TPAT training session in Miami, Florida, April 21-24, 2003.
Present at this training session were many people from Customs
Headquarters involved in developing and administrating C-TPAT.
Also present were Customs officials in charge of other security
programs, such as the Container Security Initiative (CSI), the
Automated Targeting System (ATS), the Business Anti-Smuggling
Coalition (BASC). Stephen Spraitzar, an attorney with the Law
Offices of George R. Tuttle, attended this training session and
provides the following summary of some of the highlights presented
at this training session.
Customs' Continued Commitment to C-TPAT
Customs made it clear that C-TPAT will continue
in the future and will be an integral part of the homeland security
effort. Customs noted the following:
3000 applicants have submitted C-TPAT profile responses; 70
of the top 100 importers are involved with C-TPAT.
Customs hopes to have two
training sessions per year similar to this training session.
will be increased funding for C-TPAT programs and the addition
of new positions.
of C-TPAT responses will be increased to ensure that the C-TPAT
program is meaningful.
will be expanded to foreign manufacturers and others in the
Integration With Other Security Programs
the training session, Customs reviewed the relevance of C-TPAT
membership in connection with other programs, including the following:
(Automated Commercial Environment): C-TPAT membership is required
to participate in ACE, a program to provide an integrated, fully
automated information system for the efficient collection, processing
and analysis of commercial import and export data. For the
participant, the ACE benefits include reduced data entry, reduced
paper handling, reduced financial processing, and increased
access to data.
(Free And Secure Trade): A program to expedite the shipment
of cargo between Canada and the U.S., requires participation
Targeting System (ATS): C-TPAT will be a factor in the ATS
system, which is designed to screen for high-risk cargo while
expediting the movement of legitimate freight.
24 –hour rule: C-TPAT
membership can be a mitigating factor for certain violations
in the 24-hour rule.
of C-TPAT Responses
noted the following developments in the C-TPAT program:
of Customs Validation Teams (CVT). Customs has been training
validators whose function is to visit the premises of the
C-TPAT applicant and, in some cases, the premises of the applicant's
foreign suppliers to validate the responses.
in-depth validation reviews have been conducted to date.
projects approximately 100 validations by this fall.
New Position of Supply Chain Security Specialist
will create a new position called the "Supply Chain Security
Specialist", who will be trained in the area of logistics
and supply chains.
positions are expected to be filled by September 30, 2003.
additional positions will be budgeted for FY 04.
specialists will not be account managers and, thus, will not
be involved in trade compliance.
of C-TPAT to Overseas Suppliers
this fall, Customs expects to expand the C-TPAT process to
allow overseas manufacturers and exporters to apply for C-TPAT
membership. This is a very important part of the process
because this area is a vulnerable part of the supply chain
over which most importers have no control.
membership for overseas suppliers will have to be coordinated
with the Business Anti-Smuggling Coalition (BASC), which has
been in effect for a number of years in certain countries.
Profile Responses to the C-TPAT Questionnaire
following comments were provided by Customs at the Miami training
is no right or wrong answer in responding to the C-TPAT Profile
is no standardized format for responding to the C-TPAT Profile
Customs suggested specifics
be provided in the responses.
important point for the applicant to indicate in the profile
responses is that the applicant has a procedure for the systematic
review of security procedures at the applicant's premises.
Summary of C-TPAT Benefits
the training session, Customs reviewed the following benefits
from either applying for or becoming a member of C-TPAT:
a result of responding to the C-TPAT questionnaire, the applicant's
supply chain will be more secure.
is to be an expected reduced number of cargo exams and reviews
for C-TPAT members.
membership will be a factor considered in the Automated Targeting
System (ATS) in identifying merchandise subject to examinations.
For problems or issues involving
an applicant's imported cargo, C-TPAT membership will be a consideration
at the field level.
membership will be a prerequisite for being eligible for certain
Customs programs, such as FAST and ACE.
C-TPAT membership will be
a mitigating factor in certain liquidated damage and penalty
you have any questions on any of the issues raised in this newsletter,
please contact Stephen Spraitzar at (415) 288-0427 or via email
at firstname.lastname@example.org, or
George R. Tuttle at (415) 288-0425 or via email at email@example.com.
Spraitzar is an attorney with the Law Offices of George R. Tuttle
in San Francisco. The information in this article is general
in nature and is not intended to constitute legal advice or to
create an attorney-client relationship with respect to any event
or occurrence, and may not be considered such.
© 2005 by Tuttle Law Offices.
rights reserved. Information has been obtained from sources believed
to be reliable. However, because of the possibility of human or
mechanical error by our offices or by others, we do not guarantee
the accuracy, adequacy, or completeness of any information and are
not responsible for any errors, omissions, or for the results obtained
from the use of such information.
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