As 2020 winds down, the first year of C-TPAT’s new Minimum Security Criteria (MSC) is coming to a close. The new MSC’s went into effect at the beginning of the year, and in early June, the C-TPAT portal was updated to reflect these new criteria. Having worked with several C-TPAT members as they updated their programs, there are a handful of observations and best practices that I wanted to share.
First, use your resources. It appears that US Customs and Border Protection (CBP) has been putting forth a significant effort to provide additional resources to C-TPAT members. Many of you are familiar with the C-TPAT Member Library in the C-TPAT Portal. In November, CBP uploaded a series of presentations about the MSC criteria categories in both English and Spanish. They have also released several videos on YouTube that focus on Cybersecurity. It is our expectation they will continue to provide resources to C-TPAT partners in the future.
Second, it is important to communicate with your Supply Chain Security Specialists (SCSS). They are much more than just the individual that reviews your Security Profile; they are a resource for your questions about the program. Furthermore, this year we have experienced the effects of both a global pandemic and new MSC going into effect. If you are anticipating delays in submitting your Security Profile, be sure to communicate with your SCSS. CBP has been very clear that most suspensions from the program are the result of a chronic lack of response to their communications and queries.
Finally, the best C-TPAT programs that I have seen are the ones that are active all year, not just when it’s time to submit your Security Profile. Your C-TPAT policies and procedures manual should not be gathering dust. As the year goes by, you need to be providing training, documenting inspections, reviewing your practices, and checking the C-TPAT Portal and your Status Verification Interface for changes. Set up regular intervals to review. As these are taking place, it is critical that you document program changes and implementation notes within your procedures manual.
Tradewin understands that the new MSC’s are a significant change from the legacy criteria. With our experience and resources, we can support the integration of these criteria into your C-TPAT program, or help you with the development of a new C-TPAT application.
As always, please feel free to reach out to our customs compliance consultants with any questions. we're here to help.