CBP Updates Info on C-TPAT Mutual Recognition, Lists Prerequisites

November 1, 2012 by Tim Warren|Customs

CBP posted an updated document on the mutual recognition of Customs-Trade Partnership Against Terrorism (C-TPAT) and foreign industry partnership programs. The document closely follows CBP's August version.

Goal is to Recognize Another Country's Security Program

The concept of mutual recognition (MR) is that C-TPAT and a foreign industry partnership program are compatible in both theory and practice, so one program may recognize the validation findings of the other program.

Before CBP engages a foreign Customs Administrations towards mutual recognition, three prerequisites must be met:

The foreign Customs Administration must have a full fledged operational program in place -- i.e. not a program in development or a pilot program.
The foreign partnership program must have a strong validation process built into its program.
The foreign partnership program must have a strong security component.

CBP cautions that MR does not exempt any partner, whether domestic or foreign, from complying with other CBP mandated requirements. By the same token, mutual recognition does not replace any of CBP's cargo enforcement strategies. For example, importers still need to comply with the importer security filing requirements. CBP has developed guidance for maintaining the continuity and/or restoring the flow of trade across the Nation’s borders during and after an incident that disrupts the flow of trade at the border ports of entry. Business resumption privileges consideration, however, while envisioned for C-TPAT members, is not a factor that is included in any mutual recognition arrangement.

(The C-TPAT MR process involves the following four phases: (i) a side-by-side comparison of the program requirements; (ii) a pilot program of joint validation visits; (iii) the signing of a mutual recognition arrangement; and (iv) the development of mutual recognition operational procedures.

CBP Has Signed 6 MRAs

CBP has already signed MR Arrangements with New Zealand (June 2007), Canada (June 2008), Jordan (June 2007), Japan (June 2009), Korea (June 2010) and the European Union (May 2012).

(See ITT's Online Archives 12050726 for summary of the mutual recognition agreement with the EU.