CBP Provides Add'l Info on Industry Integration Centers (Formerly CEEs)

Centers for Pharmaceuticals & Electronics Were Established in Oct 2011

In October 2011, CBP established the Pharmaceuticals Center which previously functioned as a CEE pilot and the Electronics Center which previously functioned as an Account Executive pilot. The Centers bring all of CBP's trade expertise to bear on a single industry in a strategic location to help CBP increase uniformity of practices across ports of entry, facilitate the timely resolution of trade compliance issues nationwide, and further strengthen critical agency knowledge on key industry practices. They are staffed with numerous trade positions using account management principles.

(See ITT's Online Archives 11102610 for summary of the establishment of these Centers.)

Centers Serve as Resource to Broader Trade Community & Gov't Partners

Each Industry Integration Center will become an industry-focused resource for the broader trade community and to CBP's government partners. The Centers will address an entire industry and provide a single point of contact for questions or concerns related to that industry. Center personnel will answer questions, provide information, and develop trade facilitation strategies to address uniformity and compliance concerns. They will also develop and foster training initiatives, which may include collaborative efforts with the private sector to enhance agency understanding of the industry at large.

CBP states that the Centers can serve as an important resource for small and medium-sized importers, who may not have large compliance departments, as importers of all sizes can access the Centers for information on CBP requirements and best practices related to a particular industry.

To also Provide "Single Point of Processing" for Trusted Traders

Initially, the Centers will serve as a single point of processing for businesses enrolled in CBP's trusted shipper programs: the Customs-Trade Partnership Against Terrorism (C-TPAT, Tier 3 or 2) and Importer Self-Assessment (ISA).

Required import documents for trusted partners will be routed to their respective industry Center. While revenue collection will continue to be carried out at the ports of entry, the Centers will process entry summaries and begin to perform subsequent activities, such as all validation activities, protests, post entry amendment/post summary correction reviews, and prior disclosure validations for the trusted partners within their industry.¹ As the Centers expand, CBP will look for opportunities to work with industry on expanding the definition of a trusted trader.

Centers Will Be Expected to Partner with Other Gov't Agencies

The Centers will be expected to partner with other government agencies (OGAs, such as FDA, CPSC, etc.) and promote the adoption of risk management and segmentation practices, which will result in even greater facilitation of legitimate trade and enhanced enforcement activities. CBP states it would welcome OGA participation and staffing in the Centers whose industries are regulated by those agencies.

CBP to Establish Add'l Centers over Next 3 Yrs to Cover Full Range of Imports

CBP plans to establish additional Centers over the next three years. By the end of that period, the full range of imported commodities² would be covered by the Centers.

(See ITT's Online Archives 11102610 for summary of the CBP's proposal to create Centers for an additional 8 industries.)

Benefits Include Fewer Cargo Delays, Reduced Costs, Greater Predictability, Etc.

The Industry Integration Centers fundamentals of staffing, structure and processing are the same; however, each industry has its own unique qualities, and the Centers will be flexible in providing facilitative benefits to each industry that make sense for that industry. CBP lists the following general benefits of the Centers:

• The Centers eliminate unnecessary transactional work from compliant imports, resulting in fewer cargo delays, reduced costs, and greater predictability.
• Ports of Entry shift their focus to high-risk shipments, which creates more complex enforcement work for highly skilled CBP employees and improves enforcement results, i.e., increased import safety, increased revenue protection, and reduced economic loss due to intellectual property rights (IPR) theft.
• The Single Point of Contact for inquiries improves relationships with CBP as small/medium-sized importers have a streamlined inquiry process for resolving concerns. The Centers also create increased uniformity and transparency for the trade and provide a forum to work with other government agencies to address requirements efficiently.
• The Centers also have cross-functional expertise in that it provides an environment for in-depth learning to increase CBP expertise and therefore enforcement.

¹For example, an electronics importer may import through 60 ports of entry, with post-release processing being done at each location. Once the Centers are fully staffed and have necessary trade functionality, such processing will be handled by the Centers, leading to greater uniformity in decision making.

²Including the recently established Centers for Pharmaceuticals and Electronics, CBP has proposed Centers to cover a total of ten industries: (1) Agriculture and Prepared Products; (2) Automotive and Aerospace; (3) Base Metals and Machinery; (4) Consumer Products; (5) Customhouse Brokers; (6) Industrial and Manufacturing Materials; (7) Information Technology and Consumer Electronics; (8) Petroleum, Natural Gas and Minerals; (9) Pharmaceuticals, Health and Chemicals; and (10) Textiles, Wearing Apparel and Footwear.

(See ITT's Online Archives 11120903 for summary announcing CBP has renamed the Pharmaceutical CEE as an Industry Integration Center.)