On June 16th, 2014, U.S. Customs and Border Protection (CBP) published a Federal Register notice seeking applicants to enroll in a test of the new Trusted Trader Program which will last eighteen months. The selection of initial test participants will begin no later than July 16th, 2014, and the test is limited to fewer than ten participants. Selected applicants will be notified individually of their participation date. Those applicants who are accepted will be offered a number of benefits in addition to all the benefits currently being offered under C-TPAT and ISA.
Some of the additional benefits include: (a) a reduced Food and Drug Administration (FDA) targeting and examination risk score, (b) a penalty offset upon request, (c) a reduced number of Foreign Trade Zone (FTZ) on-site inspections, (d) exemption from on-site visits from drawback specialists, and (e) exemption from random Non-Intrusive Inspections.
To be eligible to participate in the test program, a company must be an active U.S. or Non-Resident Canadian importer with at least two years of importing history. The company must also have written policies and procedures pertaining to its import process and a valid continuous importation bond filed with CBP. Other requirements include: (1) implementing and maintaining security measures and supply chain security practices meeting criteria under C-TPAT, and (2) maintaining books and records to establish compliance with laws and regulations enforced by CBP. Importers who meet the eligibility criteria and wish to participate in the test program must submit their applications to CBP via email at TrustedTrader@cbp.dhs.gov.
The program, once implemented fully, will unify CBP's current Customs-Trade Partnership Against Terrorism (C-TPAT) and Importer Self-Assessment (ISA) programs. The goal of the program would be to enhance collaboration and information sharing between various government agencies and, thereby, improving the efficiencies of the existing trade programs. This "single window" approach is consistent with the executive order signed by President Obama earlier this year, mandating U.S. government agencies to work together to streamline the import and export processes. The Trusted Trader Program test is not open to current ISA partners. However, if CBP decides to implement the Trusted Trader Program after the test period is over, CBP will transition all existing ISA partners into the program and discontinue the ISA program. ISA partners will be given the opportunity to "opt-out" of being transitioned into the Trusted Trader program.