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C-TPAT

US retailers streamline C-TPAT audits of overseas factories

Thursday, November 14th, 2013

logo-ctpatSince its post-9/11 inception, the US Customs C-TPAT program has helped the trade — and national security — by establishing a risk-based approach towards import cargo security.  Many large US retailers are involved in the program, taking steps to ensure that their foreign suppliers pass muster.  Recently, several large retailers have voluntarily joined forces to greatly improve the auditing of their suppliers’ factories.  Their pilot program has met with great success, and they hope that other retailer join forces for a wider rollout.

According to an article in the November 2013 print edition of American Shipper, “Common security lens,” an unanticipated byproduct of the C-TPAT program has been “audit fatigue” — foreign contract manufacturers inundated with extensive audit requests from US retailers and their third-party auditors.

The result has been increased costs for suppliers to comply with these often duplicative audits, which require “managers to spend time answering questionnaires, preparing for on-site audits, accompanying audit teams during plant visits and paying for third-party auditors when retailers outsource verification.”   Moreover, since the average factory is audited multiple times by different retailers annually, there is “confusion about whose standards to follow, inefficiency… and a focus on passing the audit rather than fixing any underlying problems.”

To address these issues, about 10 top US retailers — including Target, Home Depot and Levi Strauss — partnered to standardize audits in global supply chains.  With input from US Customs and third-party auditors, they created a harmonized audit checklist that incorporates the eight major areas that CBP requires for C-TPAT certification, essentially “agreeing on minimum security requirements” while leaving the details of compliance up to each factory.

The advantages of a standard approach to security are numerous:

  • Factories benefit by:
    • having more clarity and consistency about requirements
    • undergoing fewer audits, which enables them to focus on production and security.
  • Retailers gain by:
    • lowering costs of doing business
    • focusing time and resources on corrective action, education and training
    • exchanging best practices with other retailers and brands

After a successful pilot which resulted in some tweaking to the audit checklist, the working group of retailers hopes to broaden the program to include other retailers, by creating a website and LinkedIn group, and presenting at US Customs’ next C-TPAT conference.

 

CBP updates the Simplified Entry pilot program

Tuesday, November 5th, 2013

Effective November 4, 2013, US Customs has made changes to the Simplified Entry pilot program which launched in 2011:

  • CBP has changed the name of the program to “ACE Cargo Release Test” to reflect the addition of enhance functionality for:
    • automated corrections and cancellations
    • split shipments
    • in-bond cargo
    • quantity less than full manifested bill quantity (if no in-bond)
  • CBP has loosened the program’s eligibility so that direct filing importers and customs brokers no longer need to be participants in the C-TPAT program
  • The program is now open to all eligible participants for  an indefinite period, up from a 14-day period
  • CBP has added 3 new data elements to be filed in ACE Cargo Release:  Port of Entry, In-Bond (if applicable) and Bill Quantity

 

 

American Shipper: C-TPAT, ISA benefits questioned

Friday, September 6th, 2013

logo-ctpat

In the August 2013 print edition of American Shipper, the magazine highlighted its Import Operations and Compliance Benchmark Study which was released in May.  In particular, the focus was on the results of one part of the study — a survey of over 100 shippers on the effectiveness of US Customs’ C-TPAT and ISA programs.

Unfortunately, the results were not particularly positive.

As for C-TPAT:

  • 11% – Receiving all promised benefits of C-TPAT
  • 29% – Receiving some, but not all, of the expected benefits of C-TPAT
  • 7% – Receiving less than expected benefits of C-TPAT
  • 20% – Receiving no benefit from C-TPAT
  • 33% – Uncertain if C-TPAT is effective

As for ISA, “a third of respondents say they derive no benefit from the program, and nearly one half say they are uncertain of its benefits.”

The study is available here (registration required).

 

 

US works to enhance trade with Mexico, EU

Monday, February 4th, 2013

The United States continues its efforts to facilitate trade with two of its significant trading partners, Mexico and the European Union.

