James Snider, Asst. Director, Customs and Border Protection, is

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Apparel, Footwear and Textiles
Center of Excellence and Expertise
1
Why Centers?
 Respond to the dynamic trade environment
 Bring all of CBP expertise together on a single industry at the
national level
 Deliver greater consistency and harmonization
 Align CBP processes with modern business practices
 Enhance industry-based knowledge
 Implement manage-by-account practices
Textiles
Intellectual
Property Rights
Revenue
Trade
Agreements/
Preference
Programs
Anti-Dumping
Countervailing
Duties (ADCVD)
Import Safety
Agriculture
Trade Complexity
2
What are Centers?
 Virtual organizations that leverage
technology to bring work to the Center
 Coordinated from a strategic location
CEE
 Aligned by key industry sectors
 Bring existing expertise together to
authoritatively facilitate trade
 Provide a single point of processing for
participating importers
 Serve as resource to the broader trade
community and to CBP’s U.S.
government partners
3
Goals of Centers
1. Facilitate legitimate trade through effective risk segmentation
-
Utilize account based methods to process trade
-
Expand partnerships - move more importers to trusted trader status
-
Develop and implement comprehensive strategies to manage risk
2. Increase industry-based knowledge within CBP
-
Advance bi-directional education to raise industry knowledge
-
Engage industry groups and key stakeholders
-
Bring all of CBP’s expertise to bear on a single industry in a virtual
environment
3. Enhance enforcement and address industry risks
-
Leverage industry to identify issues of mutual interest to provide CBP with
targeting, enforcement, and/or intelligence information – Trade Intelligence
-
Coordinate enforcement efforts by industry to address unique risks
4
It’s a challenging task
 1,900 miles of border with Mexico.
 5,000 miles of border with Canada.
 327 “ports of entry”—official entry or crossing points.
 CEEs help minimize the challenge for both CBP and the
trade community.
C-TPAT Today
 Over 10,000 members
 Represents approximately 50% of the total value of
merchandise imported into the United States
 Strives to set the Global standard for supply chain
security
 Requirement to participate in Importer SelfAssessments
 Priority status given when applying to the CEEs.
Enforcement

IPR Seizures
Focus on areas of risk
1. Intellectual Property Rights
 59% of all FY 12 IPR seizures
 Undermine domestic producers
50%
40 %
11 %
25%
8%
0%
Handbags/Wallets
Wearing Apparel
Footwear
2. Trade Agreements
 14% of imported value claims preferential treatment
 False preferential claims undermine trade agreements
3. Revenue
 Duty collected by CBP on textile and apparel goods still accounts for
more than 40% of all duties
 Misclassification and undervaluation are schemes to evade high duty
rates on textiles and footwear
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Effective Enforcement Targeting

Center and Industry Partners work collectively to define low-risk suppliers
and sharing trade intelligence to better define and segment high-risk
suppliers.

The Center’s national approach is assisted through leveraging the
Commercial Targeting and Analysis Center (CTAC) in Washington, DC.

Established in 2009, CTAC serves as CBP’s multi-agency fusion center
for targeting commercial shipments which pose a threat to health and
safety.

Nine (9) Federal agencies co-located : CPSC, EPA, DOT, DHS, USDA,
FDA.

Federal agencies with authority governing the safety of product imported
into the U.S. acknowledge the need to share information about the
safety of those products. CTAC provides the vehicle to facilitate the
sharing of information and leverage the collective resources of the
participating government agencies.
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How Centers Operate
Previously
• ACME Apparel was importing into
60 Ports of Entry (POE), with 60
ports conducting reviews.
Center Operations
• Instead of 60 ports making decisions
on ACME Apparel entries, they would
now be reviewed by the Apparel,
Footwear & Textiles Center of
Excellence which will be coordinated
from San Francisco, CA.
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Projected End State Procedures
Port of Entry
Centers of Excellence and
Expertise

Entry Summaries (ACS/ACE)

Cargo release/Admissibility

EIP/RLF

Inbond

Rejections/Cancellation

Warehouse entries

Census Warnings

Bonded warehouses

CBP 28 and 29

FTZ

AD/CV

Submit necessary documentation for release

Revenue Collection

Adhere to current regulations

Reconciliation

ALL processes will remain at the ports

Quota Entries

Drawback Center

Post-Summary Corrections

Post-Entry Amendments

Internal Advice

Protests/Petitions

Prior Disclosures

Temporary Importations under Bond (TIB)

