December 1, 2005

The following article is derived from the 1 December 2005 edition of “The Journal of Commerce”.

US Customs and Border Protection’s Departmental Advisory Committee on Commercial Operations (COAC) has proposed 12 benefits that US Customs can offer importers who qualify as “Tier 3” members of C-TPAT.  These importers already exceed the minimum requirements for C-TPAT, and are seeking enhanced benefits from Customs that recognize their commitment and investment to the program.

These steps would not require changes in law or regulations.  The proposals are for:

•  permission to remotely file selected quota, warehouse and foreign trade zone entries

•  allowance of paperless entries, unless a paper document is required by another government agency

•  expedited drawback claims

•  new formulas for calculating transaction and continuous bonds

•  zero security inspections, unless there is a specific reason to check security

•  expedited response to rulings requests

•  updated mitigation guidelines

•  multiple suffixes to nine-digit IRS numbers

•  expedited background checks

•  requests for further information to be cleared by national account manager

•  no penalties for late duty payments (only interest would accrue)

•  opportunity to take corrective action or disclose errors before seizures, fines or penalties

Customs and Border Protection will consider these suggestions; doubtless there are concerns with proposals affecting revenue collection.