On November 21, 2025, U.S. Customs and Border Protection (CBP) released a Federal Register Notice with details of its new pilot for the participation of Third Party Logistics Providers (3PL) in the Customs-Trade Partnership Against Terrorism (CTPAT) program.
Pilot Objectives and Structure
The pilot will assess whether expanding membership of 3PLs in the CTPAT program would enhance supply chain security as CTPAT members meet enhanced security standards and are therefore considered by CBP to be lower risk entities.
The pilot program will include 10 non-asset-based and 10 asset-based 3PLs.
- Non-Asset-Based 3PLs: These providers arrange international transportation of freight and are licensed by the Department of Transportation.
- Asset-Based 3PLs: These providers facilitate cross-border activities, manage logistics services using their own warehousing assets, and are licensed or bonded by relevant authorities such as the Federal Maritime Commission or the Transportation Security Administration.
Participation is voluntary and will last for at least one year, with the start date no earlier than December 1, 2025. The program will terminate no later than five years after its initiation.
Following the pilot period, a recommendation is required to determine if these entity type should be included permanently in the CTPAT program.
Pilot Eligibility
All participating entities must comply with the eligibility requirements of the CTPAT Program including:
- Be directly or indirectly involved in the handling and management of international cargo. Entities which only provide domestic services and do not handle or manage international cargo are not eligible.
- Not allow subcontracting of service beyond a second party other than to other CTPAT members (i.e. not allow the practice of “double brokering;” the 3PL may contract with a service provider, but may not allow that contractor to further subcontract the actual provision of this service).
- Be licensed and/or bonded by the Federal Maritime Commission, Transportation Security Administration, CBP, or the U.S. Department of Transportation.
- 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 shall not remain unpaid at the time of the initial application or annual renewal.
- Maintain a staffed office in the United States, Canada, or Mexico.
Entities must also meet the CTPAT Minimum Security Criteria (MSC) for 3PL, which can be found on the CBP website here.
Application for Pilot Participation
Eligible entities that are interested in participating in the pilot program must send an email to OFO-INDUSTRYPARTNERSHIP@CBP.DHS.GOV with the subject line “CTPAT 3PL Pilot Program Interest.” The email must indicate if you wish to participate as a non-asset-based 3PL or an asset-based 3PL.
Written comments on the program, policy, and technical issues may also be submitted via email to OFO-INDUSTRYPARTNERSHIP@CBP.DHS.GOV with the subject line “Comment on CTPAT Pilot Program.”
CBP will be selecting participants on a first come, first-served basis. Approved applicants will be notified via email and directed to complete and submit a Security Profile in the CTPAT Portal.
Applicants not selected at this time may be eligible to participate at a later date and will be notified in the order in which the original interest emails were received.
For background on the Pilot Program, read our article on the CTPAT Pilot Program Act of 2023.
