Thursday, April 13, 2006



The 9/11 Commission Report recognized that a container shipment is the most likely way for a WMD to enter the US. But backfilling the holes in the global trade system is a gargantuan task. U.S. Customs and Border Protection (USCBP) has made outstanding progress with programs like the Customs-Trade Partnership Against Terrorism (C-TPAT). Can more be done? Absolutely. It just takes money.

There are off-the-shelf technologies currently available that when used properly can provide essential information on a shipment’s movements from a foreign manufacturer’s facility, through the supply chain, and all the way to the U.S. customer. But there appears to be no enduring (government) mechanism in place for submission of such solutions for evaluation and/or approval. The ability to allocate just 40 auditors to the 5,000 C-TPAT applicants is indicative of the budgetary challenges USCBP faces.

What’s baffling is that C-TPAT is in keeping with the administration’s strategy of keeping threats offshore. So this under-funding, especially when compared with the astronomical funding levels for larger operations with a similar goal of insulating us from the fight, begs the question: Do our leaders take these USCBP initiatives seriously? Until we make a real commitment to these programs and the technologies to support them, no one should be surprised that there are gaps in the system.


Is C-TPAT Protectionist?

The Importer of Record has been a fan of C-TPAT in the past, but a colleague in the chemical industry has wondered recently if the program will ultimately mean de facto protectionism. Here's what she had to say:

"Vendors in the Third World do not have the means to comply with C-TPAT. They probably never will because our industry will not be able to buy from them if we want to reap the benefits of C-TPAT. And as C-TPAT is phased in as law, as opposed to the voluntary program it is now, it will become impossible to do business in these countries. Obviously, the less we buy, the fewer resources they will have to become compliant... it's a vicious cycle."

The Importer of Record is concerned with the ability of US-based importers to participate in C-TPAT. The program seems to have been designed without adequate consideration of how the small-medium importer will be able to absorb the cost of compliance. The scenario above would only compound the problem. The end result would be that many, many small-medium US-based importers, the backbone of the industry, will be forced out of business. The economic damage from 9/11 still reverberates...

Tuesday, April 11, 2006


REACH (It's not a toothbrush)

The Importer of Record recently attended a conference on the Eurpoean Union's REACH program. REACH stands for Registration, Evaluation and Authorisation of Chemicals. In short, REACH seeks to rewrite the standards governing chemicals imported into the EU's 25 member countries. Although specifically tailored to chemicals, REACH will have profound implications for the cosmetics, textile, food, and pharmaceutical industries. You may read more about REACH at:

If you don't know about REACH, you will soon...

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