International Trade Law News

Published by Jacobson Burton Kelley PLLC

U.S. Customs and Border Protection has published the minutes of the May 15, 2007 meeting of the Commercial Operations Advisory Committee (COAC). The highlights of the meeting included:

• CBP continues to move forward with the Security Filing initiative, also known “10+2”. CBP's Office of Regulations and Rulings has completed its initial work on developing the draft Notice of Proposed Rule Making and CBP is reviewing that document internally. CBP does not yet know when the formal notice will be published in the Federal Register.

• With respect to C-TPAT, CBP reported that currently there are 7,031 certified members and all new applicants are being reviewed within 90 days, as required by SAFE Port Act. CBP has completed 4,200 validations and anticipates completing the 3,000 remaining validations by the end of the year. [This does not include the approximately 300 importers who source 75% or greater from China. These 300 importers are currently confined to C-TPAT Tier 1 and receiving minimum level of benefits since the Chinese government has denied CBP’s request to allow U.S. CBP specialists from performing validations in China.]
  

• CBP is working with the COAC supply chain security subcommittee on a proposal to utilize C-TPAT third party validators. An announcement of the best-qualified validator firms is expected soon.

• The COAC provided comments that were highly critical of the draft version of the Department of Homeland Security's “Strategy to Enhance International Supply Chain Security”, which is required by Sections 201 and 202 of the SAFE Port Act. Specifically, the COAC comments stated that "we do not believe the plan is actionable. A good plan should provide a clear set of instructions that are specific as to roles, responsibilities and actions to be taken. It should be a blue print that can be referred to in both planning and execution. The plan as written is general and very high level in describing roles and responsibilities. Until the detail is populated, we do not believe the plan is useful." The COAC's comments in Word format can be found at the following link.

• CBP is developing C-TPAT criteria for Mexican Long-Haulers and reviewing Third Party Logistics Providers minimum-security criteria.

• CBP has created the Unified Business Resumption Message (UBRM) service in order to advise the trade community in the U.S and Canada in the event of an incident that affects the flow of trade. Interested persons can subscribe to the UBRM via a RSS feed on the CBP website. [Note, the easiest way to subscribe to a RSS feed is via a news reader, such as Google Reader.]
  

• The next COAC meeting will be held in Washington, DC on August 16, 2007.

Labels: C-TPAT, Customs