Cargo Security

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Following the tragic events of 9/11, the Bureau of Customs and Border Protection (CBP), a part of the Department of Homeland Security (DHS) that was formed in response to those events, together with other agencies in DHS, became responsible for ensuring that goods being imported into the U.S. had been secured from terrorist threats. A number of different legal requirements have been instituted, most recently the requirement that importers file an Importer Security Filing (ISF) with each entry of containerized cargo. The US has also worked with numerous port authorities around the world to enhance the security measures taken overseas before cargo whose final destination is the US is laden on a vessel. Air cargo is also subject to enhanced security requirements, including cargo handled by express couriers.

Customs-Trade Partnership Against Terrorism

However, the program that has probably had the greatest impact on importers and foreign suppliers is the Customs-Trade Partnership Against Terrorism (C-TPAT), which CBP first rolled out in 2002. While this, nominally, is still considered a "voluntary" program, market conditions, such as the requirement that C-TPAT members only deal with business partners who are either C-TPAT members or can certify that they meet C-TPAT minimum security standards, suggests that it is, for practical purposes, a requirement for all importers. Security reviews have also been made a standard part of a Customs audit for those companies who are not members of C-TPAT.

C-TPAT Application

The procedure for joining the C-TPAT program, and the conditions for maintain membership in the program are found on the CBP website. Briefly, the applicant, which may be an importer, broker, other party in the supply chain such as a carrier or consolidator, as well as certain foreign suppliers, must respond to the questions on the CBP website which address the security profile of the applicant. A Supply Chain Security Specialist (SCSS) will review the responses and if all are acceptable, will inform the applicant that they have been accepted as a member of the program. In the case of an importer the application will ask questions about the security measures that are in place at all of the locations which handle cargo destined to the U.S. such as factories, consolidators, warehouses, etc. They questions are quite specific, such as what type of physical security is present at the plant, is there a perimeter fence, what type of access controls are in place for visitors and employees, how is inventory guarded, what procedure is followed to load and seal containers, what type of security training and awareness programs are in place, what type of IT security is in place and similar questions that are all designed to allow CBP to acertain whether the facilities met so-called “minimum security requirements.” After an importer is accepted into the program, CBP will schedule a validation, i.e.., a visit to a foreign facility. If the security procedures at the facility are found to be acceptable the importer will become a certified member and be giving a rating of Tier II (meets minimum security standards) or Tier III (exceeds minimum security standards), or will fail the validation and be given an opportunity to address the changes that have been identified or be suspended from the program. Every member has to be re-validated every three of four years, depending on their status in the program.

BRC has assisted many importers in helping them prepare for the application process, assisting in filing the application and preparing companies for a successful validation. Several clients that we have helped have attained Tier III status, a ranking that is achieved by only a few hundred of the ten thousand companies who have joined so far. We have provided guidance on how to evaluate several hundred supply chains that individual companies may have and have provided clients with all the necessary tools needed to remain member in good standing in the program.

