CBP Describes Plans for Combined C-TPAT/ISA, Standalone C-TPAT to Remain

CBP's planned combination of trusted trade programs, a consolidation of Importer Self Assessment (ISA) and Customs-Trade Partnership Against Terrorism (C-TPAT), would require members of the combined program to meet ISA criteria, said Michael Ginn, director of CBP's C-TPAT Field Office. Ginn spoke on a panel Nov. 27 at the CBP East Coast Trade Symposium. The goal in combining the programs is to create a singular validation and management approach to the trusted trader program, said Dan Baldwin, CBP executive director for Cargo and Conveyance Security, who spoke on the same panel. “We are taking a more reasoned approach on how to validate a company’s compliance level," said Baldwin. "There is every reason to believe a small company is just as responsible and deserving of our trust as the large corporations.”

(CBP is working to boost enrollment in the ISA program, which is considered to have more stringent requirements than C-TPAT, and recently expanded the ISA program to allow for companies that passed a focused assessment to be deemed eligible for ISA. There's about 10,500 C-TPAT members and 250 ISA members, said Baldwin. See ITT's Online Archives 12100428 for summary of CBP's expansion of ISA to include companies that completed focused assessments.)

ISA Requirements

The move to a combined trusted trade program would mean existing C-TPAT members that want to participate in the new program would need to demonstrate ISA eligibility, though members to both the C-TPAT and ISA programs wouldn't need to do anything, said Ginn. "The way that we would roll out this program, existing C-TPAT and ISA members would be automatically rolled into the program," said Ginn. "There would be no further legwork for you to do. In the future our goal is to have one application process. We are hoping to roll all of this into one."

The hope is to provide a streamlined process, which also helps with budget issues, Ginn said. "We do not have any process in place for that, but that would be the ultimate goal, he said. "If you are in C-TPAT now but not ISA, you will still have to go through their process and satisfy the requirements before you’re brought in," said Ginn. Completion of a successful focused assessment in the last 12 months will also be enough to qualify a company in the "new trusted trader program as far as C-TPAT focused assessment," he said. CBP has found about 51 companies that have gone through such an assessment during the last year, he said.

Originally the hope was to consolidate the various supply chain programs among numerous government agencies, but establishing a single program across the agencies proved to be too difficult, said Ginn. The combined C-TPAT/ISA will serve as a foundation before CBP engages with other government agencies to join the new trusted trader approach, he said. There's much to be worked out with in the program, including the possible incentives involved, which will require a regulatory and statuary review, said Ginn. Involvement from the trade community will be important in that process, he said.

A combined ISA/C-TPAT will also mean a change to the ISA evaluation process, Florence Constant, CBP branch chief for Trade Policy and Programs in the Office of International Trade. "Our proposal and vision for the ISA evaluation process is to move towards a managed account process more than an audit-based approach," said Constant. "We're leaning away from that and using the subject matter expertise and using the resources we need when we need it. When a company imports widgets just from one particular country, their process is very simple. I do not think we need a barrage of subject matter experts to come in and spend days with a demonstration of your processes."

(See ITT's Online Archives 12051809 for summary of CBP Acting Commissioner David Aguilar's discussion of a possible C-TPAT/ISA combination during Congressional testimony.)

C-TPAT Would Remain

The combined C-TPAT/ISA won't mean the end of the C-TPAT alone program, said Baldwin. That program will continue to exist and to be it's own brand, he said. The combined program is meant to be the next stage of trade compliance for importers. The existing C-TPAT program will continue to be the best program for certain carriers, etc., while some importers will be better off within the ISA/C-TPAT program, he said.