When to use C-TPAT Compliant High Security Seals
01-25-2010One of the C-TPAT requirements all members must remember is the use of ISO / PAS 17712 Container High Security Seals also known as C-TPAT compliant high security seals. It is important to make sure all containers are sealed with C-TPAT compliant high security seals.
Ø All C-TPAT Carriers crossing C-TPAT cargo through the FAST lanes are required to have C-TPAT Compliant high security seals placed.
Ø All C-TPAT Carriers crossing Non-CTPAT cargo through regular lanes MUST also place C-TPAT Compliant high security seals even though the cargo that is crossing is Non-C-TPAT.
Customs and Border Protection (CBP) requires that C-TPAT members always comply with the security standards, even when doing business with Non-C-TPAT members.
We strongly encourage placing extra C-TPAT compliant high security seals in the container in case this is opened for previous inspection before arriving to the border.
Land Border Carrier Initiative Program Members Encouraged to Merge to C-TPAT
01-25-2010Customs Border Protection Agency has announced their plan to terminate the Land Border Carrier Initiative Program (LBCIP) which was initially developed in 1995. LBCIP was developed to prevent drug smuggling by improving truck and facility security. Along with this commitment came the benefit of using “line release” which allowed carrier members to get expedited clearance for goods that crossed the border on a regular basis.
After 9/11 Customs Border Protection (CBP) has been encouraging the voluntary program Customs-Trade Partnership Against Terrorism (C-TPAT) in which all members agree to comply with certain supply chain security standards. Current C-TPAT members not only comply with all supply chain security criteria but can also receive higher benefits than those companies which are LBCIP members.
As a result CBP is announcing their intention to terminate LBCIP and place an open invitation to all LBCIP members to apply to C-TPAT and begin receiving greater benefits.
“10+2” Full Compliance Date is Coming Up
01-19-2010January 26, 2010 is set to be the deadline that Customs Border Protection (CBP) placed on U.S. Importers to complete their ISF filing with no risk of fines or penalties.
However, after this date CBP will require all U.S. Importers to fully comply with Importer Security Filing (ISF) and Additional Carrier Requirements better known as “10+2’. CBP will now enforce Importers to submit “10” data elements, plus bill of lading numbers prior to the loading of containers and break bulk cargo onto ocean vessels and the origin port. Additionally “2” data elements such as vessel stow plan and container status messages are also required.
For those Importers that fail to comply with “10+2” requirements, they will be faced with penalties by customs of up to $5,000. All ISF submissions must be complete, accurate and on time.
C-TPAT Certified U.S. Importers will have the additional benefit of receiving 50% less mitigation, whereas Non-C-TPAT members will receive full mitigation for failure to comply with the “10+2” requirement.
C-TPAT 2010 Supply Chain Security Training Seminar Agenda
01-18-2010Customs Border Protection has released the official agenda for its 2010 C-TPAT SCS Training.
Event:
C-TPAT Supply Chain Security Training Seminar : Balancing Supply Chain Security and Economic Efficiency
The 2010 C-TPAT Training will include topics such as:
- Balancing Supply Chain Security and Economic Efficiency
- Conducting a Supply Chain Security Risk Assessment
- Revalidations
- Suspensions and Removals
- C-TPAT Best Practices
- Developing a Security Training & Awareness Program
- Proactive Approaches to Security Breach Prevention
- Mutual Recognition
- Interagency Cooperation
The Seminar will be divided in two sessions:
Session 1- Wednesday and Thursday, March 17-18, 2010
Session 2- Thursday and Friday, March 18-19, 2010
Venue:
Anaheim Marriott Hotel
700 West Convention Way
Anaheim, California, 92802
Master Method WebTV Training Compliance Suite Activity Book
01-11-2010The MM Compliance Suite is the first-ever comprehensive compliance suite of proven methods and processes to simply and effectively manage every single facet of compliance responsibility.
In this training we will share our roadmap approach for completely managing your compliance department in the most accurate and cost effective manner possible. We will overview all 11 methods that make up the complete compliance suite.
Why A Compliance Suite?
To battle the complicated and wide reaching process of trade compliance, the compliance experts at Zisser have developed the first-ever comprehensive compliance suite of proven methods and processes to simply and effectively manage every single facet of compliance responsibility.
Why the Masters Method?
Each Master Method WebTV Training is based on a proven method that is guaranteed to deliver a U.S. customs approved process that is ready to use, accurate, simple, consistent and always audit ready with documentation. This makes the Masters Method unlike any training you have ever attended.
Why WebTV?
WebTV Training is the next best thing to attending a live training in person (maybe even better when you consider travel costs). It is simply the most personal, dynamic, engaging, and stimulating training possible in a virtual environment.
Event: Masters Method Training Compliance Suite
Date: Tuesday, January 12, 2010 from 11:00 AM - 12:15 PM (PT)
Location:
Any Computer with an Internet Connection
CBP C-TPAT 2010 Supply Chain Security Training Seminar
11-20-2009Zisser Customs Law Group encourages all C-TPAT members to attend the U.S. Customs and Border Protection 2010 C-TPAT Supply Chain Security Training Seminar. The Seminar will take place in Anaheim, California (venue to be announced) from March 17th through March 19th 2010. This is a great opportunity to learn more about the latest C-TPAT news and other current supply chain security topics.
Registration begins on January 6, 2010. Please note that space is limited.
Prevent security violations and protect your C-TPAT status
11-04-2009C-TPAT certified companies have quickly learned that that CBP is very rigid when responding to a breach in supply chain security. All C-TPAT certified participants in the supply chain will immediately lose their C-TPAT certification status when their shipments are found to contain illicit merchandise. The consequence is immediate suspension. Several companies have argued that it is unfair to suspend all C-TPAT participants when only one party is responsible for the incident. Usually the breach occurs at the point of loading or in-transit.
CBP has made it a point that all C-TPAT certified companies must practice supply chain security every day with every shipment. The failure to properly secure even one part of your supply chain can easily lead to a breach in security and immediate suspension from the program. All parties in the supply chain must insure that all cargo is carefully screened and monitored at all times to avoid unauthorized access and manipulation. If each point of the supply chain commits to this, no violations should occur.
