Trusted Traders Deserve Differentiated CEE Treatment, COAC Says

Now that all of the industry-focused Centers of Excellence and Expertise are fully operational, members of the Importer Self Assessment and Customs-Trade Partnership Against Terrorism programs should get a "higher level of service," the Commercial Customs Operations Advisory Committee (COAC) Trade Modernization Subcommittee said in a list of draft recommendations (here). The recommendation is among a wide range of recommendations planned for discussion at the COAC meeting on April 27 (see 1604250011). CBP's treatment of trusted traders should include "enhanced communication, accessibility and responsiveness (including updates and trends to increase or maintain compliance) with their National Account Manager (NAM) or other Center representative," the subcommittee said.

CBP should consider reorganizing the C-TPAT office to mirror "the industry specific Centers concept," the group recommended. That would "enable the respective industries to work with dedicated Supply Chain Security Specialists (SCSS), in coordination with NAMs and/or Center representatives to provide enhanced benefits to C-TPAT accounts," it said. Upon request from a "trusted partner." CBP should also request input from a CEE "when a petition is filed involving seizures, penalties or liquidated damage claims," it said. As prescribed the customs reauthorization law, CBP should consider the CEEs as it works with partner government agencies on shared trusted trader programs, it said. The agency ought to "pilot such shared trusted partner/trader programs with one to two PGAs at a time, prioritized based on Center and importer feedback," and "solicit input on from the PGAs on trusted trader benefits," it said.

Other possible benefits at the CEEs for trusted traders could include expedited entry, screening and release; reduced examination or expedited processing, said the group. "Particularly for trusted partners (C-TPAT or ISA), the Centers should provide problem resolution contacts and work with the Ports to grant the importer “preferred location designation” to provide flexibility in the exam location, where practicable, in the event cargo must be held for exam or review. Trusted partners should also receive expanded permission to use electronic and/or blanket certifications/authorizations over transactional/paper requirements," said the working group.

Better communication from the Centers is also recommended. Each CEE should get its own webpage that includes "a collection of existing and current industry based information, decisions and publications," the group said. CBP and industry should also use a "single automated platform enabling ACE account holders and the Port, Centers and [Fines, Penalties and Seizures] to communicate on enforcement issues such as seizure, penalty or liquidated damage claims, particularly those involving trusted partners," the COAC group said. The agency should also consider "whether to integrate Drawback with Centers once automation is deployed."