C-TPAT Update

Dear Friends:

We thought that you might find the FY2013 update on the Customs-Trade Partnership Against Terrorism (C-TPAT) program recently released by U.S. Customs and Border Protection to be of interest.  A copy of the update itself can be found here.

The update indicates that:

  • There are currently 10,675 certified C-TPAT members.  Approximately 40% of members are importers.  Approximately 8% of importer members have been certified as Tier 3.
  • The number of C-TPAT validations/revalidations have continued to drop year-on-year.  The update states that there was a total of 1,626 validations/revalidations in FY2013 versus 2,376 validation/revalidations in 2012 (i.e., a drop of more than 30% 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 approximately 1-I out of-4 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 that CBP is free to modify the program at will.  As a result, we have seen the program’s requirements steadily increase over the years; while, at the same time, 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, 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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