In our experience practicing supply chain security every day with every shipment is the best method for preventing a violation and protecting your C-TPAT status. At the very least it is also the best method to defend your security practices and secure quick reinstatement back into the program. U.S. Customs is committed to working with those companies who are equally committed to the program.
C-TPAT Portal Now Includes New Best Practices 2009
11-03-2009CBP has now included a very informative section in your Company’s C-TPAT Portal account. Under the Documents tab on your portal there will be a drop down box where you can find: C-TPAT Public Library, C-TPAT Partner Document Exchange and now Best Practices 2009.
Supply Chain Security Best Practices 2009 covers the following topics:
Security Criteria:
Business Partner
Conveyance Security
Physical Access Control
Personnel Security
Procedural Security
Physical Security
Security Training/Threat Awareness
Information Technology Security
Each of the security criteria’s mentioned above are explained in detail and provided with valuable information you can begin implementing in your company.
The Best Practices brochure discusses the importance and benefit of adopting security measures as well as how C-TPAT identifies best practices.
Brand New Benefit for C-TPAT Tier 2 & 3 Importers
11-03-2009As of Monday October 26th 2009 CBP has announced that C-TPAT Tier 2 & 3 Importers and ISF Filers are now eligible to request and ISF Progress Report.
To request an ISF Progress report you must e-mail to:
(JavaScript must be enabled to view this email address)
The following information must be included in the e-mail:
-Company Name
-Filer Code
-Point of Contact Telephone
-e-mail address (to which report will be sent)
For C-TPAT Tier 2 & 3 members shall provide the following information:
-Company Name
-IOR number(s)
-Point of Contact Telephone
-e-mail address (to which report will be sent)
-Inform what Tier the company is in
Please note that CBP will usually not respond to a request unless there is a problem. The report should be expected during the first week of the month after you register.
How to Prepare for a C-TPAT Validation
10-05-2009You are invited to our first webinar in the Masters Method Series - “How to Prepare for a C-TPAT Validation”. In this valuable and informative session, you’ll learn the 5 Core Steps to an Effective & Successful C-TPAT Validation, taught by the experts at Zisser who have assisted over 500 companies with their C-TPAT certification, validation & re-validation needs.
Our session will cover pre-validation strategies, communications with Customs & Border Protection (CBP), as well as preparing for the entire validation process. Don’t miss out on this great opportunity to improve your understanding of the C-TPAT validation process while adding increased value to your organization. Register today!
“How to Prepare for a C-TPAT Validation”
When: Tuesday, October 27, 2009
Time: 11:00 am (Pacific Time)
Cost: $45.00
For a copy of the PDF Flyer click here.
Please feel free to contact us with any questions you might have (619) 671-0376.
Supply Chain Security C-TPAT Workshop in Texas
10-05-2009The C-TPAT Field Office in Houston will be hosting a Supply Chain Security Workshop in Laredo and El Paso, Texas. All C-TPAT members are strongly encouraged to attend. Relevant topics will be addressed such as:
· C-TPAT Overview/Presentation
· Minimum-Security Criteria
· Container/Tractor/Trailer/Seal Inspections
· Smuggling Trends/Trend Analysis/PIA/Best Practices-SW Border
· Open Discussion
Laredo Community College
Time: 8:30 – 12:30
Date: October 29, 2009
Address: Laredo Community College
Import/Export Department
West End Washington Street
Laredo, Texas 78040
Telephone: 956-722-0521
El Paso Community College
Time: 13:00 – 16:30
Date: November 5, 2009
Address: El Paso Community College
Administrative Services Center (Board Room)
950 Viscount
El Paso, Texas 79925
The sessions will have no cost; however only 2 attendees per company will be able to register. To register please send e-mail to: (JavaScript must be enabled to view this email address) with the following information:
Company name
C-TPAT Account number & business type
Name of attendee(s)
C-TPAT Partners will receive a confirmation e-mail and must present it the day of the session for registration.
C-TPAT/Supply Chain Security Briefing in Otay Mesa
10-05-2009On October 15, 2009 the Los Angeles C-TPAT Field Office will be offering a Supply Chain Security Briefing at the Otay Mesa/Nestor Public Library, located at 3003 Coronado Ave., San Diego, CA 2154.
All C-TPAT members are encouraged to attend; local C-TPAT Highway Carriers will receive priority consideration for attendance. The sessions will have no cost; however only 2 attendees per company will be able to register.
The session will cover topics such as:
- Current threats facing your Supply Chain Security
- Review of case studies involving significant security breaches
- Steps to take to protect your Supply Chain
After each session there will be a question an answer period.
Morning Session 10:00AM - 12:00PM
Afternoon Session 1:30PM - 3:30PM
To register please send e-mail to: (JavaScript must be enabled to view this email address) with the following information:
Company name
C-TPAT Account number & business type
Name of attendee(s)
Session requested (morning/afternoon)
C-TPAT Partners will receive a confirmation and must present it the day of the session.
Last day to register is October 6, 2000. Please take into consideration that space is limited.
Customs- Trade Partnership Against Terrorism (C-TPAT) Enforcement and Appeal Process
09-30-2009U.S. Customs and Border Protection’s (CBP) works with the trade community, such as offering voluntary programs like C-TPAT. This means that CBP expects members to self police themselves and in turn allows certain benefits. Nonetheless, CBP adopts a “trust but verify” focus with all members.
For this reason, CBP has announced that actions will be taken for any C-TPAT members that do not comply with minimum security criteria.
C-TPAT Members may be removed or suspended from the program if any of the following occur:
-Narcotics seizures or other security related incidents
-Failed validations or lack of compliance with C-TPAT requirements
-Failure to provide required information or filing false or misleading information
-Actions or inaction that shows lack of commitment to the program
C-TPAT Headquarters Program Director makes the final decision to suspend or remove a member based on all information obtained.
Some of the reasons of which a company can be removed from the program are the following:
-Provided false information
-Demonstrated inadequate security
-Demonstrated a flagrant disregard for the program’s requirements
After an incident or violation to the program occurs, C-TPAT officials will determine the next step on a case-by case basis.
*Consequences after suspension and removal of program
Suspension of the FAST Lane benefit is one of the consequences of no longer being member, along with a post incident analysis to determine the circumstances that led to the violation.
