CBP Commissioner Discusses C-TPAT, Etc. At Recent TSN Meeting

Future Two-Tiered System of C-TPAT Benefits

Commissioner Bonner states that he forsees a two-tiered system of C-TPAT benefits, based on the level of security, validation results, and use of "best practices" like the Smart Box, and taking ownership of the supply chain.

First tier. According to Bonner, first tier, certified, C-TPAT importers, for example, who met C-TPAT minimal security criteria, would receive, as now, a lower Automated Targeting System (ATS) score and fewer inspections upon arrival.

Second tier. Bonner also states that second - or higher tier C-TPAT partners, i.e., certified, validated C-TPAT importers using C-TPAT best security practices would get the "Green Lane" - no inspections for security.

This would be a more secure supply chain that includes point of origin security, security at point of stuffing, ensured by C-TPAT validated partners who control their supply chain and assure point of origin security, who use a smart container (Smart Box), or see that their foreign vendors do, and who ship their goods through a Container Security Initiative (CSI) port to the U.S. According to Bonner, these are the types of shipments that would get the "Green Lane" upon arrival (i.e., subject to only relatively infrequent random inspections or inspection where a shipment is subject to specific tactical intelligence as a security or enforcement threat).

(Bonner notes that a more secure, smarter container - the Smart Box - should be implemented as soon as the technology to reduce false positives to an acceptable level is available.)

Improvements to C-TPAT

In his remarks, Commissioner Bonner also notes that there are three important things that CBP is doing to improve C-TPAT:

• more clearly defining the point of stuffing security criteria. Bonner states that CBP is now more clearly defining the point of stuffing security criteria for C-TPAT members, especially for C-TPAT importers and their foreign vendors and manufacturers. CBP notes that as a result of dialogue and discussion with the trade community, it has defined more clearly the C-TPAT security criteria at point of origin or stuffing.
• more clearly defined minimum security criteria for C-TPAT membership. Bonner also states that CBP has engaged in a dialogue with the trade, and especially with importers, to better and more clearly define minimum security criteria for C-TPAT membership. (See ITT's Online Archives or 01/13/05 news, 05011305, for BP summary of Draft 3 of CBP's new C-TPAT Security Standards for Importers.)
• ensuring that CBP has more specific, "validatable" criteria. Bonner notes that CBP is implementing a Validation Plan that will result in the validation of every certified C-TPAT partner, at least part of its supply chain. According to Bonner, 10% of all certified C-TPAT partners have had critical aspects of their supply chains validated by CBP, and another 20% are in the process. Bonner emphasizes that C-TPAT partners are expected to meet their commitments, and if they don't, they will be decertified and lose C-TPAT benefits.

Commissioner Bonner also notes that CBP has decertified 35 C-TPAT members because of negative validations and violation of their commitments and that 54 C-TPAT members have had C-TPAT benefits suspended because their supply chain security was compromised.

Commissioner Bonner states that the priority focus for CBP validations is the importer's foreign vendors and transporters and foreign transportation, from the point of origin to the point of arrival in the U.S. Bonner notes that because the terrorist threat is external to the U.S., CBP is not focusing its validations on domestic warehouses or purely domestic transportation.

CBP's Progress on "One Window" into Government for All Trade Data

In his remarks, Bonner also updates the TSN on CBP's progress in establishing "one window" into government for all trade data, by stating that there are now 26 agencies participating in the International Trade Data System (ITDS) link to the Automated Commercial Environment (ACE). According to Bonner, most recently, the Transportation Security Administration (TSA) has joined ITDS to ensure its needs for cargo security data are addressed through the single ACE portal.

(CBP noted at its recent Trade Symposium that ITDS currently has 26 Participating Government Agencies actively engaged in defining and designing an integrated government solution for cargo security through the development of ACE and that CBP is working hard to expand that participation to all agencies with a role in international trade.

CBP has previously stated that the first ITDS participating government agency, the Federal Motor Carrier Safety Administration (FMCSA), was to begin using ACE/ITDS in conjunction with ACE Release 4.)

New TSN Supply Chain Security Committee. Commissioner Bonner also announces in his remarks the creation of a new TSN Supply Chain Security Committee on which over 50 TSN members have volunteered to serve.

Commissioner Bonner's remarks at TSN meeting (dated 02/01/05) available at

http://www.cbp.gov/xp/cgov/newsroom/commissioner/speeches_statements/feb022005.xml.