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Remarks of Acting Commissioner Deborah J. Spero, C-TPAT Conference

(03/01/2006)
Thank you, Todd, for your kind introduction. I am very pleased to be here today for the Customs-Trade Partnership Against Terrorism spring 2006 training seminar, and on behalf of U.S. Customs and Border Protection, I would like to welcome you all. This is really a large group! And that’s testimony to the importance of C-TPAT and the excellent agenda that has been put together for you that will extend over the next few days. I’m sure you will have very informative and interactive discussions.

I would also like to take a moment to welcome representatives from 15 individual foreign Customs administrations and the European Commission. Your presence signifies not just the growth of C-TPAT but also its relevance to the international trade and Customs communities. We are glad you could attend the seminar and we plan to take advantage of your perspectives in some special workshops where you will share your views on the World Customs Organization Framework of Standards.

As I look around, I see some folks who also attended yesterday’s Trade Support Network conference in Manhattan Beach. I’m going to try not to use any of the same lines that I used yesterday, so you won’t get bored. But I do want to make a point that I made yesterday, because it applies to this seminar as well as the TSN meeting – and that key point is partnership. Both the TSN and C-TPAT represent a collaboration between the government and the private sector that does not, to my knowledge, exist anywhere else in the world. That’s why it is a very special week for me personally. I have the opportunity to address two audiences who represent partnerships that we have relied on to help us carry out the CBP mission. Frankly, you are the secret of our success. Not that we really try to keep it a secret. But those who have not been part of these partnerships have a hard time understanding their scope, their momentum, and their significance in helping create a safer, more secure and more facilitative international trading system.

During this year’s C-TPAT conference – aptly named “Supply Chain Security in a New Business Environment” – you will hear from a number of government and industry representatives on a wide range of issues. You will learn about companies who have made a difference by strengthening their global supply chains. And, you will hear first hand about industry best practices that have enabled companies to reach the Third Tier of C-TPAT benefits. I hope that our collective comments and the workshops will give you a clear understanding of the current status of C-TPAT and the environment in which we both operate.

Of course, as C-TPAT members, you are well aware of the progress that the federal government and the private sector have made since September 11th, 2001. Together, we have worked to strengthen the global trading system and have made our nation’s cargo more secure. And the result is that America is safer. But as I mentioned, there are many who don’t fully understand just how far we’ve come. Last week, and continuing into this week, Washington has been churning with the story about Dubai Ports World taking over terminal operations in several U.S. ports.

I won’t insult your intelligence by explaining the difference between the terminal operator’s responsibilities and other players in the seaport environment. And, it would be preaching to the choir to educate you on the complexities of international business transactions – in fact, you could educate me! And, I won’t bother to explain seaport security and the roles of the Coast Guard, CBP, and others.

When all of the furor starting building last week, we did launch a campaign to try to educate those who were reacting negatively to the Dubai Ports World transaction. We explained that CBP would continue to perform our mission of preventing terrorists and terrorist weapons from entering the United States by eliminating potential threats before they arrive at our borders and ports. We talked about our layered security programs – getting advance information on shipments; using that information to analyze and target shipments before they arrive in the U.S.; our use of technology; our inspection of all cargo that is identified as “high risk”, either at the foreign port, or upon arrival into the U.S. We talked about the Container Security Initiative, now in place at 42 overseas locations.

And of course, we talked a lot about the Customs-Trade Partnership Against Terrorism. We explained that, based on the premise that strong security brings greater trade facilitation, C-TPAT has become an important part of CBP’s layered strategy for a smart and extended border.

In fact, despite the crisis atmosphere in Washington, we appreciated the opportunity to talk about these initiatives – because after 4 years of partnerships with the trade and partnerships with other governments, we really have made the global supply chain more secure. This is due in large measure to you. Because of your willingness to think strategically about security and trade facilitation, we have been able to build C-TPAT into one of the largest and most successful public-private partnerships in history.

Not that C-TPAT is a done deal, or a completely developed program. Because it is not. As you know, C-TPAT has changed over the past four years and it will change and grow in the future. From the very beginning, C-TPAT was always intended to be a true partnership that benefited both the government and the trade community. C-TPAT was also designed to be a dynamic program, one that evolves to meet our collective needs.

