On July 18th-20th, CT Strategies traveled to Anaheim, California, to attend the 2022 Trade Facilitation and Cargo Security Summit hosted by U.S. Customs and Border Protection (CBP). By combining its annual Trade Symposium and Customs Trade Partnership Against Terrorism (CTPAT) conference, CBP filled the three-day event with key industry speakers, panel discussions, and workshops highlighting the latest requirement updates, best practices for navigating supply chain challenges, as well as the future of customs and trade.
The agenda included insightful discussions regarding E-commerce, 21st Century Customs Framework (21CCF), Forced Labor, and CTPAT. Through the discussion of the enforcement of the Uyghur Forced Labor Prevention Act (UFLPA), CBP emphasized its dedication to removing forced labor from the supply chains of goods entering and exiting the United States. For importers seeking best practices, CBP has posted the Forced Labor Enforcement Task Force (FLETF) Importer Guidance on their website detailing effective supply chain tracing and measures to ensure that importers do not bring in commodities from any regions with forced labor.
New Requirements for CTPAT Members
CBP outlined the new requirements set forth in the CTPAT Trade Compliance program regarding forced labor. For CTPAT Tier II or Tier III members participating in the CTPAT Trade Compliance partnership, CBP released the new requirements that take effect on August 1st, 2022. These requirements include risk-based business mapping, evidence of implementation, due diligence and training, remediation plan, and shared best practices. New applicants to CTPAT must meet these requirements when applying to the Program. However, existing members will have one year to implement these conditions.
Forced Labor MSC
CBP announced that on the first of January 2023 the requirements set forth in the Minimum Security Criteria (MSC) for forced labor will change. Specifically, Section 3.9 of the MSC states that “CTPAT Members should have a documented social compliance program in place that, at a minimum, addresses how the company ensures goods imported into the United States were not mined, produced or manufactured, wholly or in part, with prohibited forms of labor, i.e., forced, imprisoned, indentured, or indentured child labor,” will change from a “should” to “must.”
In case you did not get a chance to tune into the 3-day event, we’ve compiled a list of important takeaways that current and prospective CTPAT members should be aware of.
The CT Strategies team of former CBP CTPAT Supply Chain Security Specialists (SCSS) and Directors help companies successfully navigate CBP’s CTPAT program. Using insights from over 80 years of combined CBP operational and policy knowledge, we leverage our first-hand CTPAT supply chain security experience and connections to current CBP leadership, so you can save time and money and get the most out of your CTPAT membership.