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COAC Revises its Recommendations for Expanding C-TPAT at the Land Border, Etc.

U.S. Customs and Border Protection has posted amended recommendations of COAC’s Global Supply Chain Security Land Border Subcommittee. The amended recommendations largely ask CBP to obtain input from affected stakeholders.

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(See ITT’s Online Archives 11121319 for summary of December 7 COAC meeting at which the subcommittee’s recommendations were discussed.)

Recommends CBP Get Feedback on Add’l C-TPAT Tier 3 Benefits for Carriers

In the December 2011 posted recommendations, the subcommittee recommended that CBP establish Customs-Trade Partnership Against Terrorism (C-TPAT) Tier 3 status for U.S.-Mexico and U.S.-Canada highway carriers. The list of possible benefits, which has not been amended, includes recognition from CBP and from potential customers; invitations to participate in pilot programs; direct communication with C-TPAT program leadership; input in developing new security requirements and programs. This recommendation has now been expanded to state that CBP should also obtain feedback from various carrier associations regarding potential additional benefits that would be of interest to the industry.

Recommends CBP Get More Input on Security Criteria for Exporter C-TPAT

The Subcommittee also amended its recommendation that CBP develop C-TPAT status for exporters in order to facilitate mutual recognition and foster international support of C-TPAT by demonstrating reciprocity.

As amended, the recommendation has been shortened to remove specific language regarding the security criteria for exporters (e.g., trailer/container security, physical security, procedural security) and instead states that it is in the interest of the ongoing partnership for CBP to solicit input from COAC and other trade organizations to help develop the security criteria.

Recommends Establishment of C-TPAT Working Group

The Subcommittee has also formally added a recommendation that a C-TPAT working group be created under the Subcommittee. (The December 2011 posted recommendations did not include this recommendation, but the subcommittee discussed this recommendation during the December 7, 2011 COAC meeting.)

COAC Still Working on Recommendations for 3PLs, Foreign-Based Consolidators

The Subcommittee’s recommendations for third-party logistics providers and foreign-based consolidators remain unchanged but have been moved to a new section for recommendations to be further considered by the subcommittee.

(The December 2011 posted recommendations included (i) broadening the eligibility requirements for third-party logistics providers to allow property brokers to be included in the definition of 3PLs and (ii) establishing supply chain security criteria for foreign-based consolidators. However, at the December 7, 2011 COAC meeting, the subcommittee indicated that these two recommendations require further consideration.)