What is the CTPAT?
The Customs Trade Partnership Against Terrorism (CTPAT) is a voluntary supply chain security program led by U.S. Customs and Border Protection (CBP). Originally known as CTPAT Security, the program functioned as a voluntary collaboration between CBP and supply chain stakeholders – including importers, carriers, consolidators, licensed custom brokers and manufacturers – to promote U.S. border security and combat terrorism. The program is open to members of the trade community who can demonstrate excellence in supply chain security practices and who have had no significant security related events. Through this program, CBP works with the trade community to strengthen international supply chains and improve United States border security.
This past summer, new forced labor compliance requirements were added to the CTPAT Security and Trade Compliance programs.
As of January 2023, CTPAT Security partners are required – rather than merely encouraged – to have a documented social compliance program in place. At a minimum, the program is required to address how the partner ensures that goods imported into the United States were not mined, produced or manufactured, wholly or in part, with forced, imprisoned or indentured child labor. Additionally, existing CTPAT Trade Compliance partners must meet the following six forced labor prevention compliance requirements, beginning August 1, 2023:
Risk-based mapping. Partners must conduct risk-based mapping that outlines supply chains in their entirety, including regions and suppliers that they feel pose the most risk for forced labor. As part of this process, partners should take into consideration information that CBP publishes on its website. CBP may request unredacted proof of supply chain mapping.
Code of conduct. Partners must put in place a public code of conduct statement indicating their position against the use of forced labor in any part of their supply chains, as well as their commitment to risk-based mapping. The code of conduct also must be included in the importer’s social compliance program that focuses on forced labor. In addition, partners must have policies and procedures that operationalize the code of conduct.
Evidence of implementation. Partners must provide CBP with evidence of the implementation of their social compliance program, including, if requested, their risk assessment.
Examples of evidence include unredacted audits of high-risk supply chains related to forced labor, internal training programs for employees on identifying signs of forced labor and mechanisms used to show the supply chain is free of forced labor.
Due diligence and training. Partners must provide training to suppliers on the partners’ social compliance program requirements that identifies the specific risks and helps identify and prevent forced labor in the supply chain. Training should exemplify the partner’s position against forced labor as stated in its code of conduct and must ensure that the supplier’s business model and code of conduct expressly state that it will not partner with businesses that use forced labor. Proof of training must be made available to CBP upon request.
How CTPAT works
When an entity joins CTPAT, an agreement is made to work with CBP to protect the supply chain, identify security gaps, and implement specific security measures and best practices. Applicants must address a broad range of security topics and present security profiles that list action plans to align security throughout the supply chain.
CTPAT Benefits
CTPAT Partners enjoy a variety of benefits, including shorter wait times at the border and a faster review process should a detention occur. Through the program, CTPAT members are also able to better identify their own security vulnerabilities and take corrective actions to mitigate risks. Some of the benefits of the program include:
Reduced number of CBP examinations
Front of the line inspections
Possible exemption from Stratified Exams
Shorter wait times at the border
Assignment of a Supply Chain Security Specialist to the company
Access to the Free and Secure Trade (FAST) Lanes at the land borders
Access to the CTPAT web-based Portal system and a library of training materials
Possibility of enjoying additional benefits by being recognized as a trusted trade Partner by foreign Customs administrations that have signed Mutual Recognition with the United States
Eligibility for other U.S. government pilot programs, such as the Food and Drug Administration’s Secure Supply Chain program
Business resumption priority following a natural disaster or terrorist attack
Importer eligibility to participate in the Importer Self-Assessment Program (ISA)
Priority consideration at CBP’s industry-focused Centers of Excellence and Expertise
A Growing Partnership
More than 11,400 certified partners spanning the gamut of the trade community have been accepted into the program. The partners include U.S. importers/exporters, U.S./Canada highway carriers; U.S./Mexico highway carriers; rail and sea carriers; licensed U.S. Customs brokers; U.S. marine port authority/terminal operators; U.S. freight consolidators; ocean transportation intermediaries and non-operating common carriers; Mexican and Canadian manufacturers; and Mexican long-haul carriers, all of whom account for over 52 percent (by value) of cargo imported into the U.S.
How to Become a CTPAT Partner
Participation in CTPAT is voluntary and there are no costs associated with joining the program. Moreover, a company does not need an intermediary in order to apply to the program and work with CBP; the application process is easy and it is done online via CBP’s CTPAT website.
Supply chain mapping and risk assessments are critical requirements for CTPAT compliance. To learn more about how Sourcemap can help, reach out to our team.