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BIN: A C-TPAT Best Practice at the Port of Antwerp

In February 2014 C-TPAT announced its recognition of a best practice implemented at the Port of Antwerp in Belgium, the second largest port in Europe.

In order to close security gaps and increase port security, the Port of Antwerp instituted the Neighborhood Information Network (BIN). This program allows the anonymous reporting of information regarding suspicious activity at the port to local police and the companies participating in BIN, thus opening lines of communication between these companies and law enforcement and allowing the two to work together to increase security and prevent crime at the port.

BIN was implemented in response to an increase in the number of criminal acts perpetrated at the port as a result of a lack of appropriate security. For example, previous to the development of BIN, criminals were able to gain access to port computers and track containers loaded with narcotics. In other cases, criminals stole various companies’ information as a means to arrange the import of narcotics under a legitimate company’s name. Since the initiation of BIN, the number of cases such as these has decreased.

Security, for ports of all sizes, is of utmost importance as it is a means to protect incoming and outgoing cargo from becoming a vehicle for crime and terrorism. C-TPAT works to secure supply chains across the globe and improve security, and as such, recognizes BIN as a best practice.

Read Custom & Border Protection’s bulletin regarding this requirement.

By Abby Frank, Consulting Coordinator


Jim Trubits to Speak at 2014 Upstate NY Trade Conference

Jim TrubitsJim Trubits, Vice President, will be speaking about export controls at the 2014 Upstate NY Trade Conference & Expo in Rochester, NY on June 19.

Trubits will present A Beginner’s Guide to Export Compliance, which will touch on basic compliance issues for all exporters, including how to determine which export regulations (ITAR or EAR) apply to products. Jim will also be a panelist at the ITAR/EAR Roundtable, where he will be answering questions on recent export control reforms and sharing his insights gained from working with exporters as a freight forwarder.

Jim Trubits is Certified Global Business Professional, licensed Customs broker, and certified Customs specialist. Read more about Jim.

2014 Upstate NY Trade Conference & Expo




How Do You Prove Transaction Value?

Determining the price actually paid or payable for your Customs entry can be quite tricky. Transaction Value rules, pursuant to 19 USC 1401a(b), place responsibility on the importer to exercise reasonable care and accurately provide Customs and Border Protection (CBP) with the proper declared value.

It’s important to assure that all lawfully mandated payments (additions) and allowable deductions (subtractions) are accounted for in the total entered value on the Entry Summary.

If you are an importer that purchases goods under an INCOTERMS® rule starting with C or D (CIF, CFR, CPT, CIP, DAP, or DDP), you may deduct the freight transportation and other costs (insurance, etc.), provided they are included in the price payable and you have supporting documentation. To help guide importers, CBP has published the Informed Compliance Publication, Proper Deductions of Freight and Other Costs from Customs Value.

Keep in mind that Customs doesn’t consider amounts shown on the commercial invoice as proof of freight transportation paid by the shipper.

What is CBP’s position?
Customs requires transportation and insurance to be deducted as actual—not estimated—costs paid to the international carrier, freight forwarder, insurance company, or other appropriate provider of such services. Again, declaring these amounts without the proper backup may result in CBP disallowing the deductions during an audit or review of the Customs entry.

So what does CBP consider proof?
To prove actual price paid, CBP requires evidence, such as a rated bill of lading, from the service provider showing the actual freight/insurance charges. CBP may allow other types of substantiation as well.

Finally, it’s important for importers to be able to produce the required Customs entry documentation and the supplementary information showing the actual costs to support the entered value. This should be part of every importer’s recordkeeping program.

By Jim Trubits, Vice President, of Mohawk Global Trade Advisors. Jim is a licensed Customs broker. Read more about Jim here.


C-TPAT Employee Screening Requirements

In order to ensure that Partners are compliant with U.S immigration law, C-TPAT requires the use of E-Verify to certify all employees’ eligibility status to work in the United States.

Read Customs & Border Protection’s bulletin regarding this requirement here: http://www.cbp.gov/sites/default/files/documents/bullentin_feb14.pdf

This system compares completed Form I-9s with data from the U.S. Department of Homeland Security and the Social Security Administration in order to confirm that an individual is eligible for hire. In order to meet this requirement and use E-Verify, Partners must complete the Form I-9, Employment Eligibility Verification, for every employee.

U.S. employers face very specific requirements when hiring new employees, so it is crucial that C-TPAT Partners examine and verify potential employees’ eligibility no matter their immigration status through the completion of the Form I-9 and the subsequent use of E-Verify.

If an I-9 violation is discovered by C-TPAT, the Supply Chain Security Specialist will guide the Partner in coming up with an appropriate solution, but will not issue a fine or penalty. If another agency (non-voluntary, unlike C-TPAT) discovers an I-9 violation during review of the Partner, employers may be fined.

Additional Information

Form I-9

Information on E-Verify


By Abby Frank, Consulting Coordinator



C-TPAT-To Join or Not to Join

Is your company still on the fence about participating in Customs-Trade Partnership Against Terrorism (C-TPAT)?

Are the benefits of 3.5 to 5 times fewer inspections, access to FAST lanes, securing your supply chain (and hence, your reputation), plus the opportunity to participate in other U.S. Customs & Border Protection programs not enough of an enticement?

Here’s an incentive that may sway your company’s mind: the loss of business opportunities.

U.S. Customs strongly advises all C-TPAT partners to encourage their business partners to participate in C-TPAT. Many importers have taken this message to heart, and are requiring importers they purchase from domestically to also be C-TPAT certified in order to do business with them. A well recognized company does not want to be linked with a supplier who experienced a security breach within their supply chain, no matter how small the supplier.

As U.S. Customs continues to mutually recognize the supply chain security programs of other countries*, we are seeing more foreign participants requiring their international trade partners to participate in their own country’s supply chain security program. Foreign manufacturers understand inspection of their cargo is minimal when their entire supply chain is certified in mutually recognized supply chain programs, resulting in quicker processing time of their cargo and availability of their product in the market.

Doing business with companies certified in mutually recognized supply chain programs lessens the burden of work when assessing your supply chain. You don’t have to assess a business partner that is already certified in a supply chain program–they’ve already done that for you, and their Customs agency has confirmed that they’ve done their due diligence by certifying and validating them.

Instead of thinking about whether or not your company should participate in C-TPAT, ask yourself this: can we afford to lose business opportunities because we aren’t certified?

*U.S. Customs & Border Protection mutually recognizes the following foreign supply chain programs: Canada, EU, Japan, Jordan, Korea, New Zealand, and Taiwan.

Beverley Seif is Vice President & General Manager of Mohawk Global Trade Advisors. Read more about Beverley.

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Mohawk Global Trade Advisors, a division of Mohawk Global Logistics © 2016