CBP Plans to Add Forced Labor to CTPAT Trade Compliance by September

CBP would like to add a forced labor component to the Customs-Trade Partnership Against Terrorism (CTPAT) program's trade compliance requirements by the end of this fiscal year, CTPAT Director Manuel Garza said in a government issue paper released ahead of the July 15 Commercial Customs Operations Advisory Committee meeting. The fiscal year ends Sept. 30. There's been discussion about adding such a component for a long time (see 1907250029), but CBP hadn't previously provided firm timing plans.

Garza also said CBP plans to accept “new applications for the Trade Compliance Program by the end of FY2020.” CBP last summer began transitioning Importer Self Assessment program participants and in March “the remainder of the former ISA companies were instructed to provide their information and create a business profile in the Trade Compliance Portal.” CBP allows participants to choose whether to participate solely in “CTPAT-Security or to expand to CTPAT-Trade Compliance,” the trusted trader working group said. “However, to be eligible for the Trade Compliance portion, participants must also comply with the Security module of the CTPAT-Trusted Trader program.”

The working group also released some recommendations for how to improve the program. As part of that, CBP should develop metrics to measure the performance of benefits and release some results online annually, it said. “For instance, CBP could publish the average percentage of extensive examinations, and in-person validations that non-CTPAT Trusted Trader companies experienced vs program participants, etc.” Such metrics would help the agency consider when a “benefit should be phased out or needs to be modified, based on the assessment results,” it said.

CBP should also increase its transparency around considering possible new benefits for the program, the working group said. “COAC recommends that CBP develops and documents a formal process to receive and process feedback on existent benefits, as well as suggestions for new potential benefits from both CTPAT Trusted Trader Program members, PGAs, Non-government organizations and the general public,” it said. It also recommended that CBP open a public comment period to share benefits being considered and request more input “to be included in the evaluation process.”