CSI (24 hour rule) requires sea carriers and NVOCC (Non vessel Operating Common carriers) to provide US customs with detailed descriptions (manifests) of the contents of containers bound for the United States 24 hour before a container is loaded on board a vessel. Trucking companies are also bound by the 24 hour rule and are expected to provide a manifest 4 hours before trucks are loaded with products entering the United states and 24 hours in advance when leaving the United states.
The rule allows US Customs officers time to analyze the contents of the container or truck and identify potential terrorists threats before the US bound shipment is loaded at a foreign port rather than after it arrives at a US port cargo manifests must use precise as parts of the 24 hour rule freight All Kinds and Said to contain or General Merchandise descriptions often used in the past, are no longer acceptable. If any discrepancy appears on the manifest and if it is not presented 24 hours before loading, the shipment can be denied loading and entry into a US port. Whenever an invalid cargo description is used a ‘Do not Load’ message is posted and loading is denied. Cargo bound for a foreign port loaded on a vessel with cargo bound for the United States must also have a valid manifest presented within 24 hours or it will not be allowed to be shipped. A violation of the 24 hour rule may prevent the vessel from loading cargo or from unloading any cargo even if the violation applies to only one container.
In an effort to safeguard food against bioterrorism US Customs and border protection (CBP) requires the Food and Drug Administration (FDA) to receive prior notice of all food for humans and animals imported or offered for import into the United States. Carriers must file notice two hours before reaching a port of entry. Without prior notification CBP, will hold the goods at the port of entry or at an FDA registered secure facility. Food offered for import with no prior notice or inadequate prior notice will be refused admission, similar rules apply to drugs and medical devices.
Ports became the gatekeepers for the entire supply chain in preventing illegal entry of terrorists and weapons of mass destruction. They were expected to accomplish this task without interruption of service and without additional cost to shippers. Early on government regulators saw that if the burden of compliance was not going to slow the movement of goods across borders to a snail’s pace cooperation and compliances through out the supply chain.
Customs – Trade Partnership against Terrorism (C-TPAT)
C-TPAT is a joint initiative between government and business designed to augment the 24 hour rule by extending security procedures throughout the supply chain. C-TPAT requires importers to establish a documented program for security risk assessment of overseas suppliers. By requiring importers to establish a documented program for security risk assessment of overseas suppliers throughout the supply chain, companies will ensure a more supply chain for their employees, suppliers, and customers thus improving the flow of trade. Participation in C-TPAT means faster cargo processing at the border reduced number of inspections dedicated commercial lanes for more rapid border crossings and an emphasis on self policing rather than customs verification. Without C-TPAT accreditation an importer will encounter countless inspections and delays.
C-TPAT certification requires members to:
1) Conduct a comprehensive self assessment of supply chain security using C-TPAT guidelines jointly developed by US Customs and the trade community.
2) Submit a supply chain security questionnaire to US Customs.
3) Identify and complete security checks of vendors and supplies.
4) Record customs clearance documents and purchase orders
5) Ensure minimum security standard and procedures for employee screening and facilities security by suppliers.
6) Implement a program to communicate C-TPAT guidelines to companies the supply chain and work toward building the guidelines into relationships with these companies.
7) Maintain strict security procedures including security seals that are subject to periodic rigorous integrity examination and physical access controls is storage areas to eliminate unauthorized entry, pilferage and sabotage.
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