Mar. 12, 2026: Here Come the Section 301 Investigations
Mar. 12, 2026: CBP Updates Court on IEEPA Refund Process and Technology
Mar. 11, 2026: AD/CVD Petitions Announced on Lithium Battery Chemicals from China
Mar. 10, 2026: Bills Introduced in House and Senate to Restrict Non-Resident Importers
Mar. 9, 2026: States Challenge Section 122 Tariffs
Mar. 6, 2026: Customs Proposes IEEPA Refund Process to Court
Mar. 4, 2026: CIT Orders Refunds; Appeal Likely
Mar. 2, 2026: IEEPA Case Expedited to CIT for Relief
Feb. 27, 2026: New AD/CVD Petitions on Truck Bed Covers from China
Feb. 27, 2026: "Trade Deals" Under Reciprocal Tariff Framework Have Uncertain (and Maybe Varying) Futures
Feb. 27, 2026: Battle of 122 Tariffs: Is it 10 or 15%?
Feb. 27, 2026: Wither De Minimis After the Supreme Court IEEPA Decision?
Feb. 11, 2026: Legislation Introduced to End First Sale
Feb. 10, 2026: United States & Bangladesh Agreement on Reciprocal Trade
Feb. 9, 2026: U.S. and India Announce Interim Trade Deal
Feb. 6, 2026: Secondary Tariffs Threatened on Countries Selling Oil to Cuba
Feb. 6, 2026: U.S. Finalizes Terms on Trade Agreement with Argentina
Feb. 3, 2026: Answering Dumping Questionnaires Just Got Harder
Feb. 2, 2026: Apparent India/U.S. IEEPA Duty Deal Reached
Feb. 1, 2026: El Salvador and Guatemala Get IEEPA Deals
Jan. 26, 2026: BIS and Customs Funding Appropriations: Where We Are and What's It All Mean
Jan. 26, 2026: Trump Threatens to Increase Korean Tariffs to 25%
Jan. 20, 2026: Trump Threatens Europeans With More Tariffs Over Greenland
Jan. 15, 2026: Negotiations Chosen Over Tariffs for Critical Minerals, For Now
Jan. 15, 2026: New 25% Tariff Imposed on Certain Semiconductor Imports
Jan. 15, 2026: Taiwan Said to Have Trade Deal with United States
Jan. 10, 2026: CAFC Upholds Use of Domestic Sales for Transaction Value
Jan. 5, 2026: Upholstered Wooden Products, Kitchen Cabinets, and Vanities Tariff Hike Delayed
Jan. 5, 2026: CBP Mandates Electronic Refunds Effective February 6
Dec. 23, 2025: U.S. Imposes Phased-In Duties on Certain Nicaraguan Imports
Dec. 23, 2025: USTR Publishes Semiconductor Section 301 Results
Dec. 22, 2025: Big Fines for (alleged) Duty Evaders
Dec. 17, 2025: U.S. Eases Tariffs for Switzerland and Liechtenstein While Trade Deal is Negotiated
Dec. 12, 2025: USTR Greer Says More Trade Deals are Coming, While U.S. Considers USMCA Review in 2026
Dec. 12, 2025: CAFC Rules Planning Calendar Classification Already Decided
Dec. 12, 2025: Customs Proposes Revoking Handicap Article Status From Ramps
Dec. 9, 2025: OFAC Imposes Large Russia Penalties as 2025 Comes to a Close
Dec. 5, 2025: BIS Steel & Aluminum Derivative Decision Pushed to 2026
Nov. 17, 2025: Reciprocal Tariff Exemptions Expanded
Nov. 14, 2025: Switzerland Announces 15% Tariff Deal with the United States
Nov. 11, 2025: China Suspends & Delays Rare Earth Export Restrictions
Nov. 5, 2025: White House Caps China IEEPA Fentanyl and Reciprocal Tariffs at 10%
Nov. 4, 2025: U.S. and China Strike Trade Deal — Export Controls Front and Center
Oct. 30, 2025: U.S.-Korea Trade Deal Details Released
Oct. 28, 2025: Japan in Critical Minerals Agreement with U.S.
Oct. 27, 2025: Trump Terminates Talks on Trade with Canada
Oct. 27, 2025: USTR Confirms Trade Frameworks with Cambodia, Malaysia, Thailand, Vietnam (so far)

View Archive

Jan. 22, 2025: Webinar: What We Know After the Inauguration
Sep. 9, 2024: McPherson to Co-Moderate Export Enforcement Discussion
Jun. 2, 2023: BRC and Attorneys Ranked in 2023 Chambers Guide
March 2, 2017: David G. Forgue to Participate in Georgetown International Trade Update
June 28, 2006: Customs-Trade Partnership Against Terrorism: What you Need to Know and What to Expect
By: Frederic D. Van Arnam, Jr.
April 26, 2006: New C-TPAT Standards for Highway and Sea Carriers
July 19, 2005: C-TPAT Applications to be Made On-Line
Jun. 24, 2004: Bioterrorism Penalty and Mitigation Guidelines Announced
Apr. 23, 2004: Update on FDA Registration and Prior Notice
October 2003: Securing the Supply Chain
By: Frederic D. Van Arnam, Jr.
August 2003: Cargo Security -- The Legal Perspective
By: Frederic D. Van Arnam, Jr.
May 2003: Cargo Security and U.S. Customs
By: Frederic D. Van Arnam, Jr. and Robert E. Burke

Final C-TPAT Security Criteria

Information on the Bioterrorism Act of 2002