*How to get back in
CBP mentions that in order to be reinstated into the program after incident or violation the company must agree to the following:
-A corrective plan which identifies specific objectives and time frames
-The company must consent to un-announced visits by C-TPAT staff to monitor progress
To learn more about the latest C-TPAT Enforcement and Appeal Process from CPB please visit http://www.cbp.gov/xp/cgov/trade/cargo_security/ctpat/
CBP Informative Events on Importer Security Filing “10+2”
08-11-2009Customs Border Protection (CBP) has announced that a series of trade outreach events will be held in various cities around the country.These events will give the opportunity for all interested to learn more about the new requirements and implementation procedures of the Importer Security Filing and Additional Carrier Requirements also known as ISF “10+2”. To learn more about location and registration details please click here.
U.S. CUSTOMS AND BORDER PROTECTION ANNOUNCEMENT FOR C-TPAT MEMBERS
07-30-2009U.S. Customs and Border Protection (CBP) have alerted on security measures to all C-TPAT members and cross border carriers. CBP encourages all members to increase their supply chain security and vigilance among their non-CTPAT business partners - vendors/supplier and service providers (US Customs Brokers, Freight Forwarders, and/or cross border carriers - involved in their supply chain.
The US-Mexico border has recently been faced with various narcotics seizures on both sides of the border; many of which have been found in shipments related to C-TPAT members. CBP encourages members to screen, evaluate and re-evaluate all business partners - especially non-CTPAT members - on a regular basis.
One of the main factors CBP identified was the lack of implementation among security procedures. Many companies have the resources to perform their own security measures but do not follow and/or make them part of their internal security procedures. Another factor was the lack of corporate oversight, which in turn contributed to the rise in risk of internal conspiracies.
CBP is providing all companies - C-TPAT and non-CTPAT - with criteria steps to evaluate the risk factors in their respective supply chains, such as:
- Ensure there is adequate oversight and accountability of the cargo loading and sealing process.
- Employ the use of cameras and/or other suitable monitoring devices or processes at the cargo loading areas.
- Audit and verify employee screening processes, to include periodic reviews.
- Consider rotating personnel assigned to operationally sensitive positions, such as dispatcher.
- Establishment of route times from the manufacturing site to various points in the transportation flow will help monitor and ensure that drivers are arriving at designated locations within established time parameters.
- Members should work with service providers to develop written and verifiable procedures to address those instances that a driver does not check in within established time parameters. Drivers should not be allowed to make unauthorized stops.
For more information on C-TPAT click here.
C-TPAT Benefits Expanded to Japanese Business Partners
07-20-2009On June 26, the U.S. and Japan signed a mutual recognition on Security Standards in Brussels, Belgium. The arrangement will now recognize Japan’s Authorized Economic Operator program (AEO) and the U.S. Customs-Trade Partnership Against Terrorism program (C-TPAT).
US Customs Border Patrol (CBP) and Japan Customs and Tariff Bureau (CTB) will accept and recognize the security standards for all members of both C-TPAT and AEO programs. This will now result in fewer cargo exams, quicker releases and less paperwork.
All existing C-TPAT members will now have an additional benefit by being able to have their shipments to/from Japan recognized and treated with special privileges.
If you are already a C-TPAT member, we strongly recommend you to encourage your business partners in Japan (suppliers, customers, customs brokers, warehouse operators and freight forwarders) to join AEO.
The benefits received by joining will be:
- Shipments will get out of Japan faster with significantly less paperwork resulting in expedited shipments and cost reduction
- Shipments will go to Japan faster with significantly less paperwork resulting in expedited shipments and cost reduction
- Your AEO business partners in Japan will automatically meet all supply chain security obligations and responsibilities
- Reduce U.S. Customs validation visits in Japan
If you are not enrolled in C-TPAT but your business partner in Japan is an AEO member, this is a great opportunity for you to consider joining C-TPAT and enhance the efficiency and security of your supply chain.
C-TPAT currently has mutual recognition agreements with Jordan, Canada, New Zealand and now Japan.
To learn more about how to become a member of the AEO and C-TPAT program, please contact us at (619) 671-0376 or to visit our website please click here.
Otay Mesa’s New Dock Policy
07-13-2009As of June 30, 2009 U.S. Customs Border Protection (CBP) has informed that a new procedure will take place at the dock in the Otay Mesa Commercial Facility.
All C-TPAT/FAST members and sealed in-bond shipments with “highly perishable produce shipments” (frozen or iceless berries, asparagus, meat or fish, among others) awaiting inspection will receive the benefit of keeping their doors closed at all times until a CBP officer approaches them to break the seal on the container.
Non C-TPAT/FAST shipments will now require maintaining at least one door opened during their waiting time. It is important for the driver to notify any CBP Officer, Supervisor or Agriculture specialist that their door has been opened for about 20 minutes without activity.
To learn more about the C-TPAT/FAST program and its benefits feel free to contact us at (619) 671- 0376 or to visit us please click here.
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A partir del día 30 de Junio del 2009, Aduana y Protección Fronteriza (CBP) ha informado que un nuevo procedimiento entrara en efecto inmediatamente en el andén de la garita comercial en Otay Mesa.
Para todo miembro de C/TPAT/FAST y envíos sellados in-bond que contengan “productos muy perecederos (congelados o sin hielo, tales como: fresas, espárragos, pescado y carne congelada, entre otros) y espere inspección, contara con el beneficio de poder permanecer con las puertas cerradas hasta que un oficial de CBP se presente a romper el sello del contenedor.
Envíos que no sean C-TPAT/FAST se mantendrán con una puerta abierta del vehiculo mientras se espera la inspección en la garita de Otay Mesa. Es importante que el conductor notifique cualquier agente de CBP, supervisor o especialista agrícola que la puerta ha estado abierta por 20 minutos sin actividad.
Para más información y beneficios respecto al programa C-TPAT/FAST favor de contactarnos al (619) 671-0376 o para visitarnos favor de seleccionar aqui.