On the southern border, the US and Mexico recently signed a joint work plan for mutual recognition of each other’s trade security program, CBP’s C-TPAT and Mexico’s New Certified Companies Scheme (NEEC).  Both countries expect to implement the plan in two years.  This is similar to Beyond the Border initiative with our northern trading partner, Canada.

Separately, the US and the EU have renewed efforts to create a free trade zone for their mutual benefit.  Previously, the parties were unable to agree on the harmonization of taxes, tariffs, regulations and standards.  But with economic woes still engrained on both sides of the Atlantic, a free trade zone will likely save hundreds of billions of dollars — on both sides — each year, providing an incentive to find common ground.  Listen to the report from National Public Radio.

Beyond the Border — improvements for US/Canada trade

Tuesday, December 18th, 2012

Canada is the United States’ largest trading partner, with billions of dollars in goods crossing the border annually.  Last year, the United States and Canada agreed to implement the Beyond the Border Action Plan, which is intended to expedite trade between the two countries while enhancing border security.

As noted in a recent piece posted on the Government Security News website, Canada recently took a significant step in this regard by expanding its trusted travelers’ expedited border crossing pilot (Free and Secure Trade or FAST) program to a third crossing in Ontario.  Under FAST, participants that are either in Canada’s Partners in Protection (PIP) or Customs Self Assessment (CSA) program to have expedited border crossings.  Previously, expedited service was available only to carriers and shippers who were participants in both programs.  Now, the program is more in alignment with America’s trusted trader programs:  C-TPAT and ISA.

While this is a solid step in the right direction, significant work remains to meet the goals of Beyond the Border.  A recent article in Canada’s Financial Post, “Will the new Can-Am border agreement be a supply-chain headache?”, lays out several concerns.  For example, much effort must be expended to harmonize the two countries’ regulatory schemes for trade.  As pointed out by Joy Nott, president and CEO of the Canadian Association of Importers and Exporters,

[i]f we all live another 300 years, I suppose all regulations would end up being harmonized.  In the interim, it’s still the biggest hurdle to business, irrespective of the sector.  And no sector is exempt from this.

Until that time, as pointed out in the Financial Post article, traders will need to be well-versed in the trade requirements of both the US and Canada.  Ruth Snowden, executive director of the Canadian International Freight Forwarders Association, stated:

Traders will have to have both types of in-house expertise, as well as develop processes and systems to ensure compliance.  That’s getting increasingly difficult because it’s expensive to build the systems, relationships and third-party connectivity needed.

Nevertheless, in addition to the Ontario border crossing pilot, there are glimmers of progress .  For instance, as reported on this blog, CBP just increased the the dollar value of goods that would qualify for “informal entry” processing to $2,500, in a move to harmonize the values for the US and Canada in line with the Beyond the Border initiative.

CBP to launch six new CEEs in 2013

Wednesday, November 28th, 2012

Building on the success of the existing Centers of Excellence & Expertise,  US Customs has announced that six new CEEs will open in FY 2013:

1. Agriculture & Prepared Products:  Miami, FL

2. Apparel, Footwear & Textiles:  San Francisco, CA

3. Base Metals:  Chicago, IL

4. Consumer Products & Mass Merchandising:  Atlanta, GA

5. Industrial & Manufacturing Materials:  Buffalo, NY

6. Machinery: Laredo, TX

This will bring the number of CEEs to ten.

A vital component of CBP’S Trade Transformation efforts on the import front, “[t]hese virtual centers will provide one-stop processing to lower the trade’s cost of business, provide greater consistency and predictability and enhance CBP enforcement efforts.”

Simplified Entry pilot to expand

Wednesday, October 24th, 2012

Based on initial success, US Customs announced today that it is expanding the Simplified Entry pilot for air cargo to include additional participant and ports.

As for pilot participants, that number of brokers/forwarders has increased from 9 to 20.

