This article is based on information from a April 2, 2009 speech by Brad Skinner, CBP Director of C-TPAT/Industry Partner Programs, at the C-TPAT conference in New Orleans.
The C-TPAT program has come a long way since its inception in 2001. With the publication of C-TPAT Best Practices in 2006, U.S. Customs introduced a tiered approach to the program.*
*Customs updated these practices in April 2009 [read more]
This approach allows companies that invest time and resources into following C-TPAT best practices to reap additional benefits, while allowing other companies with programs that just meet minimum security criteria to participate at a lower level.
Tier 1 – Certified (not validated)
The company has successfully created a C-TPAT policies and procedures manual and completed the information in the C-TPAT web portal. Customs has reviewed the manual and determined that the policies and procedures meet the minimum security criteria for the program.
Tier 2 – Validated
Customs has visited the company’s locations and audited the actual execution of the policies and procedures established by the company. Customs concurs that all minimum security criteria of the program have been met AND the company is following the policies and procedures outlined in their C-TPAT manual and C-TPAT portal.
Tier 3 – Validated
Customs has conducted a validation of the company and has found that the company employs C-TPAT best practices.
C-TPAT program stats
During his speech at the conference, Skinner revealed some interesting statistics about the C-TPAT program.
9000+ certified partners as of March 27, 2009
851 foreign manufacturers
791 Customs brokers
292 partners are validated as Tier 3
801 partners suspended or removed since the program started
239 partners have been suspended/removed since 2008
400 of all suspensions/removals have been highway carriers
10,994 validations conducted by Customs to date
8,396 of which were initial validations
2,598 of which were re-validations
Of all validations to date, 32 percent were completed in 2008.
This shows that CBP’s effort to dedicate more resources to the C-TPAT program has resulted in increased participation and increased oversight.
By adding additional supply chain specialists and opening new offices (such as the one in Buffalo, New York), Customs has reached a point where they can more readily administer the C-TPAT program.
C-TPAT 2008 Achievements
A number of important things were achieved by the C-TPAT program in 2008.
Established Mutual Recognition Agreements (MRA’s) with Canada and Jordan. MRA’s allow C-TPAT partners to be recognized in the security programs of other countries without having to undergo a separate validation.
Issued new member benefit guide. This guide was created to help non-participants to better understand how the C-TPAT program can benefit them and national security.
Opened new C-TPAT field offices. By opening C-TPAT field offices in Buffalo and Houston, Customs could focus more resources on areas with the most trade activity–the northern and southern borders.
Created a new enrollment sector for 3PL’s. This allowed 3PL’s to finally enroll in C-TPAT.
Conducted first ever validations in China. Prior to 2008, C-TPAT participants with supply chain partners in China were unable to validate their entire supply chain. With the start of validations in China, it became possible for participants with partners in China to fully secure their supply chain.
C-TPAT 2009 Goals
Customs announced a number of goals for C-TPAT in 2009, one of which has already been reached. These goals should help guide members as they update and upgrade their C-TPAT procedures.
Issue new best practices. [Completed in April]
Conduct unannounced visits to members involved in a security incident in order to verify that security procedures are being followed.
Visit multiple supply chains for importers before issuing a validation.
Develop an international strategy to get other countries to form industry partner programs.
Refine the ACE Portal.
Provide more focused outreach to the trade community.
Are C-TPAT participants reaping the rewards?
One of the things that C-TPAT members are constantly asking is–What benefits do I get from C-TPAT?
One of the benefits most consistently cited by Customs is fewer Customs exams of your cargo.
Yet, what does this mean in the real world? Do participants truly experience fewer cargo exams?
Here are some statistics revealed at the conference.
Out of all exams conducted by Customs in 2008, about 83 percent were on non-C-TPAT shipments.
Of the exams conducted on C-TPAT shipments,
8.5 percent were on Tier 1 shipments
4.5 percent were on Tier 2 shipments
3.6 percent were on Tier 3 shipments
Likelihood of exam for C-TPAT participants
(as compared to non-participants)
Tier 1: three times less likely
Tier 2: five times less likely
Tier 3: seven times less likely
Exam stats based on container type
2 percent of all C-TPAT sea containers are examined, versus
9 percent of all non-C-TPAT containers.
15 percent of all C-TPAT trucks are examined, versus
71 percent of all non-CTPAT trucks.
These statistics clearly show an enormous advantage for C-TPAT members when dealing with Customs examination of import cargo.
Since exams are time consuming and expensive, it’s essential to reduce them to the lowest level possible. One way to achieve this is by participating in the C-TPAT program.
Another benefit that is growing all the time is the Mutual Recognition Agreements (MRA’s) that the US government has signed or is pursuing with other governments.
These MRA’s allow C-TPAT validated members to be recognized by the security programs of other countries, such as Canada’s Partners in Protection.
With MRA’s, C-TPAT validated companies no longer need to spend time and money getting certified in another country’s security program.
MRA’s are currently in place with Canada and Jordan. New Zealand should be joining this group shortly. Customs is actively pursuing MRA’s with several other countries as well.
The C-TPAT program continues to grow and evolve every year. The addition of new minimum security criteria and best practices, as well as the opening of C-TPAT field offices along the northern and southern U.S. borders, are two examples of the program’s evolution.
U.S. Customs has shown a commitment to making sure that importers secure their supply chains.
By dedicating time and resources to the program, Customs has ensured that C-TPAT members will live up to the ever evolving standards that help protect your supply chain and our country.
Need help with C-TPAT?
If you are interested in participating in C-TPAT or if you need assistance with your C-TPAT program, please contact Mohawk Global Logistics. Our licensed Customs brokers can offer you the guidance you need on C-TPAT and other compliance programs.
Robert Stein is Director of Customs & Trade Compliance for Mohawk Global Logistics. He is a licensed U.S. Customs Broker and a Certified Customs Specialist.