Norman Jaspan Associates, Inc. (NJA) will explain to the foreign supply chain business partner (“FSCBP”) why they have to be C-TPAT compliant and explain the process in order to work with a C-TPAT member. NJA will evaluate FSCBP’s controls and procedures and make recommendations which are easy to implement. These recommendations will not only meet the requirements of being C-TPAT compliant but will help the FSCBP with their day to day business operations. Even though the FSCBP is being visited on behalf of the C-TPAT member, they are really being visited on behalf of all the companies that the FSCBP sells to in the USA. The custom security specialist (“SCSS”) will always ask what percentage of your product is being sold in the USA, regardless of the customer. For example, a non C-TPAT USA company that had been buying from the same FSCBP for many years began to have its containers inspected. After contacting the FSCBP, he discovered that the FSCBP had failed a C-TPAT validation on behalf of one its C-TPAT members. This affected both the Non C-TPAT and C-TPAT members.
FSCBP is any company (Suppliers/Manufacturers, Foreign Consolidators/Stuffing Facilities, Trucking Companies, Port, Foreign Agent) that works with a C-TPAT member. In order to conduct business with a C-TPAT member, US Customs and Border Protection (CBP) requires the FSCBP to meet the minimum security requirements of the Customs Trade Partnership Against Terrorism program.
As a FSCBP, you will or may have already had a site visit by your C-TPAT member’s U.S. SCSS. Being C-TPAT compliant means that the FSCBP will be required to demonstrate to the SCSS that you are meeting the minimum security requirements if i) this is a first time visit, ii) the SCSS has not visited your facility within more than a year or iii) the C-TPAT member was suspended from the C-TPAT program because your company received too many Actions Required.
If you, as a FSCBP, are responsible for selecting a FSCBP on behalf of your C-TPAT customer, then you will have to make sure that they are also meeting the minimum security requirements. An example of this could be when the shipper or consolidator selects a trucking company. As a rule, a representative from the trucking company will be required to be present at your site visit in order to explain what steps they have taken to meet the minimum supply chain requirements.
NJA will prepare your company to identify your company exposure through a FSCBP flow chart. NJA will thoroughly prepare you for the site visit as well as work with you in preparing and implementing the written procedures.
Please contact NJA so that we can explain the site visit in greater detail and answer any questions that you may have.
If the C-TPAT member is suspended from the C-TPAT program because your company cannot demonstrate to the SCSS compliance with the minimum security requirements, then the C-TPAT member may be forced to pick another FSCBP. You want to prevent this from happening.