As for ports, in addition to the original three pilot ports of Indianapolis, Chicago and Atlanta, the group now includes:  Seattle, San Francisco, Oakland, Los Angeles, Dallas/Ft. Worth, Houston, Miami, JFK, Newark and Boston.  In a few weeks,  CBP will further expand the pilot to three additional ports, Detroit, Memphis, and Anchorage.

To date, nearly 600 importers of records have filed over 28,000 Simplified Entries in the pilot.

New Center of Excellence & Expertise opens for auto and aerospace imports

Friday, September 7th, 2012

Yesterday, CBP officially opened the newest Center of Excellence & Expertise (CEE) for importers in the automotive and aerospace industries.  The center, based in the port of Detroit, is the third CEE that US Customs has launched, following the success of the pharmaceutical center in New York and the electronics center in Los Angeles.

According to CBP, the Centers of Excellence & Expertise, devoted to a particular industry,

… offer one-stop processing to lower the trade’s cost of business, provide greater consistency and predictability and enhance CBP enforcement efforts. The centers are coordinated from strategic locations, but are manned by CBP personnel across the country. The centers represent CBP’s expanded focus on “Trade in the 21st Century,” transforming customs procedures to align with modern business. By having the centers focus on industry-specific issues, CBP is able to provide tailored support to unique trading environments.

A fourth CEE, with a focus on the petroleum, natural gas, and minerals industries, is expected to open in Houston later this month.

CBP’s official announcement on the Detroit CEE can be found here.  In addition, please see our previous blog posts that touch on the CEE program.

What’s the latest with the Simplified Entry pilot?

Tuesday, August 14th, 2012

As recapped in US Customs’ July 2012 ACE Trade Account Owner Update, the Simplified Entry pilot for air cargo is doing very well:

As of July 25, 2012 over 3,000 Simplified Entries have been successfully filed by pilot participants at the three pilot ports of Atlanta, Chicago and Indianapolis. Simplified Entries have been filed for over 230 different importers. U.S. Customs and Border Protection (CBP) and the Pilot Participants will conduct an evaluation after 60 to 90 days to assess the pilot. Plans for expansion are moving forward. CBP is finalizing plans to expand to additional airports using a regional approach. CBP will be issuing a second Federal Register Notice to announce the expansion of the pilot to additional participants [ed. note:  see below]. Lastly, CBP is looking for opportunities to add new functionality to the pilot including incorporation of the Participating Government Agency (PGA) Message Set and the use of the Document Image System (DIS).

In addition, since the Simplified Entry pilot is a paperless (electronic) program, CBP has had to consider how warehouses, freight stations and terminals will fit into the project, since many of these are non-automated (not paperless) facilities.  As a solution, the agency has created a workaround process that will allow these facilities, “on an interim basis, to release cargo based on screen printouts presented to them by filers (importers, brokers, etc.),” according to the July 2012 Update.

Finally, due to the success of the pilot, CBP is opening up the test to additional participants.  As announced in today’s Federal Register, it is also relaxing the requirement that participants who use a broker to file simplified entries must be C-TPAT-certified (although any direct filers who participate must be in the C-TPAT program).

To learn more, read about Simplified Entry in the July 2012 ACE Trade Account Owner Update, or visit the Simplified Entry section of CBP’s website.

Trade Transformation – the big picture

Wednesday, July 25th, 2012

In the trade, there is much buzz about US Customs’ ongoing Trade Transformation efforts, by which the agency seeks to facilitate and secure US imports and exports by:

  • Driving down transactions costs to the trade
  • Creating efficiencies that result in expedited clearance and review processes; and
  • Aligning security and trade targeting and enforcement efforts around an “all-threats” agenda.

Many of the initiatives that comprise Trade Transformation, such as ACE improvements, Simplified Entry, and Centers of Excellence and Expertise, have been reported on extensively in this blog and elsewhere.  But for those who like to look at the “big picture,” US Customs, in its July 2012 CBP Trade Newsletter (page 8), provides the following graphic (reprinted below) that shows these initiatives in the context of the trade timeline.