CTPAT and Social Compliance

In recent year, CBP has been diligently enhancing the security principles within the CTPAT program, including the Minimum Security Criteria (MSC). Today, we would like to draw your attention to the latest update that specifically pertains to the MSC and Trade Compliance program requirements in relation to Forced Labor. 

As of August 2023, these requirements have become mandatory, and it is now imperative to submit the necessary proof documents through the CTPAT portal. According to the MSC for U.S. Importers, Business Partners section 3.9, CTPAT Security Members must 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. 

Two people updating their company's security profile.

Important Notice for CTPAT Trade Compliance Members

CTPAT Trade Compliance Members have an additional six (6) requirements to fulfill. We understand the significance of these updates and the importance of ensuring compliance with the evolving security program. Therefore, we kindly request your attention to this matter and encourage you to take the necessary steps to meet these new obligations. 

  1. Risk Based Business Mapping – this includes a full picture of your supply chain which also includes your partners. While these details are not required for posting on the portal they can be requested at any time by CBP.
  2. Code Conduct – your company’s statement that details out your position against the use of forced labor anywhere in your supply chain – this statement must be uploaded in the CTPAT portal.
  3. Evidence of Implementation – you must present details on how you implemented your social compliance program (i.e. possible audit of your supply chain) this document needs to be uploaded in the CTPAT portal. 
  4. Due Diligence and Training – a company needs to develop educational learning about their social compliance program to their suppliers and partners – this document does not need to be uploaded in the portal however a request can be made at any time.
  5. Remediation Plan – a company needs to develop a plan for their organization if a forced labor event is identified and how they with communicated with CBP- this plan does not need to be uploaded in the portal however CBP may request these details at any time.
  6. Best Practices – if you have developed a “best practice” within your company, CBP request that you share the details with them when appropriate – this document is not required to uploaded into the portal.

Managing CTPAT Trade Compliance

Managing security and trade compliance details under the CTPAT s a dynamic program that constantly evolves alongside changes in business processes within the realm of international trade. It is crucial to remain vigilant in maintaining an effective cargo security program and staying up-to-date with all the latest updates. This task demands the acquisition of new skills and tools to effectively manage these intricate details. 

To assist with understanding these requirements, CBP has released a comprehensive FAQ document. By clicking on the provided link, you will gain access to detailed information about the benefits of compliance and enforcement measures.

Should you require any further clarification or assistance in navigating these requirements, please do not hesitate to reach out to us. We are here to support you in maintaining the highest standards of security and trade compliance. 

 Thank you for your attention to this matter, and we look forward to your continued partnership in upholding the integrity of our industry. 

About Us

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.

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