January 26, 2021

Volume XI, Number 26


January 26, 2021

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January 25, 2021

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CBP Requesting Comments on Collection of Trusted Trader Information

On Monday, August 31, 2015, U.S. Customs and Border Protection (CBP) announced it will be collecting comments on the draft application for its Trusted Trader Program (the Program). CBP invites the general public and other Federal agencies to comment on the proposed information collection pursuant to the Paperwork Reductions Act of 1995 by September 30, 2015. Comments should address:

  • Whether the collection of information is necessary for the proper performance of the functions of the agency;

  • The accuracy of the agency’s estimates of the burden of the collection of information;

  • Ways to enhance the quality, utility and clarity of the information to be collected; 

  • Ways to minimize the burden; and

  • Annual costs of respondents from the collection of information.

CBP’s new Trusted Trader Program will unify supply chain aspects of the current Customs-Trade Partnership Against Terrorism (C-TPAT) program and internal controls of the Importer Self-Assessment Program to integrate supply chain security and trade compliance. A pilot of the Program began last year. Only importers who have satisfied C-TPAT supply chain security and trade compliance requirements may apply for the Program.

CBP is developing an online application for the Program, which will be available through the C-TPAT portal. The application includes questions on the following:

  • Name and contact information for the applicant; and

  • Information about the applicant’s Supply Chain Security Profile, Trade Compliance Profile and Operating Procedures.

After importers are accepted into the Program, the importer will be required to submit an Annual Notification Letter to CBP confirming they continue to meet the requirements of the Program. Similar to the current requirements in the ISA program, the Annual Notification Letter should include information on personnel, organizational and procedural changes that impact the importer’s participation in the Program, a summary of risk assessment and self-testing results, a summary of post-entry amendments and/or disclosures made to CBP and any importer activity changes within the year period.

CBP is requesting comments on the draft application and the Annual Notification Letter. Although CBP previously requested comments in March, it had not yet developed its draft application and it revised its estimated information collection burdens.

© 2020 Faegre Drinker Biddle & Reath LLP. All Rights Reserved.National Law Review, Volume V, Number 244



About this Author

Kathleen Murphy, International trade Lawyer, Drinker Biddle

Kathleen M. Murphy counsels clients on maximizing trade benefits, making informed global procurement decisions and developing domestic and international trade compliance programs. She represents clients in duty-recovery initiatives and customs challenges concerning tariff classification, valuation, Free Trade Agreements and country of origin determinations, among other areas. She guides clients through compliance audits and validations, as well as penalty investigations conducted by U.S. or foreign customs authorities. She also represents clients in...

Mollie Sitkowski, Drinker Biddle Law Firm, Chicago, Trade Law Attorney

Mollie D. Sitkowski assists clients in ensuring their internal processes meet Customs' "reasonable care" standard. She assists clients with various aspects of trade law, including valuation, classification, free trade agreements, country of origin determinations, and auditing their import documentation to identify potential issues and risk areas. Mollie also supports clients with export compliance, including advising on export screening and classification, and filing license classification requests and voluntary disclosures with the Bureau of Industry...