U.S. Customs and Border Protection issued in late December a statement of work that provides some details on the scope of the proposed global trade exchange program. GTX is intended to further improve supply chain security by gathering and consolidating an even broader range of trade data from a wider variety of supply chain actors. Agency officials have said that this additional information would allow CBP to be more precise in identifying risks and to thus conduct fewer and better-targeted cargo inspections.
Highlights of the information provided by the statement of work include the following.
• CBP is planning to conduct and evaluate a GTX pilot test as Phase III of the Secure Freight Initiative. This pilot will be operational for at least six continuous months within the base 12-month period of the contract and may be extended for an additional year.
• GTX is envisioned as a privately operated, self-sustaining (e.g., user-fee based) system that will collect commercial transaction data not currently available to CBP from parties in the supply chain who have contracted or provided services for the production or movement of international shipments.
• GTX will be housed on the contractor’s secured system at its facility. During its
operation, various governmental, domestic and international trading partners, as well as commercial entities, will have real-time access to the data it collects.
• The GTX contractor will be required to design, develop, operate and maintain a system that:
- collects, integrates, transforms, displays and transmits data from (a) commercial supply chain data not currently available to CBP (e.g., purchase orders, fulfillment schedules and invoices), which may include radio frequency identification status messages from container security devices, (b) vessel transponder data, and (c) other information regarding production management records, inventory records and advance ship notices from foreign suppliers that the GTX pilot contractor may identify as useful;
- coordinates with all supply chain parties providing information to GTX and establishes and maintains all necessary communications and interfaces;
- complies with applicable U.S. and foreign privacy and security requirements and statutes;
- develops practices and procedures, participant agreements and technology for the retention and protection of collected data;
- demonstrates the reoccurring capability to timely and accurately provide data to CBP in a data format that is acceptable through all existing CBP communication protocols and meets all CBP statutory and regulatory requirements; and
- provides unlimited access to data for CBP at no cost to the agency during the pilot and at no cost and with no access limitations to any system resulting from the GTX pilot.
• The GTX contractor will have to identify and have signed participation agreements with up to 10 industry participants, including shippers and carriers, such that not less than 100 transactions will be available for one of the following trade regions: European Union, Pacific Rim and Middle East. A minimum of 1,200 fused supply chain data transactions must be available within the period of contract performance for each signed and identified participant. Each industry participant must provide data associated with at least 100 import or export transactions per month.
• The GTX contractor will have to identify at least three foreign government customs agencies to participate in the GTX pilot for one of the following trade regions: EU, Pacific Rim and Middle East.
• The contractor will be required to design, develop and maintain an operational GTX prototype that fuses available participant supply chain data from the point of the initiation of the commercial transaction through the logistics and financial components to the final consumer destination and acceptance of the cargo and closure of the financial obligation. The prototype must include the collection and fusion of commercial security data, including RFID status messages, container security device readings and radiation detection data. It must also associate commercial security data to supply chain data.
• GTX data must include all applicable modes of transportation, including sea, air, rail and truck, for the regions identified above for relevant supply chains.
In a Dec. 21 letter to House Homeland Security Committee Chairman Bennie Thompson, World Shipping Council President Christopher Koch said the GTX proposal raises a number of concerns. He pointed out that it seeks “an enormous amount of data” but that it is “imprecise and vague” in its description of the specific information to be collected. He noted that the provisions on information access raise “a host of significant, legitimate questions about who would have access to what data in a GTX system and under what terms.” He also stated that there is no assessment of GTX benefits to shippers, suppliers, carriers or CBP’s security programs and capabilities, particularly in comparison with the costs to be imposed on participants.
World Trade/Interactive