In the last year alone, C-TPAT has gone from 4600 certified partners to over 5700 certified partners, representing major importers, brokers, terminal operators, carriers and foreign manufacturers.

Over the past year, we have also implemented minimum security criteria, so that importers (and starting tomorrow, carriers), will know and understand minimum requirements, and also will know what it takes to exceed these requirements. In fact, as a sign of our ability to have a constructive dialogue on these issues, the implementation of minimum security criteria for importers was managed in a way that met the needs of both the trade community and CBP. And I predict that the implementation of the carrier security criteria will be even easier.

Validations have become another part of the C-TPAT vernacular. A year ago, we had only 403 validations completed, with 581 in progress. Today, we have over 1,500 validations completed with another 2,200 in progress. Talk about growth!

Benefits for C-TPAT members have also evolved. As C-TPAT members, you agree to work with CBP to identify security gaps and to implement specific measures to protect your supply chains. And in return, certified C-TPAT members receive benefits such as reduced ATS scoring, fewer security and compliance inspections, access to FAST lanes on the land borders, eligibility for the Importer Self-Assessment Program, access to training classes, assistance with security issues, and our newest benefit, one that you requested, Front of Line inspections. Many of you have also told us that you have experienced a significant reduction in pilferage in exchange for increasing supply chain security. Now that is a sound investment!

And over the last year, we have implemented a new system of tiered benefits for importers. This new system recognizes those importers that do more toward securing their supply chains, those who go beyond minimum requirements. This system is based on the level of security, validation results, and the use of C-TPAT best practices such as those I mentioned earlier.

As you know, Tier One consists of certified importers that receive the basic benefits of a certified C-TPAT member. Tier Two consists of validated C-TPAT importers that have greater ATS reduction in their scoring, twice the level of Tier One, resulting in even fewer inspections. And, Tier Three –– which represents the most significant level of benefits afforded to importers, consists of those certified and validated C-TPAT partners that exceed the minimum standards, receive the most significant risk score reductions and have adopted C-TPAT best practices. These C-TPAT partners will be subject to only infrequent random inspections.

While Tier 3 is indeed a high standard to achieve, 139 importers have met this standard. The purpose of this conference is to provide C-TPAT members with the knowledge, skills and tools needed to achieve Tier 3. The Best Practices Catalog that you asked for [hold up Catalog], does just that by providing practical measures that will help you strengthen your supply chain.

Over the past year, C-TPAT also took another significant step forward in its evolution with the World Customs Organization’s unanimous adoption of the WCO Framework of Standards to Secure and Facilitate Global Trade. The WCO Framework of Standards represents a set of supply chain security standards based on best practices in WCO Member countries, including CBP’s C-TPAT program. C-TPAT has truly gone global! Nearly 130 WCO Member customs administrations have now committed to implementation of the Framework. These 130 WCO Members include all of the customs administrations represented in this room. This overwhelmingly positive show of support for the WCO Framework confirms the critical role that customs administrations play in protecting their borders from terrorists and terrorist weapons while ensuring the smooth flow of commerce across those same borders.

Adoption of the WCO Framework is extraordinary, and its implementation has the potential to revolutionize the secure and efficient movement of goods around the world. The main elements of the WCO Framework – advance electronic transmission of manifest information, standardized risk assessment, inspection of high-risk cargo at the port of origin using non-intrusive and radiation detection equipment and tangible benefits for businesses that meet minimum security criteria – are not new to CBP or our C-TPAT partners.

While familiar to us, the WCO Framework presents a worldwide model for closer cooperation among customs administrations and stronger public-private sector partnerships to promote supply chain security and trade facilitation. It does that by its basic structure of two pillars: the Customs to Customs pillar and the Customs to business pillar.

