C-TPAT Update

Dear Friends:

US Customs and Border Protection recently released an update on the Customs-Trade Partnership Against Terrorism (C-TPAT) program that we thought you might find to be of interest.  A copy of the update itself can be found here.

The update, which is current through September 4, 2013, indicates that:

  • There are currently 10,643 certified C-TPAT members.  Of that amount, approximately 40% are importers.  Approximately 7% of importer members have been certified as Tier 3 (i.e., 4,340 of 10,643 members are importers; and 330 of the 4,340 importers are certified as Tier 3).
  • The number of C-TPAT validations/revalidations have continued to drop year-on-year.  The updates states that there was a total of 1,284 validations/revalidations in 2013 versus 2,376 validation/revalidations in 2012 (i.e., a drop of more than 50% year-on-year).
  • Interestingly, the number of suspensions/removals (which presumably includes companies voluntarily leaving the program; something which has also been increasing in recent years) at almost 3,000 companies.  This would mean that upwards of 25% of all C-TPAT members have left the program for one reason or another.

While all importers should take steps to secure their international supply chains, there are a number of concerns with the C-TPAT program itself.  The fact that there is no legislation, or even regulation, governing the program means CBP is more or less free to modify the program at will.  As a result, the requirements imposed on importers participating in the program have steadily increased over the years; while the promised tangible benefits have failed to materialize for most participants.  Unfortunately, we expect this trend to continue well into the future.

If you are currently a C-TPAT member and have any questions about your annual risk assessment program, upcoming validation or revalidation, or about voluntarily withdrawing from the program, please let us know.  If you are considering applying to participate in the C-TPAT program, we recommend that you make sure that management understands the evolving nature of the requirements so that issues do not arise down the line (i.e., the company making promises it is not able to keep).

We hope that this update is helpful.

Best regards,

Ted

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