Highway Carriers & Importers Facing CTPAT Validation Challenges

The Customs Trade Partnership Against Terrorism (CTPAT) program was established in 2001 to enhance United States border security through strengthening of international supply chains. CTPAT is a public-private partnership that facilitates the flow of cargo through ports of entry while maintaining the rigorous security standards inherent to CBP field operations.  

A recent study of the CTPAT Program released in May of 2021, found that the greatest number of businesses who were suspended and/or removed from CTPAT in 2018 and 2019 were Highway Carriers (215 in 2018 and 187 in 2019), and Importers (169 in 2018 and 179 in 2019). Many of these suspensions and/or removals were a result of security breaches.

Highway carriers in CTPAT range from large companies with sizeable facilities and a substantial number of employees, to owner-operators with single trucks that conduct their business from home. These small companies struggle to diversify their business portfolios due to a lack of resources to successfully scale their services. Security breaches have taken a particular toll on these groups.  Consequently, companies have failed CTPAT validations, lost contracts, gone out of business, and shifted operations to 100% domestic, thereby disqualifying them for CTPAT membership. In the latter case, companies are suspended, withdrawn, or removed from the program.  

The study concluded that Highway carriers and importers were statistically the most likely to be suspended or removed in 2018 and 2019.  An overwhelming number of these suspensions were related to incidents that occur because of double or triple brokering, which drastically decreases supply chain visibility, particularly in trucking. Another notable cause of suspension or removal from the program is failing to provide adequate proof of implementation of required security measures. In some cases, failing to provide evidence of implementation can also result in suspension or removal from the program. 

Many importers also fail to complete their security profiles punctually as well as with their annual review requirement. As the CTPAT program evolves, the security profile is becoming the preeminent challenge for both importers and highway carriers, as criteria that were once recommendations are now requirements. The process to complete a security profile is unique to each company, as the method for conducting a 5-step risk assessment and providing sufficient documentation varies considerably depending on the company’s unique operations. Issues often occur when companies fail to consult with their assigned supply chain security specialist (SCSS) regarding the requirements that apply directly to their entity type along with evidence to have on hand to substantiate security measures. These challenges are avoidable for a company by effectively communicating with their designated security specialist. 

CT Strategies team of former CBP CTPAT SCSS’s and Directors help companies successfully navigate CBP’s Customs Trade Partnership Against Terrorism program. The company’s CTPAT Navigator is the single source guide for all CTPAT entity types. Using insight from over 50 years of combined CBP operational and policy knowledge, CTS leverages their first-hand CTPAT supply chain security experience and connections to current CBP leadership to ensure companies are maximizing their benefits while also saving them time and money. 

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