In last week’s post, we talked about the role of the Advisory Committee on Commercial Operations of Customs and Border Protection (COAC). And, if you attended CBP’s first West Coast Trade Symposium last week, you would have learned about the two new industry trade centers, known as the Centers of Excellence and Expertise (CEEs). How are COAC and the CEEs related? Well, the idea for the CEEs was one of many ideas developed and put forth by COAC. In 2009, COAC, in its advisory capacity, suggested that CBP shift its approach to view companies as accounts rather than review each entry on a transaction by transaction basis. In response to COACs suggestions, CBP formed a workgroup to take a deeper look into this very different approach as to how the trade and CBP would work together to facilitate trade and to minimize the threat to our nation’s security. What are these CEEs all about?
The CEEs actually have been operating as a pilot program since November 1, 2010. In creating a pilot program for the CEEs, former Commissioner Alan Bersin also wanted to focus on creating an account executive and an industry specific CEE. The account executive pilot was created with the intent of focusing on those companies with good compliance history and were members of CBP’s trusted partnership programs like CTPAT, ISA, etc. The industry specific pilot would look at an entire industry in totality with the intent of facilitating trade and bringing uniformity to CBP’s practices across all ports, nationally. The workgroup identified several industries:
- Agriculture & Prepared Products
- Automotive & Aerospace
- Base Metals & Machinery
- Consumer Products & Mass Merchandising
- Industrial & Manufacturing Materials
- Petroleum, Natural Gas & Minerals
- Pharmaceuticals, Health & Chemicals
- Textiles, Wearing Apparel & Footwear
These industries were targeted for several reasons:
- Companies in these industries imported large quantities of high value goods;
- Companies in these industries partnered with CBP and were members of CBP’s trusted partnership programs; and
- Identified industries enabled CBP to work with other regulatory governmental agencies.
For the pilot programs, the workgroup narrowed it down to the pharmaceutical industry, selected for the industry center CEE and electronics, selected for the account executive CEE. With specific industries identified, CBP identified three goals for the centers:
- Develop agency knowledge and expertise concerning a specific industry;
- Facilitate shipments for trusted partners;
- Develop quality enforcement operations that enable CBP to go after high-risk companies or importers that the agency knew little, if anything, about.
Throughout the pilot program, CBP and the companies within the identified industries partnered with one another. For example, during the pilot program, CBP met with 22 of the largest pharmaceutical importers over a two-day period to discuss business processes, to understand why certain business decisions were made and to understand how industry worked with the other governmental agencies.
The pilot programs also allowed CBP to work very closely with the other governmental agencies and to share and access their data and information. This proved to be invaluable as both agencies could identify discrepancies with the information that was submitted, which ultimately led to CBP identifying smuggling activities.
Overall, the CEE pilot programs seem to be moving in the right direction. And, although there may be some bumps down the road, the information between industry and CBP and CBP and other regulating governmental agencies is becoming more and more transparent, which is moving us all towards the fundamental goals of facilitating legitimate trade and to allow CBP to focus on potential threats to the nation’s security and economic competitiveness. The CEEs are not only important for importers – brokers are critical partners and also play an important role. Where a broker would have once interacted with the port, the broker will now interact with the appropriate CEE.
But wait, there’s more news, last week, CBP Acting Commissioner David Aguilar announced that CBP is expanding the program creating two more CEEs: a center for Automotive and Aerospace in Detroit and a center for Petroleum, Natural Gas and Minerals in Houston.