C TPAT Audit Requirements

The Customs-Trade Partnership Against Terrorism (C TPAT) is a voluntary support program led by US Customs and Border Protection (CBP) focused on improving the security of private companies’ supply chains via a C TPAT audit.

C TPAT is a voluntary program where participants work to protect supply chains from the concealment of terrorist weapons including weapons of mass destruction.

What is a C TPAT audit?

The Customs and Trade Partnership Against Terrorism (C TPAT) is a joint US government and business voluntary program to build co-operative relationships that strengthen the global supply chain and border security by improving security for the transportation of persons, conveyances, and cargo throughout the commercial shipping process. This audit ensures all merchandise shipments going to the US are handled in accordance with C TPAT requirements.

What are the C TPAT requirements?

C TPAT was established in November 2001 in response to the September 11 terrorist attack in New York. The voluntary incentive-based program partners work with members of the trade community to strengthen global supply chain security and to prevent the supply chain from being compromised by terrorist organization.

Many companies are eligible for C TPAT membership including importers, exporters, third-party logistics providers, consolidators, air carriers, cross-border highway carriers, marine port authorities, ocean carriers, rail carriers, terminal operators and custom brokers.

For an importer to be eligible to join C TPAT they must be;

  • Active importer or a non-resident Canadian importer that has imported goods into the US within the past 12 months
  • Have an active US importer of Record (IOR) number
  • Have a valid continuous bond registered with Customs and Border Control
  • Operate a business office staffed in the US or Canada
  • Designate a company officer who is the primary cargo officer responsible for C TPAT
  • Commit to maintaining the C TPAT supply chain security criteria outlined in the C TPAT Importer Agreement
  • Complete a supply chain security profile in the C TPAT portal and identify how it will develop
  • Have no unpaid debt owed to CBP at the time of the application.

What is C TPAT compliance?

There are certain controls needed to ensure your business is C TPAT compliant and making sure you have all the correct documents is a very important aspect.

For personnel you must have a contract with employment agencies that includes background screenings including DMV, FBI, and export control screenings. You must keep a copy as proof the screening took place.

For business partners you must review and screen your customer database, vendor/supplier database, transactional partners, and service providers. Also, your foreign suppliers must complete and submit their C TPAT questionnaire to you and identify any weaknesses, have an improvement plan, and retain all such documents.

For carriers; you must seek and retain the C TPAT certificate. This shows due diligence by keeping your own files and this is vital when validating your C TPAT status.

For IT and technology access you can use your C TPAT manual alongside any technology control plans you may have for export control purposes and must keep all documents including a wide-aisle tour plan to avoid sharing any controlled technology with authorized people. Keeping proof of internal audits and reviews is a must to ensure all procedures are in place and being followed.

For physical access you should keep card swipe records near to your C TPAT records, photos of security and barriers, copies of truck drivers’ licenses, videos of validation of those granted access to your facilities, visitor procedures and these records should be sealed in containers.

What is the main purpose of the program?

The C TPAT program has many benefits including:

  • Playing an active role in war against terrorism
  • A reduced number of CBP inspections
  • Priority processing for CBP inspections
  • Eligibility to attend C TPAT training lectures
  • Prerequisite for participation in the importer self-assessment program
  • Penalty mitigation under certain circumstances
  • Assigned a security consultant and a supply chain specialist
  • Tier III importers allowed block designation application to DHS Safety Act
  • Exporters who allow CBP to share information with other customers agencies gain reduced inspections upon arrival in certain countries

How long does it take to become certified?

C TPAT is voluntary and there are no costs associated with joining this program. Also, a company does not need an intermediary in order to apply to the program and work with CBP. 

The application is easy and can be completed online. Firstly, a company needs to review the C TPAT Minimum Security Criteria to ensure their business is eligible for the program. Secondly, the company should submit the application via the C TPAT Portal and agree to participate.

Thirdly, the company must complete a supply chain security profile, and this explains how the company is currently meeting C TPAT’s security criteria. Therefore, a risk assessment is also necessary. Lastly, the C TPAT program has up to 90 days to certify the company into the program or to reject the application. Once certified, the company will be validated within a year of certification.

What does a C TPAT audit involve?

HQTS is a third-party inspection company that can audit the following in relation to C TPAT:

  • Vital Items
  • Container Security
  • Physical Security
  • Information Technology
  • Conveyance Security
  • Physical Access Controls
  • Procedural Security
  • Security Training and Threat Awareness

About HQTS

With over 25 years of experience in quality assurance, HQTS is ready to help your company become C TPAT compliant. Our many service locations are prepared to be your one-stop-shop for your audit needs, Including, production monitoring, pre-shipment and sorting inspections and everything in between. Contact us today to find out how we can help you navigate food quality control challenges.

Sources:

https://legal.thomsonreuters.com/en/insights/articles/determining-if-your-organization-is-ctpat-eligible

https://www.descartes.com/resources/knowledge-center/customs-trade-partnership-against-terrorism-c-tpat-faqs

cerasis.com/c-tpat

https://en.wikipedia.org/wiki/Customs-Trade_Partnership_Against_Terrorism

https://www.cbp.gov/border-security/ports-entry/cargo-security/ctpat