C-TPAT

**TIA Draft C-TPAT Security Criteria for Non-asset based Property Brokers 

Launched in direct response to the terrorist attacks of September 11, 2001, the C-TPAT program seeks to safeguard the world’s vibrant trade industry from terrorists, maintaining the economic health of the United States and its neighbors.  The partnership develops and adopts measures that add security but do not have a chilling effect on trade, often a difficult balancing act.
 
By extending the United States’ zone of security to the point of origin, the customs- trade partnership allows for better risk assessment and targeting, freeing Customs and Border Protection (CBP) to allocate inspectional resources to more questionable shipments.
 
CBP announced that third party logistics providers (3PLs) that meet certain criteria, may enroll in the C-TPAT Program beginning in January 2009.  Unfortunately, the draft criteria proposed by CBP indicates that few additional providers of logistics services, if any, will be able to meet the 3PL eligibility criteria.
 
CBP has indicated that non-asset based 3PLs that perform duties such as quoting, booking, routing and auditing but do not own warehousing facilities, vehicles, aircraft or any other transportation assets do not qualify for eligibility.
 
Property brokers represent a key component of the international movement of freight and the security of their operations is critical to ensuring overall supply chain security. These companies are responsible for thousands of international shipments each year totaling billions of dollars in freight, including daily cross-border movements at the U.S.- Mexico
and the U.S.- Canada borders.
 
TIA previously focused our efforts on CBP and the Commercial Operations Advisory Committee (COAC), a private sector advisory group who meets quarterly and advises Customs and the U.S. Department of Treasury on supply chain and trade policy.   
 
Having exhausted our opportunities with CBP and COAC, we now concentrate our efforts with the U.S. Congress’ Committees of jurisdiction and are bringing our case directly to Members of Congress.  We have been joined in this effort by the U.S. Chamber of Commerce’s Global Supply Chain Task Force.

Please click here to read the C-TPAT testimony from December 2, 2009.