FAQs for Foreign Manufacturers


Q:

Is the Customs-Trade Partnership Against Terrorism (C-TPAT a voluntary program for eligible foreign manufacturers?

A:

Yes. C-TPAT builds upon existing relationships with all of the segments, of the supply chain, both foreign and domestic, in an effort to secure the entire supply chain of goods entering the United States.

 

Q:

Is C-TPAT membership open to all foreign manufacturers?

A:

No. CBP will implement a phased approach to foreign sector enrollment, and initially will offer participation to Mexican manufacturers, Mexico related parties and a select group of foreign Manufacturers in Asia and Europe that will be invited to participate directly by CBP.

 

Q:

How will eligible foreign manufacturers outside of Mexico be notified of their opportunity to participate in C-TPAT?

A:

As eligibility to join C-TPAT will be initially open to a specific audience outside of Mexico, these eligible foreign manufacturers will be contacted directly by CBP to join C-TPAT.

 

Q:

Is C-TPAT participation currently open to related parties of all of the C-TPAT Importers?

A:

No. For this initial phase, only related parties in Mexico will be eligible to join C-TPAT. We are exploring a strategy to extend C-TPAT enrollment to related parties outside of Mexico at a later date.

 

Q:

Will Mexican related parties that are included in the security profiles of C-TPAT Importers have to undergo the entire process of applying for C-TPAT?

A:

No. Related parties in Mexico that are included in the security profile of the C-TPAT Importer are not required to complete the Voluntary Agreement and the Supply Chain Security Profile Questionnaire.

 

Q:

How can I have an impact on the security standards of my foreign service providers and affiliated foreign manufacturers?

A:

A good way to begin to influence the security standards of your manufacturers/exporters is to share the C-TPAT security recommendations and supply chain security profile questionnaire with them.

 

Q:

Will the C-TPAT importer bear sole responsibility for the security processes and facility of a C-TPAT foreign manufacturer.

A:

No. All companies who are members of C-TPAT, both foreign and domestic, will be responsible for the security of their facility, and of their supply chain.

 

Q:

As an exporter/manufacturer, I already participate in the Business Anti-Smuggling Coalition (BASC). Is it a duplication of effort in joining C-TPAT?

A:

No. Participation in BASC will not be a duplication of effort if a company joins C-TPAT. BASC is a private sector controlled initiative, supported by Customs and Border Protection (CBP), that is aimed at enhancing existing security practices to prevent drugs and implements of terror from being shipped in commercial cargo. CBP encourages companies to continue to join BASC as a means to maintain and improve their security, to share best practices with other BASC members and to receive visits by CBP officers under the Americas Counter Smuggling Initiative (ACSI).

 

Q:

If I am a certified BASC company, do I still need to apply to become a member of C-TPAT?

A:

Yes. BASC companies must still apply to join C-TPAT. However, since BASC participants already subscribe to stringent security standards throughout the scope of their operations, it is anticipated that these participants will rapidly meet the standards of C-TPAT thus expediting the enrollment process.

 

Q:

How will C-TPAT become available to other segments of the foreign supply chain after the initial enrollment?

A:

CBP is working on a strategy that will include input from the trade, to enroll additional segments of the foreign supply chain into C-TPAT. Once this is developed and approved, CBP will announce open enrollment on the CBP Web Page.

 

Q:

What additional benefits are there for foreign manufacturers to join C-TPAT?

A:

The more Customs knows about the entire security of the supply chain, the more effective we will be at making risk determinations concerning your conveyance and/or operation.

 

Q:

Will CBP assist the C-TPAT participants in the developing a threat, education and awareness program?

A:

Through conferences, training seminars and visits by C-TPAT Supply Chain Security Specialist, CBP will assist C-TPAT members in developing these areas.

 

Q:

Will CBP validate all of the foreign manufacturers that are members of C-TPAT?

A:

Yes, CPB is currently hiring and training an additional cadre of personnel to be Supply Chain Security Specialists who will conduct the validation visits.

 

Q:

In addition to the recommended C-TPAT Security Recommendations, how else will CBP communicate sound security practices to its members.

A:

In addition to the conferences/seminars, CBP will be publishing best practices on security measures adopted by C-TPAT members on the web page in the near future. These best practices will range from cost effective to sophisticated practices that will provide excellent examples to C-TPAT members.

 

Q:

Are there monetary penalties associated with C-TPAT for foreign manufacturers?

A:

Carriers who transport goods destined for the United States must apply by returning a Voluntary Agreement and a Supply Chain Security Profile Questionnaire to Customs. Supplemental information may be requested. See complete application instructions on this web site.

