Apparel 
Requirements
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C-TPAT Opened To All Importers, But Security Details Should Be Considered Prior To Signing Up |
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May
8 , 2002 Customs has issued a press release announcing the formal launch of the Customs-Trade Partnership Against Terrorism (C-TPAT). The C-TPAT is a joint initiative between government and business designed to protect the security of cargo entering the U.S. while improving the flow of trade. To keep abreast of the latest developments and to review past articles, please see our CTPAT page. Customs had previously planned to expand C-TPAT to the largest participants in all of the various segments of the trade community (importers, carriers, Customs brokers, warehouse operators, manufacturers, etc.), before expanding to the trade community as a whole. Now the plan has changed, and as of April 17th 2002, C-TPAT participation has been opened to all importers. (The program will later be opened to carriers, brokers, warehouse operators, manufacturers, etc.) Application Process The C-TPAT application process requires that the importers conduct a self-assessment of supply chain security and then submit a comprehensive supply chain questionnaire to Customs. We believe that this document will then be used by the Customs security audit team in tailoring a security plan for each importer. Customs requests that two original signed agreements, along with contact information (on a separate cover), be mailed to Customs Headquarters. The Supply Chain Security Profile Questionnaire should be sent with an electronic copy on a 3.5" floppy disk or CD-ROM to Customs Headquarters, and an additional e-mail copy should go to Customs at industry.partnership@customs.treas.gov (including in the subject line the company name and "Security Questionnaire"). Customs states that it will review the importer's completed supply chain security profile questionnaire upon receipt and that, after its review, the importer will receive a copy of the C-TPAT importer participation agreement, signed by the Assistant Commissioner, Office of Field Operations, along with feedback on their application within 60 days. Customs states that an electronic confirmation indicating receipt of the signed agreement will be sent to the e-mail address provided in the importer's application. Benefits In addition to giving their cargo faster processing at the border, Customs will offer additional potential benefits to C-TPAT members, including:
C-TPAT benefits can begin once Customs has completed a company risk assessment encompassing both security and trade compliance. Customs also states that LRIs, who have already been evaluated for risk, will be accepted into C-TPAT upon submission of a signed C-TPAT importer participation agreement. We note that in the April 15-21, 2002, issue of JoC Week, the Director of Customs' Office of Trade Relations, Andrew Maner, was quoted as stating that C-TPAT benefits will be tailored for each company and that the package of C-TPAT benefits will be different for each importer. Planning Considerations In order to obtain maximum C-TPAT benefits as quickly as possible and to minimize supply chain disruption, we advise importers to seek outside assistance in conducting the security assessment and in completing the questionnaires. Importers, who currently have no written security plans or whose supply chains may presently present substantial security risks, may wish to implement corrective measures prior to signing up with Customs for the C-TPAT. These measures should include a written security plan and an implementation plan. Our concern is that importers may either be excluded from the C-TPAT (Customs is not required to approve the application), or that a company would be allowed into the program subject to substantial increases in security and lowered import benefits. For importers who already have secure supply chains, it is important to carefully and fully describe the security measures in place, with review of the document by outside Customs' counsel. Such precautions increase the company's chances of obtaining maximum import clearance benefits under the program. The Tuttle Law Offices Our firm specializes in Customs and International Trade matters, including Customs audits, focused assessments etc. Importers interested in gaining the benefits of C-TPAT participation may contact George R. Tuttle, Sr. at (415) 986-8780 or via email at grt@tuttlelaw.com
Copyright © 2002 by Tuttle Law Offices. All rights reserved. Information has been obtained from sources believed to be reliable. However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information.
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