Customs Trade Partnership against Terrorism (C-TPAT)

US Customs & Border Protection

Accredited Trader Certification

Supply Chain Security

The C-TPAT (Customs-Trade Partnership Against Terrorism) is a voluntary United States Customs and Border Protection (CBP) business initiative designed to build cooperative relationships that strengthen overall supply chain and border security.

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1.            What is C-TPAT?

(a)          The C-TPAT initiative recognizes that CBP can provide the highest level of security to the public and to other stakehold¬ers only through close cooperation with the ultimate owners of the supply chain: importers, carriers, brokers, warehouse operators and manufacturers.

(b)           Through this initiative, Customs is asking businesses to en¬sure the integrity of their security practices and communicate their security guidelines to their business partners within the supply chain.

2.            C-TPAT Objectives

(a)          CBP recognizes that a safe and secure supply chain is the most critical part of its work in keeping the U.S. safe. For this reason, CBP is seeking a strong anti-terrorism partnership with the trade community through C-TPAT. Trade partners will have a com¬mitment to both trade security and trade compliance, which are rooted in the same business practices. CBP wants to work closely with companies whose good business practices ensure supply chain security and compliance with trade laws.

3.            Who is Eligible for C-TPAT?

(a)          Currently, open enrollment for C-TPAT is available for the following business types related to the U.S. import supply chain cargo handling and movement:

(i)           U.S. Importers of record

(ii)          U.S./Canada Highway Carriers

(iii)         U.S./Mexico Highway Carriers

(iv)         Rail Carriers

(v)          Sea Carriers

(vi)         Air Carriers

(vii)        U.S. Marine Port Authority/Terminal Operators

(viii)       U.S. Air Freight Consolidators, Ocean Transportation Intermediaries and Non-Vessel Operating Common Carriers (NVOCC)

(ix)        Mexican manufacturers

(x)         Certain Invited Foreign Manufacturers

4.            Licensed U.S. Customs Brokers

(a)          Utilizing risk management principles, C-TPAT seeks to en¬roll compliant low-risk companies who are directly responsi¬ble for importing, transporting, and coordinating commercial import cargo into the United States. The goal is to identify compliant trusted import traders who have good supply chain security procedures and controls to reduce screening of their imported cargo. In turn, this enables CBP to focus screening efforts on import cargo transactions involving un¬known or high-risk import traders. CBP will be consulting with the trade community to develop the most effective ap¬proach for each sector to participate in C-TPAT.

5.            The Application Process

(a)          Businesses must apply to participate in C-TPAT. Participants complete an online electronic application on www.cbp.gov that includes submission of corporate information, a supply chain security profile, and an acknowledgement of an agree¬ment to voluntarily participate.

(b)          In completing the supply chain security profile, companies must conduct a comprehensive self-assessment of their sup¬ply chain security procedures using the C-TPAT security cri¬teria or guidelines jointly developed by CBP and the trade community for their specific enrollment category. The crite¬ria or guidelines, available for review in this section and on the CBP website, encompass the following areas:

(i)            Business Partner Requirements,

(ii)           Procedural Security,

(iii)          Physical Security,

(iv)         Personnel Security,

(v)          Education and Training,

(vi)         Access Controls,

(vii)        Manifest Procedures,

(viii)       Information Security, and

(ix)         Conveyance Security.

(x)          See C-TPAT Online Application Instructions on the pages that follow.

(c)           Upon satisfactory completion of the C-TPAT Online applica¬tion and supply chain security profile, participants will be as¬signed a CBP C-TPAT Supply Chain Security Specialist (SCSS). A SCSS will contact the participant to begin the C-TPAT validation process.

6.            The Benefits of Participation in C-TPAT

(a)          C-TPAT offers trade-related businesses an opportunity to play an active role in the war against terrorism. By partici¬pating in this first worldwide supply chain security initiative, companies will ensure a more secure and expeditious supply chain for their employees, suppliers and customers. Beyond these essential security benefits, CBP will offer benefits to certain certified C-TPAT member categories, including:

(b)          A reduced number of CBP inspections (reduced border delay times).

(c)           Priority processing for CBP inspections. (Front of the Line processing for inspections when possible.)

(d)          Assignment of a C-TPAT Supply Chain Security Specialist (SCSS) who will work with the company to validate and enhance security throughout the company’s international supply chain.

(e)          Potential eligibility for CBP Importer Self-Assessment program (ISA) with an emphasis on self-policing, not CBP audits.

(f)           Eligibility to attend C-TPAT supply chain security training seminars.

