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Succeeding Under the New U.S. Customs Requirements

Customs Border Protection. Succeeding Under the New U.S. Customs Requirements. DEPARTMENT OF HOMELAND SECURITY. CARRIER INITIATIVE. SUPER CARRIER INITIATIVE. BUSINESS ANTI-SMUGGLING COALITION. 24 HOUR ADVANCE MANIFEST RULE. CONTAINER SECURITY INITIATIVE. Succession of Initiatives.

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Succeeding Under the New U.S. Customs Requirements

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  1. Customs Border Protection Succeeding Under the New U.S. Customs Requirements DEPARTMENT OF HOMELAND SECURITY CARRIER INITIATIVE SUPER CARRIER INITIATIVE BUSINESS ANTI-SMUGGLING COALITION 24 HOUR ADVANCE MANIFEST RULE CONTAINER SECURITY INITIATIVE

  2. Succession of Initiatives • Initially: Carrier Initiative (CI) • Then: Super Carrier Initiative (SCI) • Enhanced by: Business Anti - Smuggling Coalition (BASC) • Resulting in and headed by the Department of Homeland Security: Customs Trade Partnership Against Terrorism (C-TPAT) Container Security Initiative (CSI) 24 Hour Advance Manifest Rule

  3. Because of these specified initiatives, we have to look for a WIN-WIN concept between the CBP and the Business Community. The much needed security initiatives enforced by CBP had to keep in mind the amount of time for the Private Sector to adapt and become compliant. This focus was mainly centered on keeping the continuity of trade and commerce through all ports.

  4. In general, ocean carriers have had to emphasize these three main points… COMMUNICATION EDUCATION IMPLEMENTATION (Based on Seaboard Marine experience) CARRIERS CUSTOMS CUSTOMERS

  5. COMMUNICATION The pro-active plan that Seaboard followed entailed… • …holding meetings with domestic and foreign office personnel to discuss and meet standards set by C-TPAT and the 24 Hour Rule. CSI, while not currently effective in the Western Hemisphere has and is being considered for our short-term business plan.

  6. COMMUNICATION Cont… The pro-active plan that Seaboard continues to follow entails… • …discussions and written communication with our customer base. 1st Foreign Shippers to the USA 2nd USA Import/Export Community

  7. C-TPATtopics reviewed and discussed were: Security (Procedural / Physical / Personnel / Conveyance) Access Controls Manifest Procedures (Which also encompasses the 24 Hour Rule)

  8. 24 HOUR RULEtopics reviewed and discussed were… • Manifest information (first & last port, SCAC Code, voyage #, arrival date) • Transparent and accurate commodity descriptions (Schedule B #’s and quantities) • Timely presentation of cargo and documents • Complete Shipper/Consignee information • Vessel / Equipment / Hazardous information …all meant to keep “YOUR” cargoes from being marked as “DO NOT LOAD” by the National Targeting Center.

  9. EDUCATION Education is the key to minimize exposure to non-compliance consequences. Detailed discussions took place to make sure that the import/export community knew the two following points very clearly… 1). Substantial benefits could be obtained by working diligently to remain within initiative guidelines. (This results in additional consideration by the CBP with respect to the 24 Hour Rule requirements.)

  10. EDUCATION 2). Steep monetary penalties exist for non- compliance. (Effective May 6th) First offense ($5,000) Second and every subsequent offense ($10,000) Note that special consideration is given during the cargo examination “Targeting Process” to Carriers, Importers, NVOCC’s, Customs Brokers etc… based on their C-TPAT participation. Furthermore, C-TPAT participation will be a mitigating factor in determining penalties and violations of the 24 Hour Rule.

  11. IMPLEMENTATION(Work in Progress) Communication and Education having been addressed, Implementation streamlining continues to be a priority. Results are… 1). …reduced costs associated with increased security requirements 2). …shortened cargo transit times to/from the US and worldwide 3). …the business community returning to the “NEW” normal

  12. Security Costs….Who Pays?! • The US Government initiates and enforces new guidelines and requirements, but at what cost, and to whom? • Unfortunately, passing the proverbial “Buck” remains the most popular idea when paying for increased security which means that eventually, EVERYONE pays. • What we have to keep in check is… To what degree?

  13. IDEALLY, what is the desired effect? Relationship building in a uniform and universally acceptable method of conducting business, that partners security responsible entities, for the safe transport of cargo… ata reasonable cost!

  14. Ultimately…we all answer to a higher authority! With this in mind… We all need to challenge ourselves and consider the following: After the guidelines have been presented, Let’s ask ourselves …. Are they Working? YES or NO?

  15. Regardless of our approval or disapproval, we the business community must continue to have dialogue to provoke thought and positive action. The results of this action must be conveyed to Customs so that all interests are met….hopefully both ends will meet somewhere in the middle… and BALANCE achieved.

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