What is the CTPAT Trade Compliance Program, and Why Does It Matter?

The Customs Trade Partnership Against Terrorism (CTPAT) Trade Compliance Program is a voluntary U.S. CBP program that provides importers the opportunity to make a commitment to supply chain mapping and compliance in exchange for a specific set of benefits.

These benefits include: priority admissibility review if importers who are members of the Program have their shipments detained due to the U.S. forced labor ban, a Withhold Release Order, or CAATSA; advanced notice if CBP becomes aware of errors indicating a possible violation of 19 U.S.C. 1592 or 1593a, giving the member 30 days from the date of the communication to perform a self assessment and submit a written disclosure of the relevant facts to CBP, and; redelivery hold benefits, in which members who have shipments held for forced labor issues may hold their shipments intact at their own facility until CBP resolves the issue (rather than at a customs facility, at the importer's expense).

CTPAT Trade Compliance Program requires ongoing forced labor due diligence and supply chain mapping

Once importers are accepted into the CTPAT Trade Compliance Program, they must ensure they uphold program requirements to maintain their membership. This includes continued compliance with all CBP laws and regulations, particularly forced labor prevention.

According to the CTPAT Trade Compliance Handbook, Trade Compliance Program members must conduct risk-based analysis of supply chain partners (i.e. suppliers) that outlines the supply chains in their entirety to include regions, suppliers, and other factors that the importer feels poses the most risk for forced labor to ensure the supply chain is free from the use of forced labor. Importers are required to determine within their organization what imports are considered high risk to their business model but should take into consideration information that CBP provides publicly on CBP.gov.

Partners must also create a code of conduct statement that represents their position against the use of Forced labor within any part of their supply chain. Partners must have policies and procedures in place that operationalize the code of conduct, as well as evidence of those policies’ implementation.

Partners must provide training about the social compliance program requirements to their suppliers that identifies the specific risks and helps identify and prevent forced labor in the supply chain. The training should exemplify the company's position against Forced labor as stated in their code of conduct. Training requirements are determined by the partner but must ensure that the suppliers business model and code of conduct represent they will not partner with business that use forced labor.

Partners must maintain a remediation plan for their organization, in the event forced labor is identified in their supply chains and provide this information to CBP, upon request. This plan must include the process for disclosing the identification to CBP and outline the necessary steps for the organization’s employees and suppliers to correct the issue.

CBP and FLETF continue to promote the benefits of joining the CTPAT Trade Compliance Program as part of their efforts to ensure importers comply with the U.S. forced labor ban. To learn more about how Sourcemap can help your business maintain existing membership with the Program, or begin the Trade Compliance application process, reach out to our policy team today.