CARRIERS

Q:

What are the requirements for joining C-TPAT for U.S. /Mexico Border Highway Carriers?

A:

Carriers who transport goods destined for the United States must apply by returning a Voluntary Agreement and a Supply Chain Security Profile Questionnaire to Customs. Supplemental information may be requested. See complete application instructions on this web site.

 

Q:

Can a Carrier become an approved FAST carrier without being a C-TPAT participant?

A:

No. Participation in C-TPAT is a requirement for participating in FAST. FAST is designed to build upon the security measures required in C-TPAT, targeted specifically for expediting processing at our land border with Mexico and Canada.

 

Q:

What are the benefits of participation in C-TPAT?

A:

The primary benefits are access to dedicated FAST Lanes along certain U.S./Mexico border crossings and the potential for a reduced number of inspections (reduced border times).

 

Q:

Do I have to join both the C-TPAT and FAST Programs to receive the most benefits?

A:

Only carriers who are C-TPAT and FAST certified, and whose drivers possess valid driver registration card will be permitted to use the FAST Lanes along certain U.S. /Mexico border crossings. If a carrier does not want to use the dedicated lane, then participation in FAST will not be required.

 

Q:

If I am a C-TPAT Northern Border Highway Carrier and a FAST U.S./Canada Highway Carrier, do I still have to apply to receive benefits on the Southern border?

A:

Yes. Since the information required to apply on the Northern and Southern borders is slightly different, a U.S./Mexico Border Highway Carrier Application must be submitted to be considered for C-TPAT and FAST on the Southern border. Part of the application process includes sending the U.S./Mexico Border Highway Carrier Agreement and U.S./Mexico Border Highway Carrier Supply Chain Security Profile to CBP. Carriers that are already C-TPAT and FAST on the northern border should already be very familiar with this procedure and will receive expedited processing by CBP.

Security and the Supply Chain, Is C-TPAT for You?

Every  person who is involved in logistics, distribution or supply chain event management will be impacted by on-going efforts to create a more secure global trading system. In order to create this system, a partnership was designed to  bring together the best technology, best industry practices and regulatory  authority that would create a trust between business and government and create a more secure supply chain. C-TPAT, the Customs-Trade Partnership against Terrorism was developed to provide a template for how to handle cargo securely throughout global supply chains.¬ (9/25/2002)

Traditionally, the approach to supply chain security was focused on keeping the goods that were supposed to be in the box, in the box. Now, there is an added responsibility to insure that things that are not supposed to be in the box are actually kept out  of the box. As an importer, you must now be able to demonstrate that you have  both aspects of this process under control, and you must be able to demonstrate that control as it extends throughout your entire supply chain.

The extra efforts are  designed to keep the terrorist needle out of the global trading haystack.

The events of September 11,  2001, caused the closing  of the entire border and port systems. On that horrifying day, just-in-time production systems broke down, material flow was frozen and trade systems  worldwide crumbled. Customs needed a methodology to begin processing goods at  the borders and the ports, so a partnership was formed with key traders who  agreed to demonstrate that they would attend to the security of products flowing into our trading system, regardless of mode or port. C-TPAT increases the scope  and accountability of management over supply chain events and partners to prevent the introduction of weapons of terror into the trade network.

The partnership is designed to capture information and demonstrate control over all aspects of the  supply chain including the events and providers that have a role in moving  goods. It requires a complete self-assessment that encompasses procedural  security, physical security, personnel security, education and awareness  training, access control, manifest and conveyance security issues. The  partnership requires that you report back to Customs with an evaluation of your own supply chain systems and the actions you have taken or plan to take to  assure that your entire process is secure. Customs will review the plan and make recommendations that they deem to be appropriate.

C-TPAT will provide a  guideline to determine how to open the borders if there is a future issue or  concern at any border or port of entry. Participation in the program will determine the priority of trade flow as goods begin to move, when they begin to  move through restricted border entry points. Preferential treatment will be provided to products that are determined to be the lowest risk and if there is ample evidence of control throughout the chain of commerce. On the other hand, non-C-TPAT materials will be subjected to intensive inspection during times when borders are closed or restricted. Carriers will be more inclined to move goods that have been demonstrated to be under appropriate care during times of crisis  or tension. C-TPAT removes any client-based bias and provides an objective  platform for processing merchandise and the assessment of risk.

