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Centers of Excellence and Expertise in U.S Customs and Border Protection and some implications for Viet Nam Customs

U.S. Customs and Border Protection (CBP) established ten Centers of Excellence and Expertise managed from strategic locations around the country to focus CBP’s trade expertise on industry-specific issues and provide tailored support for importers.

Concept and purposes of the Centers

The model of Centers of Excellence and Expertise (CEE) was developed as a test by CBP in 2012 and become operational nationwide in 2016, marking a transition the operational trade functions that traditionally reside with port directors to the Centers of Excellence and Expertise on a industry-focused basis, aiming to facilitate trade, reduce transaction costs, increase compliance with applicable import laws, and achieve uniformity of treatment at the ports of entry for the identified industries.

The concept of the Centers arose in response to claims that CBP’s port-by-port trade processing authority sometimes resulted in similar goods entered at different ports of entry receiving disparate processing treatment causing trade disruptions, increased transaction costs, and information lapses for both CBP and the importer.

In order to overcome this shortcoming, CBP established the Centers as national offices, which have the authority to perform post-clearance trade management functions, and make decision regarding importations of merchandise by their assigned importers, including post-summary processing of entry summaries, answer questions, provide information and develop comprehensive trade facilitation strategies to address uniformity and compliance concerns. Local-based processing functions, such as collections and broker licenses, continue to be processed at the Ports of Entry by the appropriate Center or Port personnel.  However, Centers are fully responsible for post-release processes such as all summary and post-summary correction (PSC) reviews, liquidation and protests for entry summaries nationwide.  In addition, the Centers also process prior disclosures within their industry, and further information regarding the prior disclosure process.

These above-mentioned funcitions are performed regardless of the ports of entry at which the importations occur, thereby ensuring the uniformity of treatment on importations nationwide. CBP believes that providing broad decision-making authority to the Centers will better enable the Centers to achieve these goals for CBP and the trade.

Operational process and benefits

Following those above-mentioned purposes, CBP currently operates 10 Centers, strategically located at ports of entry across the United States. The 10 Centers and their respective industries are:

- Agriculture & Prepared Products, managed by the Miami Field Office, specializes in agriculture, aquaculture, animal products, vegetable products, prepared foods, beverages, alcohol, tobacco or similar industries.

- Apparel, Footwear & Textiles, managed by the San Francisco Field Office, specializes in wearing apparel, footwear, textile mill products, or similar industries.

- Automotive & Aerospace, managed by the Detroit Field Office, specializes in automotive, aerospace, or other transportation equipment and related parts industries.  

- Base Metals, managed by the Chicago Field Office, specializes in steel, steel mill products, ferrous and nonferrous metal, or similar industries.  

- Consumer Products & Mass Merchandising, managed by the Atlanta Field Office, specializes in household goods, consumer products, or similar industries and mass merchandisers of products typically sold for home use.

- Electronics, managed by the Los Angeles Field Office, specializes in information technology, integrated circuits, automated data processing equipment, and consumer electronics.  

- Industrial & Manufacturing Materials, managed by the Buffalo Field Office, specializes in plastics, polymers, rubber, leather, wood, paper, stone, glass, precious stones and precious metals, or similar industries.  

- Machinery, managed by the Laredo Field Office, specializes in tools, machine tools, production equipment, instruments, or similar industries.  

- Petroleum, Natural Gas & Minerals, managed by the Houston Field Office, specializes in petroleum, natural gas, petroleum related products, minerals, and mining industries.

Unlike the traditional mode, CEE operates account and industry based management approach, whereby each importer will be assigned to an industry-category administered by a specific Center based on the tariff classification in the HTSUS of the predominant number of goods imported. The list of HTSUS numbers that will be used by CBP for the importer’s placement in a Center is the same list of HTSUS numbers that are referenced in the definition for Centers. Factors that may cause CBP to place an importer in a Center not based on the tariff classification of the predominant number of goods imported include the importer’s associated business practices within an industry, the intended use of the predominant number of goods imported, or the high relative value of goods imported. Brokers acting as the IOR will have their entry summary processed by the Center relating to the predominant HTSUS number for the entry summary since brokers’ business models do not necessarily align within a particular industry sector.

In practice, the implementation of this model has delivered significant effectiveness and benefits for CBP. The CEE serves both as a strategic connection between the business community and CBP operations, and as a mechanism to enhance consistency in operational implementation across ports of entry. It enables the timely resolution of trade compliance issues on a nationwide scale, while also strengthening CBP’s risk management efficiency.

This model also requires a highly qualified workforce, with experts receiving in-depth, sector-specific training. As a result, it contributes to the development of a cadre of specialists with profound knowledge of particular commodities and market characteristics.

Assessment on the possibility of application CEE model in Viet Nam

The industry-focused Centers of Excellence and Expertise (CEE) model of U.S. Customs and Border Protection represents a valuable international best practice, reflecting the trend toward modernizing customs management in the context of rapidly expanding international trade and increasingly diverse and complex global supply chains.

In the context of Viet Nam Customs’ ongoing comprehensive digital transformation, aimed at building a digital customs model in line with the Government’s orientation, the U.S. CEE model offers relevant implications for adaptation to Viet Nam’s conditions.

The process of digital transformation, together with a modern customs management model and the digitization and standardization of business processes, will ensure the consistent implementation of procedures across all customs units nationwide. The integration and centralization of data under a digital customs model will also facilitate the establishment of a centralized enterprise database. These conditions provide a solid foundation for the feasible application of the CEE model in Viet Nam.

At the initial stage, Viet Nam may consider piloting this model by establishing specialized units or expert groups in sectors where the country has strong export advantages (such as textiles and garments, electronics, and agricultural products), and applying it to selected groups of enterprises, including Authorized Economic Operators (AEOs) and enterprises with large import-export turnover.

The study, selective adoption, and appropriate application of the U.S. CEE model in Viet Nam would carry significant practical implications. It would contribute to enhancing the effectiveness of state management in customs, strengthening risk management, reducing workloads at the pre-clearance and clearance stages for border checkpoints, and thereby facilitating trade activities. This, in turn, would support Viet Nam’s economic development and growth in the new phase.

References:

          1. Centers of Excellence and Expertise (CEE) Overview, https://www.cbp.gov/trade/centers-excellence-and-expertise-information

 2. SAFE Framework of Standards to Secure and Facilitate Global Trade (“SAFE Framework”

          3. CEE Directory and Operational Structure, https://www.cbp.gov

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