Next month, C-TPAT will unceremoniously celebrate its fifteen-year anniversary. C-TPAT was once hailed as the single most successful private-public partnership ever created. The program however, administered by CBP, has recently fallen on hard times with flat or declining membership. There’s also apathy or a general lack of enthusiasm on the part of the trade community to participate in C-TPAT. This is unfortunate; as the program, if designed and properly implemented, can be a big benefit for many companies. I can also tell you with impunity that this is not how the program was originally envisioned in 2001 and 2002 by the seven founding and Charter Members.
To be sure, CBP is largely culpable for mismanaging the program and allowing it to become another draconian mind-numbing experience for importers. But some of the blame should also be borne by Congress, trade advocacy/advisory groups and with the trade community itself. The program began running off the rails several ago when, without continuity of management, many Supply Chain Security Specialists (SCSS) took things into their own hands. The primary Achilles heels of the program are:
· Lack of training and understanding of rudimentary supply chain mechanics on the part of the Supply Chain Security Specialists (SCSS). There have also been numerous inconsistencies and uniformity issues among the SCSS’ in the way validations or revalidations are performed.
· Poor or virtually non-existent communication in many instances. E-mails and phone calls sometimes go unanswered or acknowledged.
- C-TPAT Portal 2.0 is dysfunctional and in my view, does not help CBP determine if a C-TPAT Member qualifies for the program or meets the annual maintenance requirements.
On February 8, 2017, the Government Accountability Office (GAO) issued a report titled “Providing Guidance and Resolving Data Problems Could Improve Management of the Customs-Trade Partnership Against Terrorism Program”. The document is critical of the C-TPAT Portal issues and ongoing problems with data. Today, under the direction of CBP’s Director of C-TPAT (recently made a permanent position by Commissioner Kerlikowske) Liz Schmelzinger is reimagining and repairing the program. Later this year or early next, CBP is expected to convene a C-TPAT Conference to announce many of the program changes.
Remember, this is supposed to be a “partnership” program that affords mutual benefits. Although many Members complain that the “partnership” part of the program abruptly ends when a participant signs the C-TPAT Agreement. It shouldn’t feel like that; and I for one am anxious to see some of the changes the new Director makes.
In the meantime, the trade community at large, along with advisory groups like the Commercial Operations Advisory Committee (COAC) should work closely with CBP to identify and remedy the shortcomings of this program. Honest and forthright feedback is vital to helping CBP address the problems experienced by Members. So, if given an opportunity please give CBP your candid and uncensored feedback. Hopefully, it’ll help make the program better and thus stronger; it will also assist CBP with recruiting new C-TPAT Members.
If your company is considering joining C-TPAT, designing and implementing programs is a deep core competency of Trade Innovations. Please e-mail us today for a free quotation.
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