(g)          It is clear that security issues will play an ever more important role in international trade logistics. Today’s voluntary programs may become mandatory programs in the future. Many compa¬nies recognize that participation in C-TPAT is part of a “best practices” approach to achieving leadership in their industry.

7.            How the Partnership Works

(a)          CBP C-TPAT account managers will contact participants to begin joint work on establishing or updating account action plans to reflect C-TPAT commitments.

(b)          Action plans will track participants’ progress in making security improvements, communicating C-TPAT criteria or guidelines to business partners, and establishing improved security relationships with other companies. • Failure to meet C-TPAT commitments will result in suspension of C-TPAT benefits. Benefits will be reinstated upon correcting deficiencies in compliance and/or security.

8.            Confidentiality of Data

(a)          CBP has stated that all information on supply chain security submitted by companies applying for the C-TPAT program will be confidential. CBP will not disclose a company’s par¬ticipation in C-TPAT.

9.            C-TPAT Costs of Participation

(a)          Firstly, C-TPAT participation is voluntary. Secondly, CBP recognizes that not all companies are in a position to meet C-TPAT minimum security criteria or guidelines. All eligible companies that import into the U.S. or provide import cargo movement or handling services should assess their supply chain security procedures to determine if they can qualify. CBP intent is to not impose security require¬ments that will be cost prohibitive. For this reason, CBP has worked in concert with the trade community in developing security criteria and guidelines that reflect a realistic business perspective. Potential C-TPAT participants may find that they already have many of these guidelines in place.

(b)          That said, enhanced security and C-TPAT participation will cost money. Also, those firms that have historically had few or no security guidelines in place will find that there will be added costs of getting “up to speed” organizationally. C-TPAT is also not intended to create any new ‘liabilities’ for com¬panies beyond existing trade laws and regulations. However, join¬ing C-TPAT will commit companies to follow through on actions specified in the signed agreement. These actions include self-as¬sessing security systems, submitting security questionnaires, de¬veloping security enhancement plans, and communicating C-TPAT guidelines to companies in the supply chain. If a company fails to uphold its C-TPAT commitments, CBP would take action to suspend benefits or cancel participation.

10.          Viability for Small- and Medium-Sized Companies

(a)          Initially, it was mostly large companies that rely heavily on international supply chains that applied and became active participants in the program.

(b)          CBP, however, encourages all companies to take an active role in promoting supply chain and border security. In that re¬gard, C-TPAT is not just a big-company program. Medium and small companies should evaluate the requirements and benefits of C-TPAT carefully in deciding whether to apply for the program. Moreover, even without official participation in C-TPAT, companies should still consider employing C-TPAT guidelines in their security practices.

11.          Must vs. Should

(a)          Note that C-TPAT Security Criteria and Security Guidelines use the words “must” and “should” a great deal. These words have specific, yet logical and intuitive meanings. “Must” means that it is a requirement. A business will not achieve program participation status unless the requirement is met. “Should” means that while the procedure is likely considered to be an industry “best practice” it is not necessarily a requirement for program participation.

(b)          Businesses can antici¬pate, however, that over time, more “shoulds” will become “musts.” many Web sites use the protocol to obtain confidential user information, such as credit card numbers. To access the C-TPAT Security Link Portal:

12.          Recommendations vs. Guidelines vs. Criteria

(a)          The C-TPAT program has continued to evolve. When the program was first established, CBP issued what were called “Security Recommendations.” These “Recommendations” evolved into “Security Guidelines.”

(b)          In late October 2004, CBP, in discussion with the trade com¬munity, began drafting more clearly-defined, minimum-secu¬rity criteria for businesses wishing to participate in the C-TPAT program. After months of dialogue, CBP developed minimum-security criteria designed to accomplish two im¬portant goals: first, to offer flexibility for accommodating the diverse business models represented within the international supply chain; and second, to achieve CBP’s twin goals of se¬curity and facilitation.

(c)           “Security Criteria” are now the established minimum secu¬rity requirements for participation in the C-TPAT program. Security Criteria have been established for: Importers, Rail Carri¬ers, Foreign Manufacturers, Highway Carriers and Sea Carriers. For other groups, the “Security Guidelines” remain in effect.

