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As the C-TPAT program continues to evolve and members are required to comply
with additional minimum security criteria, CBP must also look to provide
additional, meaningful and tangible benefits to certified C-TPAT partners in
exchange for the added security commitments demonstrated by the C-TPAT member.
To this end an innovative procedure has been developed and implemented to
address multiple container shipments that are associated to an entry that is
designated for a Stratified Compliance Measurement (CM) examination. When
multiple containers are covered by an entry with a CM requirement,
traditionally CBP would move the container(s) with the targeted cargo to the
CES for examination, while the container(s) which do not hold the targeted
commodity would remain at the terminal until the entry is released by CBP.
Importers would incur costly demurrage charges for the containers remaining at
the terminal.
CBP has developed an option that provides C-TPAT importers an avenue to have
their containers which do not contain the targeted commodity removed from the
terminal while the entry is still on intensive CM hold. Under this option, the
importer of the goods must sign a statement on the importer's letterhead
stating that they will hold all the containers with the seal intact until an
electronic release from CBP is obtained. The importer accepts responsibility
for any containers compromised in any way or delivered without CBP
authorization. An importer who violates this agreement may also be suspended or
removed from the C-TPAT program. In addition, unauthorized release of the held
containers could result in CBP penalties for violation of the importers bond.
This option is yet another benefit CBP provides as an incentive for
participation in the C-TPAT program. Providing this option to C-TPAT importers
nationwide is an additional benefit which will assist some C-TPAT members by
reducing demurrage costs, yet have minimal impact on CBP enforcement
operations. Again, this option only applies to multiple containers held under a
single entry targeted for a CM examination.
The Assistant Commissioner in the Office of Field Operations has approved
extending this benefit nationwide to C-TPAT importers to the extent possible
and practical. All Directors of Field Operations have been instructed to review
their cargo inspection operations to develop and implement procedures to grant
this privilege when appropriate.
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