Conference on Container Security in Bremen,Germany
06-29-2009
On September 10, 2009 the European Commission (EC) will hold a conference on Container Security in Bremen, Germany. According to the EC, the Port of Bremen accounts for 22% of the trade between the European Union (EU) and the United States (US). Container Security is at everyone’s most interest, and the EU is no exception, which is why they are addressing all security factors within the supply chain.According to the EC, research is underway to develop new container security technology that will improve secure the international supply chain.
One of the benefits that will hopefully be obtained by the conference will be the control and monitoring of container cargo between the EU and the US. New technological advances and more R&D for container security will also be important topics that will be further discussed.
For further details please visit the link below:
http://ec.europa.eu/enterprise/security/csc.htm
Thailand’s Approach Towards Supply Chain Security
06-10-2009On June 5th and 6th, th annual executive council meeting of Federation of Asia Pacific Air-Cargo Associations (FAPAA) took place in Bangkok, Thailand. Cargo security became one of the main topics. Thailand is currently aiming to increase their supply chain security on all of their export products. Supply Chain Security should become a worldwide concern; and Thailand is now taking part in it.
A pilot program will take place, as government and customs authorities, along with the private sector want to come up with security procedures that aim to reduce cargo inspection of their exports to the country of destination and higher supply chain security standards for all cargo.
Thailand Customs and Border Patrol are currently adopting security measures to screen their cargo being exported to the U.S. Two of the methods being utilized are Container Security Initiative (CSI) and Customs-Trade Partnership against Terrorism (C-TPAT). Cargo must be inspected and scanned before being exported; just as well security measures must be complied by business partners involved for cargo going out of the U.S.
AEO “Authorized Economic Operator” 2009 Update
06-10-2009As July 1, 2009, according to the European Commission Taxation and Customs Union (ECTCU), an AEO “new security framework” will become in effect. It will now be required that all importers and exports in the European Union (EU) will have to submit a description of goods on their process of Pre-Departure and Pre-Arrival to the EU. The declaration will have to be lodged up to 24 hours prior to exportation or importation. This new measure will hopefully reduce any supply chain security seizures and increase compliance among companies and Member States.
AEO Certification - be it Security and Safety Certificate (AEO-F) or Customs and Security Certificate (AEO-S) are aimed at lessening the effect by providing benefits in regards to these declarations. One benefit is that AEO certified companies is will have to provide pre-departure and pre-arrival declarations with less security-related information, as opposed to Non-AEO companies, which will need to declare additional information.
C-TPAT First Annual Northern Border Highway Carrier Conference
06-10-2009On August 19, 2009 C-TPAT will be having their first annual Northern Border Highway Carrier Conference in Buffalo, NY at the Buffalo Hyatt Regency Hotel. There will be no cost to attend to this conference; however, it will have a capacity of approximately 500 C-TPAT members. It is important to register on time to assure your space in the conference. Online registration will be available on June 1st 2009. The conference will cater relevant situations regarding FAST lane, validation of a highway carrier among others. Some of the attendees will include Supply Chain Security Specialists as well as directors of the Buffalo, NY; Washington, DC; and Houston, TX C-TPAT field offices.
For further details and registration site please visit:
https://apps.cbp.gov/ctpat_training_registration/?w
http://www.cbp.gov/xp/cgov/trade/cargo_security/ctpat/ctpat_buffalo.xml
Benefits and Best Practices for Importer Self Assessment
06-10-2009
As part of the updates and topics held at the 2009 New Orleans Seminar; CBP provided valuable information on Importer Self Assessment (ISA). CBP defines ISA as: a voluntary trade facilitation partnership program for trade complaint companies to assume responsibility for managing their own compliance, in exchange for less CBP oversight.
For companies that are already enrolled in the C-TPAT program, this is a great opportunity to increase your company’s supply chain security and become more complaint with customs regulations.
Some of the basic requirements are: comply with all applicable Customs laws and regulations, maintain a system of business records that demonstrates the accuracy, establish, document and implement internal controls, perform periodic testing, and maintain results of the internal testing for three (3) years.
Some of the benefits consist of: Exemption from comprehensive audits, coverage available for multiple business units, and possible mitigating factors for penalties or liquidated damages.
CBP’s and the Interagency Workinng Group’s Import Safety Action Plan
06-10-2009On July 2007, President Bush established the Interagency Working Group on Import Safety, this group was responsible to oversee the strategies and methods that were being applied and should be applied in order to improve and promote import safety.
One year later, an “Action Plan Update” was released. The Interagency Action Plan consisted in 14 recommendations which are the following:
Safety Standards - Focuses on creating and strengthening standards, as well as complying with the Consumer Product Safety Act.
Certification - Allows companies to verify compliance, certification and cargo process and Importer Self Assessment- Product Safety Pilot (ISA-PS).
Good Importer Practices- Consists in conducting interagency collaboration and compliance with U.S. Statutes and Regulations.
Penalties -Tougher mitigation guidelines, non-compliant merchandise, and conduct outreach to field offices.
Foreign Collaboration and Capacity Building- Involving foreign partners to comply with supply chain security.
Common Mission - All parties involved in a Supply Chain should conduct uniform procedures such as interagency meetings, cross training, and communication.
Interoperability/ Information Gathering - Makes it easier for government and the trade community to work through automated systems: International Trade Data System, Automated Commercial Environment/Automated Commercial System.
New Science- Improve procedures in order to prevent any hazard throughout the supply chain.
Intellectual Property Protection- Data must remain as confidential as possible in order to be secure, for this reason IPP is very much enforced in all parties involved in a supply chain.
Recall- Federal State Rapid Response, respond rapidly after any problem has occurred.
Technology/Product Recalls - Consumer Product Safety Improvement Act Established Guidelines
Track and Trace - Being able to identify where cargo is at any point of the supply chain.
Some of Customs Border Protection’s roles in assuring Supply Chain Security would be: Containment at the ports of entry, Interdiction before cargo arrives as well as providing industry partnership benefits.
Obama Administration’s efforts to strengthen border security
04-17-2009President Obama’s recent visit to Mexico to meet President Felipe Calderon is the last of a long line of talks and agreements between both countries to strengthen border security. The main reason for the plan-called Plan Merida or Merida Initiative-is to support Mexico with $700 million dollars to strengthen and work with Mexican authorities in the fight against drug cartels.
