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Supply Chain

Straight Talk About C-TPAT

By Rennie Alston, President, ARI Customs Compliance

C-TPAT (Customs–Trade Partnership Against Terrorism) is a voluntary initiative — a joint government-business partnership to enhance supply chain and border security. Although the initiative is mentioned frequently, it’s not always fully understood. Rennie Alston, president of ARI Customs Compliance and an instructor at The World Academy, helps answer some of those frequently asked questions.


Question 1: What are the benefits for importers in participating in the C-TPAT program?

Alston: An immediate benefit of the program for importers is decreased cargo exams. Import shipments that are subjected to U.S. Customs examinations face increased costs of such exams in the form of U.S. port examination charges, container stripping charges, cargo transfer charges and storage and demurrage charges. Fewer exams means fewer costs and an immediate positive effect on the corporate bottom line.


Questions 2: If a company joins the C-TPAT program, do they avoid Customs Focused Assessment Compliance Audits?

Alston: No. But by joining the C-TPAT program, an importer does become eligible to join the Importers Self Assessment (ISA) program. The ISA program allows an importer to conduct an annual internal self-assessment of their own compliance profile and to determine and address risk areas and corrective action elements within their regulatory compliance profile.

Members of the ISA program are removed from the Focused Assessment Audit schedule conducted by the Office of Strategic Trade and Regulatory Audit division of U.S. Customs and Border Protection.


Question 3: Is it costly to become C-TPAT certified?

Alston: Many companies are able to implement process and procedures to satisfy many minimum program security standards with just a minimal investment.
Security enhancements in certain areas may require an investment, but all expenditures are offset by increased efficiency. A secure supply chain is a more efficient supply chain, and efficiency saves an importer unnecessary expense, such as foreign demurrage charges, unnecessary delays in the port of loading and overcharged foreign inland freight charges previously included in foreign shippers’ profit centers.



Question 4: What is the difference between C-TPAT certification and validation?

Alston: Once an application is approved, a company is certified. The certification process is simple. A company files an application using the Customs Web portal application, which CBP then reviews. The process takes approximately 90 days.

Once certified, CBP conducts an on-site visit to the company, within a year, to verify the information in the application. CBP also visits a foreign business partner of the certified company to ensure that minimum security practices are also in place at the foreign business partner’s location. If CBP is satisfied with their findings after completing the reviews, CBP will validate the C-TPAT participant. 



Question 5: Is a C-TPAT validation like a Customs regulatory audit?

Alston: Absolutely not. The C-TPAT validation certifies that a C-TPAT participant has achieved its Tier 1 certification status. The validation is an on-site verification of the participant’s online application details. It is an opportunity for both CBP and the C-TPAT participant to work together to share supply chain details, recommendations, improvement possibilities and security details to complement the existing commitment of the C-TPAT company. The validation team does not address Customs compliance issues associated with regulatory audit topics.



Question 6: If I have a related company in the United States that is also an importer of record operating under a separate Employer Identification Number (EIN), can our company join C-TPAT independent of that related entity?

Alston: Yes, a company may join the C-TPAT program independent of another related entity operating under a unique importer identification number. Your C-TPAT application would detail the security elements of your specific import supply chain profile addressing elements that pertain to your specific EIN and business unit security management practices.


Question 7: Does my company have to install a fence around our facility to become C-TPAT certified?

Alston: No. Fencing is not a requirement, but it is a recommendation to demonstrate perimeter access controls. Perimeter access controls can be achieved in other ways than just fencing. A C-TPAT security supply chain specialist will work with your specific company to recommend the best ways for your company to secure perimeter access controls.


Question 8: How many companies are currently involved in the C-TPAT program?

Alston:There are nearly 8,500 certified companies, and approximately 7,785 have been validated. And these numbers are continually increasing.


Question 9: Can my company apply for C-TPAT without the assistance of a third party?


Alston: Yes, there are many companies that have delegated the responsibility of C-TPAT application and management to their internal resources.

Companies that look for third-party assistance often look to consultants and Customs brokerage firms. These third-party companies can be valuable to potential C-TPAT applicants. They represent a level of expertise in the application process, minimum security standards, and the execution of those standards.