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Exporter Eligibility Requirements for C-TPAT

Posted July 10, 2014

On July 9, U.S. Customs and Border Protection (CBP) announced the planned eligibility for exporters to participate in the Customs-Trade Partnership Against Terrorism (C-TPAT) and issued a list of applicable admissibility requirements and guidelines.
C-TPAT is a voluntary program designed to improve supply chain security and was only accessible to importers in the past. CBP officials and industry representatives have been working since last year to expand the C-TPAT into a broader authorized economic operator-type scheme by extending eligibility to exporters.

According to the release, “As the C-TPAT program has continued its evolution, it has become apparent that exports also have an important role in international supply chains and while this sector is not as heavily owned by CBP and the C-TPAT program, developing an export component for C-TPAT would further enhance both the program and its relationship with other mutually recognized Foreign Customs administrations.”

Eligibility requirements for exporters include the following:

  • Be an active U.S. Exporter out of the United States.
  • Have a business office staffed in the U.S.
  • Be an active U.S. Exporter with a documentable with Employee Identification Number
  • (EIN) or Dun & Bradstreet (DUNS) number
  • Have a documented export security program
  • Create and provide CBP with a C-TPAT supply chain security profile
  • Commit to maintaining the C-TPAT supply chain security criteria
  • Have an acceptable level of compliance for export reporting for the latest 12-month period

Additional areas of focus include the following:

  • Security procedures
  • Exporter Minimum Security Criteria
  • Business Partner Requirements
  • Point of Origin
  • Participation/Certification in Foreign Customs Administrations Supply Chain Security Programs
  • Container Security/Inspection/Seals/Storage
  • Conveyance Tracking and Monitoring Procedures
  • Physical Access Controls
  • Export Training and Threat Awareness
  • Information Technology Security

CBP has yet to announce a date for the launch of a C-TPAT export pilot program. In the meantime, CBP and the trade community are continuing to evaluate the specific benefits that an export component for C-TPAT would offer. Both sides recognize that these benefits will have to be fairly substantive to counter the expected costs to exporters of strengthening the security of their supply chains.