Within these pillars, and an important key to effective implementation of the Framework, is capacity building. Many of the 130 WCO Members that have committed to Framework implementation will need capacity building assistance. CBP, along with several other WCO Members, including Australia, Canada, Japan, New Zealand, Sweden and the United Kingdom, along with the European Union, have committed to providing capacity building assistance to support of Framework implementation. In addition, recognizing the critical need for a comprehensive capacity building program to support implementation of the WCO Framework of Standards, the WCO also recently established a new Capacity Building Directorate. The main mission of this new Directorate is to ensure that all WCO Members that have demonstrated the true political will and commitment to implement the Framework will have access to some type of capacity building assistance. The Director of the WCO Capacity Building Directorate is from Sweden and was a key player in the development of Sweden Customs’ Stairsec supply chain security program, with which many of you are certainly familiar.

As a demonstration of our recognition of the importance of capacity building, CBP has already posted a Technical Attaché to work in Brussels for the WCO Capacity Building Directorate. And because the internationalization of supply chain security principles is so important, we will be adding another CBP Attaché in the near future – and we are specifically recruiting for someone with C-TPAT experience to support the building of Custom-business partnerships in WCO member countries.

A second very important aspect of the WCO Framework is the concept of mutual recognition, wherein countries reach agreement on minimum criteria for a secure supply chain and thereby provide greater facilitation of trade between themselves. This is, of course, a potentially powerful tool to enhance trade, and should be of great interest to multi-national companies. However, we have many challenges in reaching mutual recognition. First, we must agree on the standards for what the international customs community refers to as “Authorized Economic Operators”, or AEOs. (When I first heard the term AEO, I asked what it meant, and our international affairs staff said “just think of it like a C-TPAT importer”). The WCO is working on the AEO standards right now. And while we are, of course, in favor of shared standards, mutual recognition for us at CBP will only occur once other countries have developed their own Customs-business partnerships with criteria of equal rigor to our own C-TPAT program. Some of you may be in a position to play a significant role in implementation of the WCO Framework’s Customs-to-Business partnership pillar. I say this because by virtue of your participation in C-TPAT, you already have extensive experience in Customs-to-Business partnerships. We, therefore, will rely on you to work closely with other customs administrations as they develop their own national supply chain security programs. Your knowledge and experience with C-TPAT will be invaluable to them.

Implementation of the WCO Framework of Standards provides CBP and our C-TPAT partners with an opportunity to strengthen our own partnership and broaden the security of our supply chains around the globe. The standardization of customs procedures and processes also has tremendous potential to increase the efficiency of international trade. I encourage all of you to listen carefully and ask questions as you hear more about the WCO Framework of Standards later in this conference. Representatives of foreign Customs administrations will also discuss their progress in implementing the Framework. You should think specifically about how implementation of the WCO Framework of Standards will help your company, and about how you and your company can help facilitate effective implementation of the WCO Framework in other countries.

As I noted, the WCO Framework represents an unprecedented global approach towards supply chain security and trade facilitation. It is an approach that CBP fully supports. Its implementation will be a huge step forward by the international community to secure global trade. We are committed to working with other customs administrations and the private sector towards broad and effective implementation of the WCO Framework of Standards. The Framework is also yet another example of how we can take C-TPAT to a new level.

Before I close, I want to share one story with you that demonstrates just how far we’ve come in building C-TPAT. In January, Secretary of Transportation Norman Mineta went to Shanghai to address the American Chamber of Commerce. This was a large crowd and during one of the open panels, Adidas Corporation told the Secretary that because of C-TPAT’s preference that importers use hard sided shipping containers that can be sealed, China’s use of open-top containers has been visibly reduced. In Adidas’ words, the reduction of open top containers on China’s roadways has had a positive impact on traffic safety and shows how the C-TPAT program has reached deep into the supply chain.

That small story illustrates the impact of C-TPAT throughout the world. And now, I must close to let you get on with the seminar. I want to thank you for the opportunity to talk to you today. I truly believe that only by fostering an ongoing, interactive and open dialogue, will we continue to achieve greater efficiencies, leverage best practices and strengthen the global supply chain. I am proud of what we have accomplished so far and look forward to working with you to ensure that the C-TPAT program achieves even greater success. Together, I know that we can fulfill our shared vision of protecting our nation and our economy.

Thank you.

Acting Commissioner Spero reserves the right to edit her written remarks during her oral presentation and to speak extemporaneously. Her actual remarks, as given, therefore, may vary somewhat from the written text.

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