Liquidation

NO CHANGE TO EXSITING SHIPPING
PATTERNS
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Benefits of Centers
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Center Customer Satisfaction
 First ever benchmarking survey gave high marks for CEE
customer satisfaction for both populations the CEEs serve—
participating accounts and those that use the CEE as an
importing resource.
CEE Participating Accounts
74% “Very Satisfied” after contacting a CEE
After contacting a CEE, over 96% received a
resolution on their issue.
• 65% of respondents indicated that their CEE
processes all of their company’s Importer of
Record (IOR) numbers
• Most contact the CEEs a few times a year,
often to discuss C-TPAT questions and
procedures.
•
•
CEE Non-Participating Accounts
•
•
•
18% reached out to the CEEs on compliance
issues, and 61% received adequate assistance
from CBP regarding their concern.
Those that contact CEEs primarily do so a few
times a year.
Respondents primarily contact CEEs about CTPAT questions/procedures, CBP holds and
release times, and exams, 96% receiving a
resolution to their issue.
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Centers of Excellence and Expertise
San Francisco
2
6
Los Angeles
1. Agriculture & Prepared Products
2. Apparel, Footwear & Textiles
Chicago
3. Automotive & Aerospace
4
4. Base Metals
5. Consumer Products & Mass Merchandising
6. Electronics
7. Industrial & Manufacturing Materials
8. Machinery
9. Petroleum, Natural Gas & Minerals
10.Pharmaceuticals, Health & Chemicals*
Buffalo
Detroit
7
3
10 New York
5
Atlanta
9
8
Laredo
Houston
1
Miami
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Center Schedule Opening Dates
Year
FY 2012
Center
•
•
•
•
Pharmaceuticals, Health & Chemicals
Electronics
Automotive & Aerospace
Petroleum, Natural Gas & Minerals
April
2013
• Base Metals
• Industrial & Manufacturing Materials
• Machinery
June
2013
• Agriculture & Prepared Products
• Apparel, Footwear & Textiles
• Consumer Products & Mass Merchandising
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Apparel, Footwear and Textiles Import Highlights

$131.6 billion in footwear, textile, wearing apparel products
come into the U.S. (5.5% of all imported value)

Top 5 countries of origin account for 66% of these imports
 China ($58.5 billion)
 Vietnam ($9.6 billion)
 India ($6.5 billion)
 Indonesia 4 ($6.2 billion)
 Mexico ($5.8 billion)

Over 64,800 entities import footwear, textiles and wearing
apparel
 378 entities are ISA (23.9% of imported value)
 3,144 entities are C-TPAT partners (62.1% of imported value)
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Center Myths- Participation

I’m not C-TPAT or ISA, the Centers aren’t for me.

Under the Center test notice issued in the Federal Register,
preference will be given to C-TPAT/ISA accounts, but it is not
required to be managed by a Center.

I’m not filing in ACE, I can’t be part of the Centers.

Participants and filers can transmit the necessary
documentation electronically via the ACE portal, the
Document Image System (DIS), but also via email to the
Center.
16
Center Myths- FRN

I’m automatically going to be part of the Center’s
managed accounts.

You must volunteer! There is a test notice in the Federal
Register seeking importers to volunteer for the six new
Centers. The FRN details the processes and procedures for
volunteering to participate in the Centers. To receive
centralized processing benefits from the Center, you must
volunteer.

Even for importers that don’t volunteer the Centers will be
available to assist them, and all members of the trade
community. The Centers will address an entire industry, and
be a source of definitive information for questions or concerns
related to that industry. In this way, the Centers are available
to all importers.
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Center Myths- Operations

I’m going to have to change where I import because of
the Centers.

No. The Centers are virtual. CBP will leverage technology to
bring the work to the Centers, regardless of where the entry of
merchandise occurs.

I import products in multiple industries, I’m going to have
to apply to every Center.

No. The Centers are "industry focused, and account based."
Importers will have the opportunity to volunteer for the Center
that best fits their business. The assigned Center will be the
primary point of processing for all entry summaries,
regardless of the commodity that is entered.
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Center Myths- Sequestration

Sequestration will impact CBP’s Centers

The Centers are revenue neutral. This means that the
implementation of the Centers is based on the realignment of
existing resources into a new Center-based organizational
structure.

CBP is committed to the Centers as the future of trade
processing.
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Questions?

Contact:
James Snider
Apparel, Footwear and Textiles CEE
Assistant Director,
U.S. Customs and Border Protection
James.snider@dhs.gov
(619) 744-5217
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