The funding will help in some the following actions:
- Issuance of inspection technology
- Issuance of helicopters and surveillance aircraft for the Mexican military
- Increase in cooperation with Mexican authorities in areas such as information and training
- Assistance regarding reforms in the Mexican judicial system
- Oversight of implementation of the Initiative
At the same time, agencies such as the Drug Enforcement Agency (DEA), the Department of Justice (DOJ), the Alcohol, Tobacco, and Firearms Agency (ATF), and the Federal Bureau of Investigation (FBI), among others are developing plans to reinforce the Initiative and cooperate with the administration’s goal of securing the southern border.
All these actions are centered on the issue of drugs and arms smuggling along the US/Mexico border and the continuing fight against drug cartels.
C-TPAT and ISF/10 + 2
04-17-2009As of January 26, 2009 the new regulations for importers and sea carriers, Importer Security Filing (ISF) data, more commonly know as 10+2 data, become effective. Customs sent an e-mail to C-TPAT members encouraging them to begin filing ISF data as soon as possible.
The interim final rule includes a delayed compliance date of 12 months. Between January 26, 2009 and 2010, CBP will show restraint in enforcing the rule. CBP will take into account difficulties that filers may face in complying with the rule as long as the filer is making a good faith effort and satisfactorily progressing toward compliance.
Some ISF filers have found that full compliance with ISF requires an average of 30-60 days. Given this in information, C-TPAT members should not wait until January of 2010 to start complying with the rule. There are benefits to C-TPAT members comply, including being reliably identified prior to lading. In addition, (you) customers will realize C-TPAT benefits.
For more information regarding ISF/10+2 please visit:
http://www.cbp.gov/xp/cgov/trade/cargo_security/carriers/security_filing/
or write to (JavaScript must be enabled to view this email address)
C-TPAT “State of the Program” Update
04-17-2009At the 2009 C-TPAT seminar held in New Orleans, a general session conducted by CBP presented updates on the C-TPAT program. The session is for CBP to demonstrate to the trade community that the program is evolving and there is commitment by the government regarding the program and supply chain security. Some key statistics are presented below.
Number of companies certified to date (April 2009): 9,128
- 4,213 Importers
- 55 Marine Port Authorities and Terminal Operators
- 731 Consolidators
- 851 Foreign Manufacturers
- 791 Brokers
- 2,487 Carriers
Number of companies validation
- 10,994 Total validations completed
- 8,396 Initial validations completed
- 2,598 Re-validations completed
- 3,748 Validations in 2008
- 29 New companies in Tier 3
Tier III members: 292
In 2009 CBP will be:
- conducting unannounced visits of members previously involved in breaches
- visiting multiple supply chains (for importers based upon risk before issuing a validation determination and granting benefits)
- issuing a new best practice catalogue
- having more focus outreach
- finding more countries to partner with (mutual recognition)
- refining portal and functionally
- further refining information regarding C-TPAT
- verifying in re-validations that companies have applied all action required from previous validations.
One out of 55 C-TPAT sea containers are examined
One out of 11 non C-TPAT sea containers were examined
One out of 6.5 C-TPAT trucks were examined
One out of 1.4 non C-TPAT trucks were examined
Tier I: 3.5 times less
Tier II: 4.5 times less
Tier III: 7 times less
C-TPAT importers are examined on average 5 times less than non C-TPAT
Tiers
- I. 90 days to review security
- II. Certified and validated
- III. Only importers
Portal
- Automated reports
- On-line tutorials
- Supply chain workshops
- Revised company and security profile
- Security survey C-TPAT (Q2)
- Northern border highway conference (August 2009)
- C-TPAT annual conference in Los Angeles (March 2010)
Mutual Recognition
The four Phases to Mutual Recognition
- Side by side comparison of the program requirements
- Joint validations
- Mutual recognition arrangements (signing)
- Development of mutual recognition operational procedures, primarily information sharing
Most actively
- Japan (completed phase one and two)
- Singapore (completed phases one and two)
- Waiting to sign, expected June 2009
- EU (completed phase one, phase two pending)
- Korea (AEO) (in the process of phase one)
Argentina (program exchange)
Australia (program exchange)
Brazil (training)
Chile (program exchange)
China (program exchange)
Colombia (training)
Ghana (training)
Guatemala (program exchange)
Israel (program exchange)
Kenya (training)
Malaysia (program exchange)
Mexico (program exchange)
Peru (program exchange)
Philippines (program exchange)
Switzerland (program exchange)
Taiwan (program exchange)
75% of the members in PIP/PEP are in C-TPAT
Best Practices
It was also discussed that:
- The bar is constantly being raised
- The best practices are always changing
- There are 200 specialists
- The information in 2006 catalog are still up to date but some may no longer be considered best practices
- Best practices addendum in 2009
- Companies should add best practices to their security profile
Management support
- Management to be involved in C-TPAT
- Performing risk/self assessments
- Ensuring employees are aware of C-TPAT
Business Partners
- Use third parties to perform periodic audits of business partners’ security procedures
- Table top exercises (testing employees)
- Business partners address areas of vulnerability
Conveyance security
- High security seals (multiple)
- Tamper evident tape, labels
- Automated tracking systems for modes of transportation
Physical access controls
- Biometrics
- Comprehensive searches of employees vehicles (upon entry/exit from facility)
- Innovative access control and key systems
- Vehicle gate pass controls and parking permits
Procedural security
- Test (table top exercises)
- Employee rotation policies to prevent collusion
- Automated tools for advanced scheduling
Security training
- Security awareness training for employees and business partners
- Periodic web-based training
- Posting of security updates
Information technology
- Agreement regarding change of password
- Multiple passwords
Another Reason to Join C-TPAT
04-16-2009In the past few weeks, US authorities have been detecting more than usual shipments (from IMMEX [Maquiladora] companies) which contain narcotics. In these cases, the text of Rule 2.2.4 number 23, federal authorities of AGA are obligated to immediately suspend import permit of the company involved.
After long negotiations with the authorities of SAT, certain changes were made to Rule 2.2.4. This means that from now on, if arms or drugs are detected in an exportation by an IMMEX company, the company will NOT be immediately suspended from its import permit, but instead will be given a guarantee of audience (before the authorities) so that the company can present the necessary information to exonerate itself.
