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United States Customs had the responsibility to ensure that goods arriving in the country comply with regulations such as documentation, records in US agencies, labeling and marking, certifications, fumigation, ownership. intellectual, the correct selection of tariffs and the payment of tariffs.
After September 11, the US government UU It created the Department of National Security as a Cabinet department focused on the establishment of new policies, guidelines and regulations to improve security in international trade, prevent possible attacks by terrorists and guarantee a safe passage and not manipulated. of materials in US ports.
Customs were transferred from the Treasury Department to National Security and became Customs Borders and Protection (CBP). CBP assumed greater responsibility in meeting National Security objectives by keeping US ports safe. UU And implement several initiatives since September 11 to improve security.
They focus primarily on the sea ports of origin to prevent dangerous substances from being loaded on ships bound for the United States, as well as on the safe movement of cargo across the borders with Mexico and Canada.
One of the challenges facing the agency is the inability to open and inspect every container that arrives at US ports. UU And that crosses the borders. This is due to labor limitations and the significant volume of cargo that arrives in the country: the vast majority of containers are not open and are not controlled by CBP, which leaves most of the containers open to threats potential
The customs-commercial association against terrorism is born
One of the biggest initiatives that the CBD has launched since its inception is a program called the Customs and Trade Association Against Terrorism or C-TPAT. Since CBP can only inspect a small percentage of incoming containers, the agency presented C-TPAT as one of the efforts to ensure a higher level of safety over non-inspected containers.
C-TPAT was designed to build cooperative relationships that strengthen international supply chains and border security in the United States. It seeks to safeguard the global trade industry of terrorists while maintaining the economic health of the United States and its neighbors.
This program is a voluntary partnership between the government and the private sector that encourages registered importers to ensure their import processes from foreign suppliers at their locations so that containers arrive without potential problems.
Once an importer feels that their import processes meet the CBP standards, schedule a review for C-TPAT eligibility. A CBP representative meets with the importer to review the processes of all locations, identify the necessary improvements and, ultimately, move towards the importer's registration.
How C-TPAT benefits the supply chain
C-TPAT for CBP guarantees the safety of non-inspected containers through best-practice processes implemented and administered by registered importers.
The benefits for the importer may include:
- A reduced possibility of inspection
- An increase in the public image.
- A dedicated link from CBP
- A reduction in interruptions in the supply chain.
- Greater security of the goods.
- Faster cargo movements through Mexican and Canadian ports and borders.
- Special port entry by product type.
- Possible lower insurance premiums
- Possible mitigation of liquidated damages claims in the importer's security presentation
As of May 2019, there are more than 11,400 certified C-TPAT members in the program, including US importers UU., The carriers of highways of EE. UU / Canada and USA UU / Mexico, and authorized US customs agents. UU These companies represent more than 52% of the products imported to the United States.
How to obtain the C-TPAT certification
The process to request the C-TPAT program is quite simple. First, companies must complete an online application on the CBP website. The application includes three parts: the corporate information of the company, a security profile of the supply chain and a recognition of agreement to participate voluntarily.
To complete the security profile of the supply chain, companies must conduct a rigorous self-assessment using the C-TPAT guidelines. This evaluation includes a review of:
- Physical security – List of facilities, activities and hours of operation, security guards, perimeter security devices, blocking devices, lighting, alarms and cameras / sensors used in all places.
- Physical access control – Access control for employees, visitors, suppliers and vehicles.
- Security Personnel – Recruitment policies, citizenship verification, employee misconduct, background investigations and dismissal procedures.
- Information security – Policies for the use of ID, passwords, email and Internet, as well as for the security of hardware and software.
- Procedural security – Policies of sending and receiving hazardous, surplus and missing materials, security in the warehouse, review of documents and maintenance of records.
- Training and awareness in security. – Policies related to C-TPAT, security and protection training, and related procedures
- Transport security – Policies for the control of seals (locks in containers), inspection of containers and seals, and storage of containers.
- Requirements of the business partner – Policies related to the selection, management and evaluation of brokers, carriers, suppliers and warehouses.
C-TPAT methodology and the 5-step process of CBP
An organization can select a dedicated internal team or hire an external consulting organization to perform the tasks listed below, taking into account the eight areas of the C-TPAT evaluation. The team must review current, documented and undocumented policies, procedures and safety programs. The organization can hire additional staff for review and implementation.
- Map of cargo flows and supply chains
- Conduct threat assessments.
- Identify security vulnerabilities and weaknesses and rate them.
- Prepare an action plan to address security weaknesses.
- Document the procedures for risk assessment, audit and annual review.
The evaluation includes interviews with those responsible for the various security areas and a tour of the physical distribution and corporate facilities, including those of external organizations in the importer's supply chain.
Once an organization has its map "as is" and has identified the gaps to reach the C-TPAT status, it can begin to implement training and improvement processes.
Weighing the ROI of the C-TPAT investment
Although CBP does not charge companies for participating in the C-TPAT program, companies will often have to invest to improve their practices and meet minimum safety requirements. The three largest costs of implementation of C-TPAT incurred by importers are:
- Improve or implement physical security.
- Improvement or implementation of IT systems / database development.
- Salaries and expenses of personnel hired or hired specifically to implement and / or administer the C-TPAT program
The costs of the C-TPAT certification for ongoing maintenance may include:
- Salaries and expenses of personnel hired / hired specifically for the implementation of C-TPAT
- Improve or implement the use of security personnel.
- Improve or implement physical security.
CBP offers three levels of certification for importers:
Tier I – Certified C-TPAT Partner
This is the most basic level of certification and is granted upon successful completion and acceptance of a request. Some of the benefits include:
- A reduced number of exams compared to importers that are not C-TPAT
- Shorter waiting times at the border.
- Access to ReE and Secure Trade (FAST) lanes at land borders, including accelerated cargo processing.
- Inspections in front of the line.
Level II – Minimum criteria met and validated
This level of certification is designed to recognize companies that have done more than just the minimum security requirements. This level of certification offers some additional advantages:
- The same benefits as Level I
- Reduced risk profile.
Level III – Exceeds minimum safety standards
This level of certification is granted to companies that have adopted the best practices, have layers of defense interconnected and are actively supervised by the administration staff. Some of the benefits of this level include:
- Benefits of levels I and II
- True "green lane" treatment with zero or infrequent safety inspections
- In case the container is selected, it receives priority and moves in front of the examination line.
Impact of the total cost of C-TPAT
There are significant costs incurred by a registered importer when reviewing, updating processes, implementing and maintaining a C-TPAT program. These costs are now part of the total cost of the organization.
However, the costs of interruptions in the supply chain, delays in the dispatch of shipments from the seaport, additional charges in the port or in the deposit due to the inspection, additional tariffs of the customs agents, delays and sanctions to The organization's own clients, etc., are also part of the total cost of the land.
The registered importer must identify whether the reduction in shipping problems due to the C-TPAT registration has a dollar value greater than the implementation costs. But the organizations now registered in C-TPAT are, in fact, seeing positive results in their total download costs.
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