Effective January 1, 2020, U.S. Customs and Border Protection (CBP) implemented an updated version of the CTPAT Minimum Security Criteria (MSC) for CTPAT members and their supply chain business partners. The new MSC applies to all 12 Industry categories. It is the first major revision since 2003. In addition; they added one additional Eligibility Requirement which is as follows:
Maintain no evidence of financial debt to CBP for which the responsible party has exhausted all administrative and judicial remedies for relief, a final judgment or administrative disposition has been rendered, and the final bill or debt remains unpaid at the time of the initial application or annual renewal.
All Industries will be expected to upgrade their security to meet the new requirements. Please see dates of implementation.
The changes include three new criteria categories (Security Vision and Responsibility, Cybersecurity and Agricultural Security) plus an enhanced version of all of the other sections. Please find below an overview of the three sections:
1) Corporate Security-A) Security vision and responsibility (NEW) B) Risk Assessment, C) Business partner requirements D) Cybersecurity (NEW)
2) Transportation Security-A) Conveyance and IIT security B) Seal Security C) Procedural Security E) Agricultural Security (NEW)
3) People and physical security—A) Physical access B) Physical Security C) Personnel security D) Security training, threat and awareness.
CBP will remove the present security profile questionnaire from the CTPAT member’s portal and save it in the documents section as a PDF file. This will be replaced by a new security profile questionnaire.
The new MSC is not only going to hold the CTPAT member accountable but now the spotlight is going to focus on the first and second tier business partners.
For many CTPAT members and their service providers, this is lot to digest all at once. For some, this is going to represent a major change in the way they are doing business now. For those CTPAT members who are only a member because their customer is demanding it, the new MSC will be overwhelming. In addition, there is no discretion in latitude that CBP previously provided the CTPAT member in their ability to demonstrate their adherence to MSC, (both domestic and especially foreign), because there is less interpretation in the new 2020 MSC.
We will develop the proper procedures, questionnaires, and checklists as well as security training in order to bridge the gap between what you physically have in place and what is required. For over 19 years, we have successfully assisted applicants to join the CTPAT program and have traveled around the world to prepare and be present for foreign validations. The latter is of significant importance during a revalidation when there is no domestic validation and your ability to maintain your CTPAT status rests solely with your foreign supplier and their business partners being able to demonstrate that they are meeting the MSC.
Some CTPAT links that you may find of interest are as follows:
Click on Learn More below for additional details on: