Global Trade Security Program Compliance

Customs-Trade Partnership Against Terrorism (“C-TPAT”) is a voluntary program through which U.S. Customs and Border Protection (“CBP”) and companies work together to strengthen the security measures that are applied to international supply chains in order to ensure the integrity of shipments that arrive at the U.S. border.

CBP developed C-TPAT after 9/11 to encourage importers, carriers, consolidators, customs brokers, and manufacturers to adopt and maintain certain security measures for their imports of merchandise into the United States. When a company opts to join C-TPAT, it is required to address a broad range of security topics, present security profiles, maintain security measures, and work with their foreign supply chain partners (i.e., suppliers and service providers) to adopt the same types of security protocols.

In exchange for participating in C-TPAT, CBP promises various benefits, such as reduced inspections, priority processing when CBP inspections do occur, and expedited customs clearance of shipments. C-TPAT participants are also eligible to apply for participation in the Importer Self-Assessment (“ISA”) program, which exempts importers from comprehensive audits.

In addition, CBP has entered into various Mutual Recognition Agreements with foreign customs administrations. The essential concept of Mutual Recognition is that C-TPAT and the foreign program have established a standard set of security requirements which allows one program (e.g., C-TPAT) to recognize the validation findings of the other program (e.g., AEO). CBP has signed Mutual Recognition Agreements with:

New Zealand (New Zealand Customs Service’s Secure Export Scheme Program or “SES”)
Canada (Canada Border Services Agency’s Partners in Protection Program or “PIP”)
Jordan (Jordan Customs Department’s Golden List Program or “GLP”)
Japan (Japan Customs and Tariff Bureau’s Authorized Economic Operator Program or “AEO”)
South Korea (South Korea Customs Service’s Authorized Economic Operator Program or “AEO”)
European Union (EU’s Taxation and Customs Union Directorate AEO); and,
Taiwan (Directorate General of Customs, Taiwan Ministry of Finance’s Authorized Economic Operator Program).

Both C-TPAT companies and companies participating in the above-referenced foreign security programs are considered trusted members of the trade community whose security standards have been validated by either CBP or the Foreign Customs Administration. Therefore, C-TPAT importers that also export and AEO manufacturers or exporters of record are given a reduction in their risk score by both Customs Administrations, thereby translating into fewer examinations at the port of importation.

Miller Proctor Law assists companies in –

Assessing the current status of their supply chain security compliance and readiness for application to participate in C-TPAT
Completing the C-TPAT Memorandum of Understanding (“MOU”)
Completing the Supply Chain Profile Questionnaire
Assistance through CBP’s C-TPAT validation process

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Melissa M. Proctor

President and CEO