This modification is of enormous importance in terms of judicial security for the IMMEX companies, now that the authorities will abstain from automatic suspensions for these cases.
Here is where the C-TPAT (Customs Trade Partnership Against Terrorism) program comes into play. One of the main requirements of the program is to have written and verifiable procedures for such areas as the selection and evaluation of business partners, inspection and tracking of equipment (trailer and tractor), and physical access controls (visitors and employees). These procedures are proof that the company is committed to maintaining a secure supply chain and can go a long way in an audience.
Companies should join C-TPAT to prevent loss of their Mexico import privileges.
C-TPAT Best Practice Update 2009
04-14-2009
At the 2009 C-TPAT seminar in New Orleans, Customs presented attendees with the C-TPAT Best Practice update 2009 brochure. This brochure is updated information to the 2006 Best Practice Catalog. At the “Best Practice” workshop the speaker mentioned that everything in the 2006 Best Practice Catalog continues to serve as a valuable tool for the trade community but some may no longer be “best practices.” Building on this foundation, CBP will continue to provide updated best practices on a regular basis via the program’s secure web portal.
The program has been evolving and past best practices are becoming new industry standards. Remember, with time Customs keeps raising the bar and expects more of the members. Even if you cannot immediately adopt all of the best practices, the more that you can put into practice, the more secure your operations will be-and the greater your potential for eventually reaching tier 3 status. We encourage you to review the recommendations given in your validation reports and the ones mentioned below. These best practices will enhance your security policies and procedures at your facilities.
If you have any questions about the recommendations or C-TPAT program, please contact Zisser.
“C-TPAT is dedicate to meeting the needs of our members while also promoting the highest possible level of cargo security. We hope that this best practices update will be helpful to all.”
- C-TPAT Director Bradd Skinner
Overview of Supply Chain Security Best Practices
Applicable to C-TPAT members as well as all supply chain partner companies. (The information below is in the C-TPAT Best Practice Update 2009 brochure).
Security Criteria
- Business Partner
- Conveyance Security
- Physical Access Control
- Personnel Security
- Procedural Security
- Physical Security
- Security Training / Threat Awareness
- Information Technology Security
Business Partner
- Perform periodic audits of business partners accompanied by a third-party security firm (these audits may be performed without advance notice). The firm should provide a written assessment of business partners’ adherence to C-TPAT minimum security criteria. If non-compliance is discovered, it could be sufficient grounds for terminating the business relationship.
- Conduct periodic table-top exercises to address security breaches within the supply chain and, if one does not already exist, create a “quick response team” to investigate suspicious activities discovered during cargo transportation.
Conveyance Security
- Use tamper-indicative security labels, bearing an actual photo of the seal and a serial number, attached to the hinges and between the two doors of the vehicles.
- Use multiple ISO/PAS 17712 certified high security seals on all shipments bound to the U.S.
- Use a dock locking arm to anchor the container chassis to the loading dock.
- In addition to using a bolt seal, attach a cast iron J-bar device to the locking bar that requires a specialized tool for removal.
Physical Access Controls
- Ensure that as employees enter the facility, their photos are displayed on an electronic access system monitor so that the security guard in the area can verify that individual entering match the photos displayed on the monitor.
- Issue all visitors thermal-activated visitor ID badges featuring expiration marking/coloring that appears after eight hours.
- Ensure that the exterior doors of building are equipped with two-person key systems that require a company manager and a security guard to unlock the facility.
Personnel Security
- Use fingerprinting to document the identify of all new hires, and provide an employee list to national authorities on an annual basis for additional screening.
- Conduct exit interviews as a routine part of the employee termination process, with a counselor on hand to evaluate the likelihood that a terminated employee might pose a retaliation threat.
Procedural Security
- Use tamper-evident tape with serial numbers to seal cartons, and verify the serial number against the packing list when loading and at the final destination.
- Schedule all deliveries at distribution centers in advance using an online automated tool, and ensure that upon arrival, drivers provide security guards with shipment-linked delivery numbers for verification.
Physical Security
- Install a double-layered perimeter fence, creating a secure zone between the two fence lines. Ensure that both fences are equipped with electronic monitoring capabilities, and that the outer fence incorporates underground concrete to deter tunneling.
- Maintain multiple alarm systems that include door contacts, heat and vibration sensors, and seismic movement detectors.
- Position security guard view towers at each corner of the facility perimeter with sightlines that permit views of activity inside and outside the facility. Make sure the towers are manned at all times.
- If the facility is located adjacent to a lake or eitheir body of water that forms part of its perimeter, install an optical fence above and below the water line to detect waterborne intruders.
Security Training / Threat Awareness
- Require new employees to complete a multiple-module security training program. Web-based training should emphasize recognition of internal conspiracies, maintaining cargo security, facility access control, and mail handling procedures. Publish security updates via internet.
- Conduct a semi-annual security awareness training seminar for all U.S. based suppliers, customers, and other business partners.
Information Technology Security
- Install software on employees’ laptops that allows management to delete information from the hard drive from a remote location.
- Require computer users to sign an agreement of liability for the use of the company’s information system, and renew these agreements each time a password change is initiated.
- Equip computers with biometric retina scanners for authentication and identification purposes.
How C-TPAT Identifies Best Practices
Best practices in a general sense are innovative security measures that exceed the C-TPAT minimum security criteria and industry standards.
In order for the best practices to be effective, they should include high-level managerial support, employ a system of checks and balances, and have written and verifiable policies and procedures.
CBP C-TPAT specialists have conducted over 8,000 validations and site visits since the publication of the 2006 Supply Chain Security Best Practices Catalog. The dynamic trade environment and diverse business models of C-TPAT partners have presented the program with new best practices. Included in this pamphlet is a snapshot of new best practices recently identified by the program.
The benefit of adopting security measures
The best practices outlined in this document, if adopted, will protect the security of member companies as well as their economic health. As the global supply chain grows more secure, the United States will become more effective and efficient at preventing terrorists, terrorist weapons, narcotics, and other contraband from entering the country. This, in turn, prevents costly interruptions in the free and fair flow of trade.
