CBP Announces ISA-Product Safety Program

If you are a current ISA participant thinking about ways to improve compliance, now might be a good time to consider the Importer Self-Assessment Product Safety Pilot. In addition to receiving time on the agenda at the U.S. Customs and Border Protection Trade Symposium October 29 – 31, CBP announced in the Federal Register that they would begin a trial program to expand the Importer Self-Assessment Program to include product safety. The trial is designed to encourage companies to maintain a high-level of compliance with product safety laws and standards.

The ISA-Product Safety pilot will be conducted by CBP, CPSC and volunteer importers. Existing ISA members can apply for the product safety program and the two agencies will select a limited number of the applicants to participate. In order to participate in ISA–PS, an importer must:

· Be an active member in ISA and comply with all ISA requirements and obligations.
· Complete an ISA–PS/CPSC Questionnaire and sign an ISA–PS/CPSC Addendum.
· Agree to comply with all laws and regulations administered by CBP, as well as the CPSC
· Maintain an internal control system that ensures the integrity of product safety.
· Notify CBP of any major organizational changes that may affect the importer’s product safety controls.
· Submit an annual written notification to CBP that sets forth the importer’s ISA–PS point of contact and acknowledges that the importer continues to meet the requirements of ISA–PS.

Companies selected for the pilot program will be expected to follow a set of best practices compiled by the government. Through domestic site visits, CBP and the CPSC will verify that companies have adequate procedures and processes in place to ensure product safety throughout the supply chain.

As an incentive, the CPSC will offer increased benefits to companies that join the program. Some of these benefits include:
· Assigning a product-specific point of contact that can assist in providing product codes of recalled products for inclusion on customs entries.
· Training on product safety compliance, internal controls and agency audit procedures.
· Allowing companies to extend ISA coverage to multiple business units.
· Fewer product safety tests on goods.
· Granting "front of the line" privileges at CPSC laboratories to ISA-PS participants when product safety testing is necessary.
· Allowing products to be destroyed instead of requesting redelivery of faulty goods to CBP.
· Automatic enrollment in CPSC's Fast-Track Product Safety Recall Program.

The pilot program will be reviewed after two years to determine whether it should become permanent.