13.          Supply Chain Security Best Practices Catalog

(a)          On March 9, 2006, the U.S. Customs and Border Protection issued its long-awaited “Supply Chain Security Best Prac¬tices Catalog.” This is a 56-page booklet that is organized based on C-TPAT Security Criteria. The best practices in¬cluded in the catalog are those that have been identified through more than 1,400 validations and site visits by CBP C-TPAT Supply Chain Security Specialists (SCSS). “Best Practices” are defined as:

(i)            Security measures that exceed the C-TPAT Security Cri-teria,

(ii)           Incorporate management support,

(iii)          Have written policies and practices that govern their use,

(iv)         Employ a system of checks and balances, and

(v)          Have measures in place to ensure continuity.

(b)          I he catalog is essentially a statement of what CBP considers to be practices that will meet or exceed its Security Criteria, and has therefore become very popular in the industry. Available online at: www.cbp.gov/linkhandler/cgov/import/ commercial_enforcement/ctpat/ctpat_best_practices.ctt/ctpat_best_practices.pdf.

14.          C-TPAT Security Link Portal

(a)          The C-TPAT Security Link Portal is a secure, full-service, In¬ternet web portal that will allow qualifying C-TPAT partici¬pants to:

15.          Enter new applications.

(a)          Instantly submit information updates and add new information.

(b)          Maintain a “living” Supply Chain Security Profile that can be updated as needed and must be updated and re¬certified on a yearly basis.

(c)           Communicate directly with CBP C-TPAT and/or their designated C-TPAT Supply Chain Security Specialists using a secure system.

(d)          Receive information directly from CBP to include cargo security alerts and sanitized intelligence information.

16.          Maintain a list of authorized users.

(a)          All C-TPAT participants will be required to use the C-TPAT Se¬curity Link Portal to ensure that all company information and Supply Security Profile information is accurate and complete. C-TPAT participants and certified members will be required to enter, update, and maintain several key fields of informa¬tion to assist in the verification of program eligibility. This in¬cludes the posting of current C-TPAT Supply Chain Security Profile and business profile information. CBP is using 128 bit Secure Sockets Layer (SSL) encryption. SSL uses a system that uses two keys to encrypt data. Both Netscape Navigator and Internet Explorer support SSL, and partners. Each party must have consented to the release of their company name among the C-TPAT membership. The SVI is the point of electronic access to verify the C-TPAT status of another Status Verification Interface Participant (SVIP).

(b)          Go to: https://ctpat.cbp.dhs.gov/. For information on the C-TPAT Security Link Portal, visit the www.cbp.gov C- TPAT web page at: www.cbp.gov/xp/cgov/import/commercial enforcement/ctpat/

(c)           Go to the Status Verification section to Generate an SVI.

(d)          Read and accept the Consent to Use Company Name terms and conditions that appear on the introductory screen for the SVI. Active acceptance of the Agreement (i.e., selecting the “I Accept” box) will be required to access the SVI.

(e)          For more information on the C-TPAT Security Link Portal, go to: www.cbp.gov/xp/cgov/import/ commercial_enforcement/ctpat/implement_portal.

17.          C-TPAT Status Verification Interface (SVI)

(a)          As stated in the C-TPAT Security Criteria, Certified C-TPAT partners need to verify the participation status of other eligi¬ble C-TPAT business partners. To address this need, CBP has created the Status Verification Interface (SVI). The SVI allows consenting certified C-TPAT partners to verify the participation status of other consenting certified C-TPAT Access to the C-TPAT SVI is now found in the C-TPAT Se¬curity Link Portal. SVI Access is granted to certified C-TPAT partners who meet the specific SVIP criteria. To quality as a SVIP, participants must have:

(b)          Access to the Internet C-TPAT Security Link Portal;

(c)           Achieved certification status as a C-TPAT participant;

(d)          Generated an SVI alpha-numeric status identification number (ID) in the C-TPAT Security Link Portal;

(e)          Accepted the terms of the electronic C-TPAT CONSENT TO USE COMPANY NAME form found in the C-TPAT Security Link Portal.

(f)           For SVI instructions, frequently asked questions, SVI fact sheet and/or access to the SVI interface go to: www.cbp.gov/ xp/cgov/import/commercial enforcementyctpat/svi.

(g)          For More Information on C-TPAT

(h)          For ongoing information and updates on the C-TPAT pro¬gram, go to the U.S. Customs and Border Protection Web site at www.cbp.gov.

18.          C-TPAT Online Application Instructions

(a)          For important instructions for submitting an online C-TPAT application go to: www.cbp.gov/xp/cgov/import/commercial enforcement/ctpat/online app/ and select “Instruc-tions for Completing the C-TPAT Online Application. The Online Application itself can be found at: https://ctpat.cbp.dhs.gov/CompanyProfile.aspx

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