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Update: C-TPAT Security Standard

December 3, 2004

This updates our newsletter of November 18, 2004, in which we described a second draft of minimum security standards that are being circulated to 16 selected importers. Comments from those companies have been requested by December 3, 2004. Thereafter, it is not clear whether CBP will move to implement the requirements or circulate further changes.

Our prior newsletter, "Customs' Increased C-TPAT Security Standards", of November 18, 2004, provided generalized information as provided in the first draft of the security standards.  

This second draft removes the previous language that characterized the CBPs measures as "minimum standards." Instead, importers would be required to implement documented and verifiable processes for determining risk in the supply chain. Such processes would need to take into account factors from the company business model, such as volume, country of origin, routing, potential terrorist threat via open source information and etc. In response to such a threat assessment, "appropriate" security responses will be required.

For those interested in viewing the specific changes made by CBP in this second draft, following is a comparison of the first and second drafts.

Our firm assists importers, brokers, and other parties to apply for, and meet, the ongoing requirements of participating in C-TPAT. If you have any questions on any of the issues raised in this newsletter, please contact George R. Tuttle, Sr. at (415) 288-0425 or via email at, or Steve Spraitzar at (415) 288-0427 or via email at, or George R. Tuttle, III at (415) 288-0428 or via email at

George R. Tuttle, Sr., Stephen Spraitzar and George R. Tuttle, III are attorneys 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 as such.

Copyright 2005 by Tuttle Law Offices.

All 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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