CBP’s Mission
As a core trade program within CBP, mission is to:
- Prevent terrorists and / or terrorist weapons from entering the United States by partnering with members of the trade community to enhance the security of their international supply chains, with priority focus on foreign manufacturers through CPB clearance process.
- Facilitate the flow of legitimate cargo through the provision of partner incentives and benefits, while allowing CBP resources to concentrate on higher risk shipments.
- Internalize the core principles of supply chain security through cooperation and coordination with members of the international community, while simultaneously supporting and facilitating other CBP security initiatives (e.g., Free and Secure Trade, Secure Freight Initiative, and Container Security Initiative).
CBP’s Latest News Releases
04-14-2009This month, again CBP sent C-TPAT members various news releases regarding seizures involving C-TPAT partners. Due to incidents such as these CBP is raising the bar for expectations of minimum security criteria. All members need to re-evaluate their supply chain security program to make sure that it is complying with CBP’s requirements. This is a clear warning that CBP will take immediate action to suspend/remove partners who are not complying with the minimum criteria of the program.
CBP will continue to send news releases of incidents such as these to raise awareness and restore partner attention regarding supply chain security. CBP wants to inform everyone that seizures of this sort demonstrate that containers/trailers can be compromised, an indication of failure to comply with C-TPAT minimum security criteria. These seizures underscore the importance to have robust supply chain security measures governing inbound and outbound shipments.
CBP is not only targeting northbound shipments but also southbound destined for Mexico for contraband such as firearms and undeclared currency. In the past two weeks there have been four significant seizures involving C-TPAT members going southbound. CBP would like to advise C-TPAT members that they may experience increased inspections at all Southwest border Ports of Entry. Click below to read the news releases.
Click here for April 6, 2009 News Release.
CBP officers seize nearly three tons of marijuana hidden in two FAST shipments at Laredo port of entry.
Click here for April 10, 2009 News Release.
CBP officers at El Paso port seize 4.5 tons of marijuana in one bust.
Click here for April 13, 2009 News Release.
CBP officers seize $1 million in undeclared outbound currency from FAST driver at World Trade Bridge.
2009 ICPA Trade Compliance Survey Results
04-09-2009Economic globalization and the growth of global trade volume drives focus on Global Trade Compliance among importers and exporters.
In working with our import clients at Zisser, we began to realize that they were facing challenges in managing the regulatory aspects of the import process. We were seeing that errors and lost productivity manifesting from manual processes were costing them in terms of delays, lost revenue from incorrect duties, as well as fines and penalties.
We conducted this survey of the ICPA member base in January 2009 and received 232 responses. The survey was designed to better understand the environment and to begin creating a baseline for measuring best practices in Import Regulatory Compliance. We believe that automated tools, centralized electronic recordkeeping and an audit trail are elements of a best practices approach to trade compliance - we desired to establish a current benchmark for this.
The paper focuses on Zisser’s findings about how Compliance Managers are dealing with Harmonized Tariff Schedule Classifications and Duty Reduction Programs.
We’d like to thank the ICPA board and members for their support and participation.
To read the results from the surevey click here.
President Obama…Good for Trade?
03-25-2009In today’s uncertain economy, President Obama has many challenging issues to address. The top issue within the International Trade community is probably free and reduced duty trade programs. Importers and exporters alike are concerned over his opinions on these programs. President Obama has made it quite clear that he disapproves of the current arrangements. While some believe he will do away with current agreements and disapprove pending agreements, he has stated the opposite pushing for reform rather than dissolution. He has stated that global trade is unsustainable if it favors only the few (speech in Berlin 07/24/08). He has also stated that it is impossible to turn back globalization, and that if we could, we would be worse off (speech in Flint, MI 06/15/08). Listed below are the key points that President Obama is concerned about and will work toward improving:
• Enforcement of existing, and creating stronger labor, safety, and environmental standards in countries with which we have active trade agreements. Existing labor, safety, and environmental laws are not being adhered to and properly enforced in countries we have active trade agreements with. Obama’s mission is to ensure enforcement of current laws is utilized before even considering new trade agreements.
• Creating transition assistance for displaced workers. For the Americans who find themselves jobless due to the export of manufacturing jobs to cheaper labor countries, President Obama wants to create transitional assistance in the way of job training, and reduced educational costs or grants to those who need to learn a new trade applicable in our upgraded job market.
• Enforcement of existing safety laws against Chinese products. President Obama wants to ensure that quality and safety sacrifices are not being made in exchange for lower prices.
• Amendments to NAFTA labor agreements.
• Firmly opposing CAFTA until labor and environmental standards are adhered to. Due to the disregard of the environmental and labor requirements that were set, President Obama does not support the current CAFTA agreement.
• Evaluating subsidized programs for “mega-farms” and lack thereof for smaller farms. President Obama believes that NAFTA should benefit the “many” and not the “few” (http://www.businessweek.com). The existing allocation of subsidized funds is mostly beneficial for the mega-farms, and leaves the small family farms struggling to compete. In Mexico for example, many small family farms receive only about 15% of their profits in the way of subsidy which is barely enough to buy seeds and fertilizer. They are not granted enough to install irrigation systems, or purchase necessary machinery to make their farms more profitable and competitive. For this reason, they are limited to producing only one crop a year - when and if enough rain falls.
• Plans to re-invest in communities affected by globalization. President Obama wants to financially assist communities that were highly dependant on manufacturing jobs that have since been exported to other countries.
• Improvement of labor and human rights standards for China trade. President Obama reiterates that existing labor and safety laws must be adhered to in China so that the standards that are set for the benefit of our own citizenry apply to others as well.
• Tangible benefits of fair trade to the U.S. The existing non-tariff rate barriers being imposed at the border (export vs. import) do not balance fairly in some cases. President Obama would like to see the U.S. benefitting equally from free trade.
• Supports free trade with Oman.
• Extension of trade restrictions on Burma to promote democracy. President Obama realizes the influence that the U.S. - a super power among nations - has on political, economic, and moral values of other nations. He understands that the trade agreements put into place indirectly support these values.
• Stronger labor standards for the pending Colombia free trade agreement.
• Re-negotiation of the Korea Free Trade Agreement. This is in regard to the non-tariff barriers that South Korea implements to keep out U.S. automobiles while exporting large numbers of automobiles to the U.S.