Customs is moving  forward with the C-TPAT initiative. The program was offered to the top importers  in April and by June over two hundred applications were pending Customs approval. In July, air, rail and ocean carriers were invited to enroll into the program. In the near future, ground carriers, brokers and producers will be asked to enroll into C-TPAT. This initiative will overlay the LRI (Low Risk  Importer) Program and will expand the drug smuggling focus of programs such as  the BASC (Business Anti-Smuggling Coalition) and the SCI (Super Carrier Initiative). C-TPAT is designed to secure the entire supply chain so that  weapons of mass destruction or other terrorism efforts or terrorists themselves do not enter the U.S. through Ports, Terminals or Borders.

Private companies are  being enlisted to push the borders and points of control all the way out to their offshore suppliers while maintaining the ability to validate security from the point of origin to the points of destination. This program will re-invent border security by moving the control of product away from the ports.

In addition, the goal  is to engage the best of breed or emerging technologies that will provide electronic proof statements that monitor and report the movement of legitimate  cargo in transit prior to reaching the border. Total asset visibility and authentication are the desired end state.

This ideal state of  tracking and in-transit reporting would integrate technology for locating and in-transit alerting capability. It would also provide evidence regarding: loading of shipments in a secure facility; by authenticated personnel; verification of contents of the shipment, security of the container from origin, transmitting the content information and manifest information to Customs and other stakeholders upon loading, being able to identify and report container tampering, and allow Customs to verify the integrity of the container in a non-intrusive manner at the port of entry.

Developing the capability to filter the illicit from the licit trade in the face of increased terrorist threats and growing volumes of trade and commerce at previously  un-secured ports of entry is the challenge. The strategy for securing  cross-border and ocean-port trade from the threat of terrorism must balance the imperatives of adequate control while sustaining economic openness. Borders and  ports must be secure from catastrophic harm. They must also be able to support  the velocity of global trade and transportation.

The best means to  secure our global supply chains will be to move away from placing primary reliance on a system of control or inspection at the border. In order to push  the inspection back to the origin, Customs must have a partnership with importers, carriers and stakeholders who control variable elements at the point  of origin. These controls must be supported by all providers and carriers and be accompanied by a set of concentric checks built into a system prior to cargo arrival at ports of entry.

Effective trade  management will be based on a foundation of credible risk management and the  ability to reliably identify the personnel, goods and conveyances that are  legitimate. C-TPAT provides a comprehensive report on the state of security  within the entire profile of the company‚Ä™s supply chain.

Developing a common  standard for security practices that will govern the loading and movement of  cargo throughout the supply chain is the goal. These practices must provide  visibility in such detail that the cargo loading activity can be validated; and that the contents confirmed as secure throughout the transportation life of the product from origin to entry point. Delivering an electronic documentation that  travels with or validates the integrity of the cargo against compromise  throughout its travel cycle while securing the computer system(s) against  hackers or compromise fulfills the objective of a verifiable and secure supply  chain.

Until technology catches up with reality, C-TPAT provides verifiable evidence that your company and your related suppliers are watching every event in the supply chain. Your enrollment and compliance demonstrates that your company is above reproach in  the area of security and that all appropriate efforts have been taken to assure  that each event in your supply chain is managed. Every person must understand his or her role in smart, secure and efficient trade.

In order to enroll in  C-TPAT and contribute to our national security agenda, you must: Sign the Memo  of Understanding, Conduct a Self-Assessment, Complete a Supply Chain Security Profile Questionnaire, Develop Corporate Supply Chain Program enhancements, Communicate Security Guidelines with Supply Chain Partners, and Demonstrate  Acceptable Levels of Trade Compliance. Is C-TPAT for you? Yes, if you want to do your part in preventing the advance of terror into or through your own supply  chain. Yes, if you are concerned about keeping priority and velocity in your  supply chain. Yes, if you want to be part of a more secure global trading  system.

Steve Schellenberg is currently involved with IMS Worldwide in Houston as a Senior Consultant and Marketing Project Manager. IMS provides Foreign-Trade Zone management, consulting and operations and is also engaged in providing assessments and validations in Homeland Security relative to supply chain  security, site and facility threat and risk assessments and C-TPAT evaluations.

Prior to joining IMS,  Steve has worked in the air cargo industry both in freight forwarding, ad hoc charter operations and with a global integrated carrier. Steve managed the operations and sales for BAX Global in Laredo, San  Antonio, El Paso and Monterrey, Mexico and has extensive experience in managing all aspects of trade in this region. He also started the operations for EG&G Logistics, Kelly Distribution Center in San Antonio as  Business Development Director and is currently the Chair of the Logistics Task  Force, Free Trade Alliance, San Antonio.

Steve lives in San Antonio and is a member of the Board of Directors of the San Antonio Transportation Association  and currently serves in the role of First Vice President, he is also on the Board of the Free Trade Alliance, San  Antonio.

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