The second-draft proposals maintain C-TPAT as a voluntary program, but are more direct than the current guidelines in spelling out security measures that importers and their non-U.S. suppliers are expected to take in exchange for reduced levels of inspection and eligibility for certain automated customs payment programs.
CBP officials had asked industry representatives to submit comments to the agency by Dec. 3.
In a four-page letter dated Dec. 3 to the office of field operations of CBP, the NIT League said it has major concerns over the revised security standards proposed by the agency to apply to importers, and that they may force importers to leave the voluntary program or deter them from joining it.
The NIT League urged CBP to continue to work with industry to modify the security standards, despite’s Customs’ stated intention to introduce new standards as early as at the end of this year.
The league told the agency it should define the criteria to be considered by importers in performing a security risk assessment, instead of leaving it to individual companies that may use inconsistent interpretations.
The NIT League also questioned the proposed mandatory standards, saying they clash with the voluntary nature of the C-TPAT program and raise issues of liability for the companies concerned.
On container security, the NIT League agreed importers must require that procedures exist at the time of container stuffing for the inspection of the container and for the affixing of a high security seal when the container has been loaded. However, the shipper group said it is not reasonable “to impose mandatory requirements on importers for activities that occur overseas at the point of container stuffing, sealing, or storage, since the importer will not be able to effectively enforce such requirements.”
“Although improvements were made to the second draft, there are still significant problems that need to be addressed by CBP,” the League concluded it its letter, urging the agency not to adopt the proposed standards.
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