It is apparent that the task at hand for President Obama is not a quick and easy one. He has quite a few opinions and challenges to address. While he does not oppose free trade internationally, he disapproves of the current state the existing agreements are in. Working on enforcement, re-negotiations, amendments, evaluations, and implementations appear to be an important priority to President Obama.
Insight into Mexico’s new supply chain security program ASC
02-11-2009(English)
As part of our series of interviews with the directors of supply chain security programs worldwide, our supply chain security group recently had the opportunity to speak with Mr. Edgar Carrillo Luna, Director of the Alliance for Secure Commerce (ASC) from General Customs Administration in Mexico City.
This unique opportunity allowed us to get insight on the development of the program from its main source and director, Mr. Carrillo. Giving us an overview of the development of this program, Mr. Carrillo confirmed that Alliance for Secure Commerce will be formally announced and operational by 2009, thanks in part to the input being received regularly by US Customs, which will sign a mutual recognition agreement with Mexico once the program is operational.
According to Mr. Carrillo, Mexico’s supply chain security program will be very similar to its American counterpart, C-TPAT, as the requirements, security criteria and use of an online portal for members will be practically identical. Furthermore, the benefits of the program will be very similar, including the use of the FAST lane on shipments destined for Mexico at the seven ports of entry that currently have the dedicated lane.
Although the pilot has not yet begun and in the initial phase of the program only importers will be eligible to join, the following stages will accept every other member of the supply chain, including exporters, manufacturers, carriers, customs brokers, and warehouse operators.
Alianza para el Comercio Seguro – Un adelanto exclusivo sobre el programa de seguridad de cadena de suministro de México
(Español)
Como parte de nuestra serie de entrevistas con los directores de programas de seguridad de cadena de suministro a nivel mundial, tuvimos la oportunidad de hablar con Edgar Carrillo Luna, Director de Alianza para el Comercio Seguro, programa de la Secretaría de Hacienda y Crédito Público.
Este encuentro nos dió la posibilidad de obtener información sobre el desarrollo del programa. Explicando la visión general del programa, el Sr. Carrillo afirmó que el lanzamiento del programa está previsto en el 2009, gracias en gran medida al apoyo recibido por parte de la Aduana estadounidense (CBP) con quien se busca firmar un acuerdo de reconocimiento mutuo. Esto significa beneficios recíprocos – tales como prioridad en inspecciones y el uso exclusivo de carriles – para ambas fronteras a aquellas compañías que estén en algún programa, ya sea ACS en México o su equivalente en Estados Unidos, CTPAT.
El programa será muy similar al programa de C-TPAT, ya que los requisitos, criterios de seguridad y el uso de un portal electrónico para sus miembros serán prácticamente idénticos. Además, los beneficios del programa serán similares, a diferencia que el programa ACS tiene un adicional como la reducción en el pago de multas.
A pesar de que el programa piloto aun no ha comenzado y la fase inicial sólo contempla a compañías importadoras, en las siguientes etapas se aceptará al resto de los miembros de la cadena de suministro: exportadores, empresas manufactureras (maquiladoras), transportistas, agentes aduanales y operadores de bodegas.
C-TPAT Achievements
10-01-2008(As of October 2008)
8,707 - Certified Partners to current date:
- 7,948 - Certified Partners at the end of 2007
- 759 - Increase in membership in 2008
7 - Field Offices; Current staffing level is 195
9,690 - Total Validations Completed
- 7,797 - Initial Validations Completed
- 1,893 - Re-Validations Completed
Number of completed validations by year:
- 2003 / 137-Validations
- 2004 / 294 –Validations
- 2005 / 1,109-Validations
- 2006 / 2,253-Initial Validations / 16-Revalidations / 2,269-Total Validations in 2006
- 2007 / 2,516-Initial Validations / 575-Revalidations / 3,091-Total Validations in 2007
- 2008 / 1,488-Initial Validations / 1,302-Revalidations / 2,790-Total Validations in 2008
Importer – 4,099
Carriers – 2,333
Brokers – 758
Foreign Manufacturers – 769
Consolidators – 694
Marine Port Authorities and Terminal Operators – 54
415 - Total suspensions (213 Highway Carriers)
279 - Total removals (119 Highway Carriers)
Internationalization Efforts:
- 3 - Mutual Recognition Arrangements: New Zealand, Canada, Jordan
- 4 - Mutual Recognition Projects: Australia, European Union, Japan, Singapore
- 4 - Technical Assistance Projects: Malaysia, Mexico, Philippines, Guatemala
- 3 - Capacity Building Training Programs: Ghana, Brazil, Kenya
Security Criteria Implemented:
- 10 - Business Entity Types: Importers, Sea Carriers, Highway Carriers. Rail Carriers, Foreign Manufacturers, Customs Brokers, Mexico Long Haul Highway Carrier , Port Authorities/Terminal Operators, Air Carriers, Consolidators
Tiered Benefits Structure – commensurate with security enhancements. Best Practices Catalog.
- 271 - Tier 3 Importers
On a typical day, CBP…
Processes:
- 1.13 million passengers
- 70,200 truck, rail, and sea containers
- 2,639 aircraft
- 304,000 vehicles
- Arrests 2,472 people
As a result:
- Intercepts 84 fraudulent documents
- Intercepts 1 traveler for terrorism/national security reasons
- Seize:
- 7,388 pounds of narcotics
- $652,603 in restricted/prohibited goods
- $187,176 in undeclared or illicit currency
- 4,296 prohibited meat or plant material including 164 pests
CBP statistician’s tallies for the fiscal year 2008 have recently completed, and it is interesting what was accomplished last year.
- CBP apprehended over 1 million people at their ports of entry and between them.
- CBP seized just less than 3 million pounds of narcotics.
- CBP apprehended more than 200 people with serious criminal records including for murder, rape and child molestation.
- CBP helped expand our work force by 11 percent, including 17 percent more Border Patrol agents, 7 percent more CBP officers and 5 percent more agriculture specialists.
- CBP continued to safeguard commercial trade through enhanced enforcement actions, which grew to more than 19,000 seizures valued at $351 million.
- CBP accomplished all this despite increasingly difficult and dangerous conditions as 1,413 incidents of border violence were recorded.
