Final C-TPAT Rules Out

Journal of Commerce March 28, 2005

WASHINGTON -- Importers that participate in the Customs-Trade Partnership Against Terrorism have a new set of deadlines to upgrade their security to new voluntary guidelines.

Customs and Border Protection posted a final version of the long-awaited C-TPAT Importer Security Criteria on its web site. Customs officials in the past have said that the new criteria will further tighten supply-chain security.

Along with the criteria is a timetable for importer compliance. Importers will have until May 25 to "harden" their physical supply chains through new requirements for container security, premises security and access controls.

By July 25, importers will enhance internal supply-chain management practices, including personnel security, document processing, information technology security and training.

By Sept. 25, importers must have procedures in place for foreign business partners, including documentation that vendors are meeting the C-TPAT criteria.

Customs has not published a list of frequently-asked questions that are designed to provide more detail about how companies meet the criteria. There are also no published benefits for companies that meet the new standards.

Importers may find the new criteria online at: http://www.customs.gov/xp/cgov/import/commercial_enforcement/ctpat/criteria_importers/

-- R.G. Edmonson

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Commissioner Bonner Announced Security Criteria
March 26, 2005

Customs-Trade Partnership Against Terrorism (C-TPAT) Message from Commissioner Robert Bonner announcing Security Criteria March 25, 2005.

The Customs-Trade Partnership Against Terrorism (C-TPAT) is the largest and most successful government-private sector partnership to emerge from the ashes of 9/11.   Launched in November 2001, with only seven major importers, today C-TPAT has grown to more than 8,800 enrolled companies, which include United States importers, customs brokers, terminal operators, carriers, and some foreign manufacturers - all major players in the global supply chain.

From the beginning, voluntary participation and jointly developed security criteria, best practices, and implementation procedures were the guiding principles for C-TPAT.  As the program has grown, so has our need for more clearly-defined security criteria to establish the minimum, baseline security expectations for membership in this voluntary, incentives-based program.

To this end, in late October 2004, U.S. Customs and Border Protection (CBP), in discussion with the trade community, began drafting more clearly-defined minimum-security criteria for importers wishing to participate in the C-TPAT program.   After months of constructive dialogue, we have developed minimum-security criteria designed to accomplish two important 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 security and facilitation.  The threat of terrorism remains a real concern, and I believe it is now time to move from discussion to implementation.

Accordingly, the minimum-security criteria for importers will become effective on March 25, 2005.  Importers who have not yet joined the C-TPAT program must meet or exceed these security criteria before being certified and eligible for program benefits.   For current C-TPAT members, implementation will be phased in through three steps to ensure that an importer's security measures are consistent with these security criteria.

First, importers will have 60 days - until May 26, 2005 - to meet the container security, physical security, and physical access controls outlined in the new security criteria.  These security elements will provide an immediate 'hardening' of the physical supply chain.

Second, within 120 days - or by July 26, 2005  - C-TPAT members will be expected to address internal or procedural security elements, including personnel security, procedural security, information technology security, and the establishment of a security training and threat awareness program.  These security measures, internal to your company, will help strengthen overall supply chain management practices.

Third, importers will have 180 days - or until September 26, 2005 - to leverage their corporate strength to push security enhancements back into their supply chain, from point of stuffing to point of arrival and the CBP clearance process.  These business partner requirements outlined in the security criteria are paramount to an effective supply chain security program.

As the C-TPAT program continues to evolve, we look forward to continuing our dialogue with the trade community and working in a proactive, positive way to improve supply chain security and the security of global trade. Together, we will build a safer, more efficient worldwide trade environment.

Robert C. Bonner
Commissioner