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C-TPAT Frequently Asked Questions
| Q: |
What is Customs-Trade
Partnership Against Terrorism (C-TPAT)? |
| A: |
C-TPAT is a voluntary government-business
initiative to build cooperative relationships
that strengthen and improve overall international
supply chain and U.S. border security. C-TPAT
recognizes that U.S. Customs and Border Protection
(CBP) can provide the highest level of cargo
security only through close cooperation with
the ultimate owners of the international supply
chain such as importers, carriers, consolidators,
licensed customs brokers, and manufacturers.
Through this initiative, CBP is asking businesses
to ensure the integrity of their security practices
and communicate and verify the security guidelines
of their business partners within the supply
chain. |
| Q: |
What kinds of businesses
can apply 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
- U.S. Importers of record
- U.S./Canada Highway Carriers
- U.S./Mexico Highway Carriers
- Rail Carriers
- Sea Carriers
- Air Carriers
- U.S. Marine Port Authority/Terminal Operators
- U.S. Air Freight Consolidators, Ocean Transportation
Intermediaries and Non-Vessel Operating Common
Carriers (NVOCC)
- Mexican and Canadian Manufacturers
- Certain Invited Foreign Manufacturers
- Licensed U.S. Customs Brokers
How were these trade participation categories
selected?
CBP is responsible for screening all import
cargo transactions. Utilizing risk management
principles, C-TPAT seeks to enroll compliant
low-risk companies who are directly responsible
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 unknown or high-risk
import traders. |
| Q: |
How do eligible companies
apply to participate in C-TPAT? |
| 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 agreement
to voluntarily participate. In completing the
supply chain security profile, companies must
conduct a comprehensive self-assessment of their
supply chain security procedures using the C-TPAT
security criteria or guidelines jointly developed
by CBP and the trade community for their specific
enrollment category. The criteria or guidelines,
available for review on the CBP website, encompass
the following areas: Business Partner Requirements,
Procedural Security, Physical Security, Personnel
Security, Education and Training, Access Controls,
Manifest Procedures, Information Security, and
Conveyance Security. |
| Q: |
What are 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 participating
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:
- A reduced number of CBP inspections (reduced
border delay times)
- Priority processing for CBP inspections.
(Front of the Line processing for inspections
when possible.)
- 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.
- Potential eligibility for CBP Importer
Self-Assessment program (ISA) with an emphasis
on self-policing, not CBP audits.
- Eligibility to attend C-TPAT supply chain
security training seminars.
|
| Q: |
How will the partnership
work on an ongoing basis? |
| A: |
Upon satisfactory completion of
the C-TPAT Online application and supply chain
security profile, participants will be assigned
a CBP C-TPAT Supply Chain Security Specialist
(SCSS). A SCSS will contact the participant to
begin the C-TPAT validation process. |
| Q: |
What happens if a company
fails to meet the C-TPAT minimum security criteria
or guidelines? |
| A: |
Failure to meet C-TPAT commitments
will result in suspension or removal of C-TPAT
certification status and associated benefits.
Benefits may be reinstated upon correcting identified
deficiencies in compliance and/or security. |
| Q: |
Where can I get more information
on C-TPAT? |
| A: |
C-TPAT information is maintained
on the www.cbp.gov web site. |
| Q: |
What exactly are CBP expectations
for the C-TPAT participant? |
| A: |
To make a commitment toward the
common goal of creating a more secure and efficient
supply chain through partnership. CBP understands
that it has entered a new era and requires the
assistance of private industry to ensure increased
vigilance throughout the supply chain. CBP recognizes
that just as it protects the trade and our borders,
businesses must ensure that their brands, employees,
and customers are protected to the best of their
abilities. |
| Q: |
Will the information our
company provides to C-TPAT be confidential? |
| A: |
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 participation in
C-TPAT. |
| Q: |
As a company, we are very
interested in C-TPAT but we are not interested
in spending a lot of money or increasing our
liabilities if something goes wrong. Is it
still possible to participate in C-TPAT? |
| A: |
The decision to join C-TPAT is
voluntary. Not all companies may be 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 requirements
that will be cost prohibitive. For this reason,
we 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.
C-TPAT is also not intended to create any
new 'liabilities' for companies beyond existing
trade laws and regulations. However, joining
C-TPAT will commit companies to follow through
on actions specified in the signed agreement.
