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If you analyzed the requirements and the reasons why one would join the Customs-Trade Partnership Against Terrorism when it was launched in 2002 and compared it to today, you would notice how much the program has evolved. The common denominator is that it was developed as a voluntary effort to protect the import supply chain from terrorists who could use one of the 9 million cargo containers that arrive in the U.S. each year to smuggle personnel, firearms and weapons of mass destruction.

If your company is considered the importer of record and/or the consignee, a carrier, port, terminal operator, customs broker, forwarder or consolidator, you should know that you’re eligible to join C-TPAT. Unlike conventional Customs’ initiatives, C-TPAT requires the applicant to create a C-TPAT team consisting of employees who have knowledge of your company’s operations, human resources, information technology and logistics.

The team should focus on procedural and physical security, access control, personnel security, education and training awareness, manifest procedures, conveyance security and information technology security.

There are several reasons why joining the program may leave the impression that the program is mandatory rather than voluntary:

• Eligible C-TPAT members are experiencing more inspections and audits when previously they had no inspections at all. A C-TPAT member will have comparably fewer inspections and audits.

• The ability to do business with existing customers or to be eligible to do business with a prospective customer. Many other industries are following the lead of the major retailers, which are in the forefront of requiring their current and future vendors to join C-TPAT.

• Customers are exerting pressure on the vendors’ U.S. suppliers when they are importing product into the United States. This is also evident because the imported product requirements are being extended to non-saleable items such as promotional products. For example, a major pharmaceutical company buys promotional product from a vendor representing different U.S. companies, which in turn imports its product from overseas. Both the vendor and all of the U.S.-based suppliers would be required to join C-TPAT.

• U.S. Customs officials urge importers to consider C-TPAT, often when the importer is working with Customs officials on conventional issues, such as duties, tariffs and country-of-origin matters.

The preceding is excerpted from an article by Ronald Jaspan that originally appeared in The Journal of Commerce. Mr. Jaspan is president of our C-TPAT consulting partner Norman Jaspan Associates Inc., a New York-based management consulting firm. He can be contacted at (516) 239-4611, or at ronald@normanjaspanassociates.com.
 

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