Defining C-TPAT for Importers
C-TPAT Security Criteria for Importers
Importers must conduct a comprehensive assessment of their international supply chains based on the C-TPAT security criteria. Where an importer outsource or contracts elements of their supply chain, such as foreign facility, conveyance, domestic warehouse or other elements, the importer must work with those business partners in order to ensure that pertinent security measures are in place and adhered to throughout their supply chain.
The supply chain for C-TPAT purposes is defined from the point of origin (manufacturer, supplier or vendor) through to point of distribution and recognizes the diverse business models C-TPAT members employ. C-TPAT recognizes the complexity of international supply chain and endorses the application and implementation of security measures based upon risk analysis.
Therefore, the program allows for flexibility and the customization of security plans based on the members business model. Appropriate security measures must be implemented and maintained throughout the importer's supply chain - based on risk.
Business Partner Requirement
Importers must have written and verifiable processes for the selection of business partners including manufacturers, product suppliers and vendors.
Security Procedures: For those eligible for C-TPAT certification (carriers, ports, terminals, brokers, consolidators, etc) the importers must have documentations (C-TPAT certificate, SVI number, etc) indicating whether these business partners are or are not C-TPAT certified. SVI stands for Status Verification Interface.
For those business partners not eligible for C-TPAT certification, importers must require their business partners to demonstrate that they are meeting C-TPAT security criteria via written/electronic confirmation (contractual obligations via a letter from a senior business partner officer attesting to compliance, a written statement from the business partner demonstrating their compliance with C-TPAT security criteria or an equivalent WCO [World Customs Organization] accredited security program administered by a foreign customs authority or by providing a completed importer security questionnaire).
Based upon documented risk assessment process, non C-TPAT eligible business partners must be subject to verification of compliance with C-TPAT security criteria by the importer.
Point of Origin: Importers must ensure that business partners develop security processes and procedures consistent with the C-TPAT security criteria to enhance the integrity of the shipment at point of origin. Periodic reviews of business partners' processes and facilities should be conducted based on risk and should maintain the security standards required by the importer.
Participation/Certification in Foreign Customs Administrations Supply Chain Security Program
Current or prospective business partners who have obtained a certification in a supply chain security program being administered by foreign Customs Administration should be required to indicate their their status participation to the importer.
Other Internal Criteria for Selection
Internal requirements, like the financial stability, capability of meeting contractual security requirements and the ability to identify and correct security deficiencies as needed, should be addressed by the importer. Internal requirements should be assessed against risk-based process as determined by an internal management team.