These actions include self-assessing security
systems, submitting security questionnaires,
developing 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. |
| Q: |
What is the overall vision
for C-TPAT in the coming months and years? |
| A: |
CBP recognizes that a safe and
secure supply chain is the most critical part
of our work in keeping our country safe. For
this reason, CBP is seeking a strong anti-terrorism
partnership with the trade community through
C-TPAT. Trade partners will have a commitment
to both trade security and trade compliance rooted
in their business practices. CBP wants to work
closely with companies whose good business practices
ensure supply chain security and compliance with
trade laws. |
| Q: |
Is the C-TPAT program
a viable consideration for medium or small
size companies? |
| A: |
CBP encourages all companies to
take an active role in promoting supply chain
and border security. C-TPAT is not just a big-company
program. Medium and small companies may want
to 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. |
C-TPAT Carrier FAQ's
| Q: |
As a carrier, I already
participate in the Customs Carrier Initiative
- is it a duplication of effort in joining
C-TPAT? |
| A: |
No. C-TPAT is the primary CBP
supply chain security program. CBP is looking
for carriers to join C-TPAT to enhance existing
security practices and better address the terrorism
threat to international air, sea, and land cross-border
shipping.
C-TPAT participation requires that a Carrier
Initiative Program (CIP) participant implement
and document specific C-TPAT supply chain security
guidelines or criteria. CIP participants should
already subscribe to the importance of security
from a narcotics-smuggling perspective and
are well positioned to expand their security
focus to encompass anti-terrorism. |
| Q: |
In
the less-than-truckload motor carrier environment,
is each C-TPAT importer required to place
a new ISO 17712 compliant seal on the trailer
when the pickup and delivery (P&D) driver
picks up freight? |
| A: |
Trailer
and container integrity must be maintained
to protect against the introduction of unauthorized
material and/or persons. In the less-than-truckload,
pickup and delivery environment, the use of
a secured padlock or similar locking device
is sufficient to meet the importer C-TPAT sealing
requirements. Only a limited number of individuals
should have access to open this padlock. However,
after the freight from the P&D trucks
is sorted, consolidated and loaded onto line
haul trailers which are then destined to cross
the U.S. border, these trailers must then be
sealed with a high security seal which meets
or exceeds the current PAS ISO 17712 standards
for high security seals. Written procedures should
stipulate how seals are controlled, to include
procedures for recognizing and reporting compromised
seals and/or trailers to CBP or the appropriate
foreign authority. Only designated employees
should distribute container seals for integrity
purposes. |
| Q: |
For trucking operations
where a truck makes several pickups and then
heads straight for the U.S. border, what kinds
of sealing or locking devices will be required? |
| A: |
For
P&D operations that do
not use a hub to sort or consolidate freight
prior to crossing the U.S. border, the importer
and/or trucking company must use ISO 17712 high
security seals for the trailer at each stop,
and to cross the border. Written internal procedures
must be in place to record the change in seals,
as well as stipulate how seals are controlled
and distributed, and how discrepancies are noted
and reported. As CBP develops the minimum security
criteria for truck carriers, this requirement
will be discussed in greater detail and may or
may not be modified. |
| Q: |
What about tank trucks
and flatbeds and other equipment that cannot
be sealed? |
| A: |
Tank trucks and flatbeds hauling
goods for C-TPAT importers that are incapable
of being sealed do not need to be sealed or padlocked. |
| Q: |
What
other kinds of locking or sealing devices
are acceptable for use by P&D drivers
in an LTL environment? |
| A: |
The intent of this security element
is to maintain the integrity of the trailer and
prevent unauthorized access. CBP does not stipulate
exactly what kind of device is required, but
instead provides general criteria which affords
the importer the flexibility in how to meet this
standard. |
| Q: |
How must the seals be
applied to the trailer? |
| A: |
Seals must be applied to the trailer
to prevent and detect any unauthorized access. |
| Q: |
Will CBP suspend or remove
me from the C-TPAT program if I do not implement
a sealing program for trailers destined for
the United States? |
| A: |
Retaining membership in the C-TPAT
program is contingent upon a continued, demonstrated
commitment to enhancing supply chain security,
and on meeting the outlined minimum security
criteria. At present, only C-TPAT importers are
governed by the minimum security criteria, but
development of the minimum security criteria
governing sea carriers, air carriers, and truck
carriers is underway. Container security measures,
including sealing requirements, are crucial aspects
to supply chain security and C-TPAT members who
do not adopt acceptable practices may be suspended.
CBP will continue to work in partnership with
members to address individual business models
and company concerns. Any decisions to suspend
or remove a C-TPAT member from the program are
taken seriously, are only made by senior C-TPAT
program managers, and are initiated only after
discussions with the C-TPAT member have failed
to resolve the security deficiency. |
For More Information:
Contact Industry Partnership Programs at (202)
344-1180 or fax (202)
344-2626 or email us, at industry.partnership@dhs.gov
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