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Are You Ready for a C-TPAT Exporter Security Regime?
Bill Ferguson, NYK Line (North America) Inc.
U.S. Customs and Border Protection (CBP) is working with the Commercial Operations of Customs and Border Protection (COAC) Exports and Trusted Trader Subcommittees to co-create a future new export process model and trusted trader program for Trade's consideration. Are you ready for a C-TPAT for exports? If you are an importer that also exports or a pure exporter, a carrier, a forwarder, FTZ, or any other intermediary you may want to begin to follow this activity.
C-TPAT Director Ms. Lauren Kauffer has advised the Advisory Committee on COAC that, "...U.S. exports are already receiving benefits from our Mutual Recognition Agreement (MRA) partnerships at cargo delivery overseas." CBP has been in earnest discussion with foreign customs authorities regarding delivery of reciprocal facilitation benefits for U.S. exports at ports of unlading and final delivery in recognition of applying mutually recognized security and trade compliance criteria applied to U.S. exports. CBP has in a limited and low profile project offered importers that also export the ability to declare C-TPAT practices are being followed for exports as well. These commitments have been communicated to U.S. MRA partners informally by CBP. The importers that also export have declared that they have seen marked improvement in expected delivery of their exports and fewer inspections as result of the program. These facilitation benefits have been experienced primarily in the EU and Japan.
Based on the success of the informal pilot and the need to establish a reciprocal regime for U.S. exports modeled after U.S. requirements for C-TPAT for imports, CBP is considering adding a new exporter entity to the C-TPAT suite of supply chain security profiles as soon as this Spring. CBP has recognized early on that U.S. exports are not imports and the criteria will have to be tailored to facilitate exports as well as enhance security to achieve trusted trader status with our MRA partners.
A group of trade representatives assembled this list of draft criteria that might be explored at the time of an Exporter's C-TPAT eligibility evaluation or validation. This list is not all inclusive and is in no way a representation of CBP's intention in this regard; it is for general discussion purposes only.
C-TPAT Exporter Security Survey
- How do you verify and maintain safe cargo/product?
- How do you verify Business Partners?
- Do you conduct initial and periodic physical checks to verify standards are being met?
- Do you perform background checks beyond financial review to include factors that might contribute to a security risk?
- How do you check and verify compliance with export compliance regulations?
- How do you verify that received goods meet your specifications?
- What modes do you ship (air, ocean, truck rail, etc.)?
- To what countries do you export?
- Do you ship directly or through an intermediary?
- If you use intermediaries how do you verify quality of services and ensure the integrity of cargo to be exported is maintained?
- Can you provide details of your receiving and shipping processes?
- What type of conveyances do you utilize when exporting goods, such as marine or air containers, trailers, rail freight cars/wagons, etc.?
- Are safety and security inspections performed upon receipt of equipment to be stuffed at your loading facility?
- Is cargo waiting to be exported stored in a secured area or facility?
- At the moment of stuffing into conveyances, is cargo inspected for safety and security?
- Is the conveyance checked for safety and security?
- Is the stuffing operation visually recorded by taking periodic images of stuffing throughout the loading process?
- If so, how long are images stored before archive or disposal?
- Are videos or photos archived?
- How long are the archives maintained?
- What is the process to retrieve archived records?
- Upon completion, is a final photograph or image taken for the cargo prior to closing and securing of the doors?
- Upon completion of stuffing of cargo for export who verifies loading is complete and closes the doors?
- Upon completion of stuffing of cargo for export who applies the ISO 17712 high security seal?
- Is the party finally verifying the load and sealing the conveyance the same party who stuffed the container?
- During loading operations, what are the procedures to report/resolve discrepancies?
- Are container seals applied at the loading dock or sealed in the yard?
- If sealed in the yard, how do you maintain security between completion of stuffing and application of the high security seals?
- Are seal numbers verified upon exit for the stuffing facility?
- How is the out-gate notified what seal number was applied and needs to be verified?
- What is the procedure for discrepancies at the out-gate?
- When arranging transport from the point of stuffing to the point of loading upon an exporting vessel , aircraft, or cross-border train, do you plan the route inclusive of physical route, transit time to destination, and consideration of time of day and hours of operation to avoid risks, including any idle time?
- Do you have procedures in place to verify date and time of delivery at destination or load port, such as requiring "proof of delivery" or other paper or electronic document verifying receipt?
- Can you describe procedures for mitigation of exceptions found during inland transit to final point of exportation?
Note: These criteria deliberately stop at the port of exportation as the reciprocal AEO criteria would be applied from loading onboard the export conveyance.
More information regarding progress of these initiatives can be found on CBP's website under Trade, Outreach and Advisory Committee on Commercial Operations of Customs and Border Protection (COAC): http://www.cbp.gov/xp/cgov/trade/trade_outreach/coac/
William (Bill) Ferguson is Vice President of Security Services for NYK Line (North America) Inc. and Group Security Officer for NYK Group Americas responsible for policy development and administration of NYK Group Security programs. Bill is a 30+ year shipping veteran. He began his NYK career in Secaucus in 1992. Prior to joining NYK he held positions in marine surveying, chassis pool supervision, equipment control, traffic, and operations with Marine Surveys, Maher Terminals, TTT Ship Agency, YS Line USA, and NLS (USA)/NLS Intermodal.