111During the weeklong series of 10 informative webinars on trade regulations, we heard TOP TIPs from numerous federal agencies, including U.S. Customs & Border Protection (CBP), U.S. Food and Drug Administration (FDA)’s Division of Southeast Imports, Miami’s CBP Fines, Penalties & Forfeitures (FP&F) Office, Miami CTPAT Field Office and more! Each webinar was produced to assist importers and exporters understand compliance and hot issues. Below are summaries of two webinars – FDA Import Operations Associated with COVID-19 Efforts and CTPAT – State of the Program / Minimum Security Criteria Updates:

Session Two: Food and Drug Administration (FDA)

Topic: FDA Import Operations Associated with COVID-19 Efforts

TOP TIP: FDA’s Ruth Dixon, Program Division Director for the Division of Southeast Imports recommends importers of FDA regulated goods to SUBSCRIBE to receive email updates related to COVID-019 and check out FDA COVID-19 Response At-A-Glance Summary for the latest updates.

CSMS COVID-19 related messages:

  • CSMS #42118616: Reminder: Update on FDA’s Import Operations During the Coronavirus Disease 2019 (COVID-19) Outbreak
    • Provides operational/functional updates relevant to ongoing activities on FDA Prior Notice review, FDA entry processing, FDA sampling/examination of high risk shipments, FSVP inspections, filer assessments, and compliance activities.
    • Strongly encourages all members of the import community who deal in FDA-regulated articles to utilize the FDA Import Trade Auxiliary Communication System (ITACS) for current entry status and to receive FDA notices electronically.
  • CSMS #42253103 – FDA Recommends Use of ITACS During COVID-19 Outbreak
    • AGAIN, Strongly encourages all members of the import community who deal in FDA-regulated articles to utilize ITACS.
      • Why should you get an ITACS account?
        • Contact us to get an ITACS account! You must request an ITACS account from FDA – typically 2-3 business days for approval (or longer).
        • Benefits to the trade community include faster release of your goods because you have the ability to receive more detailed entry statuses than what is currently transmitted to filers via Customs’ Automated Broker Interface (ABI) reducing the need for phone calls inquiring about the status of entries and eliminating the need to email, mail or fax entry documentation.

FDA To Temporarily Conduct Remote Importer Inspections Under FSVP Due to COVID-19

  • On April 3, 2020 FDA announced importers would be requested to send records required under the Foreign Supplier Verification Programs for Importers of Food for Humans and Animals (FSVP) rule electronically (or through other prompt means) to the Agency as it shifts to conducting these inspections remotely during the COVID-19 public health emergency.

Warning Letters Issued to Companies Making Bogus COVID-19 Claims

To date, the FDA has issued 42 warning letters to companies making bogus COVID-19 claims, including one to a seller of fraudulent chlorine dioxide products, equivalent to industrial bleach, frequently referred to as “Miracle Mineral Solution” or “MMS”, as a treatment for COVID-19. After the seller refused to take corrective action, a federal court issued a preliminary injunction requiring the seller to immediately stop distributing its unproven and potentially dangerous product.


 Session Five: CBP – Miami CTPAT Field Office

Topic: CTPAT – State of the Program / Minimum Security Criteria Updates

 TOP TIP: The CTPAT Portal will included the Minimum Security Criteria Updates Starting June 1st. An excel spreadsheet with the new MSCs is available on the CTPAT Portal – BEAT THE RUSH – complete it now and submit on June 1st!

 Impact of COVID-19:

  • Supply Chain Security Specialists (SCSS) continue to perform their job requirements; however, do to travel restrictions Validations, PIAs, and Joint Security Assessments are currently on stand still while CTPAT determines an alternative option during COVID-19.

Updated MSCs & Enforcement | 2020 Initiatives: Building CTPAT’s Future


  • As CTPAT continues to evolve, the Program will advance key initiatives that foster partnerships, improve supply chain transparency and security, and continue to ensure CTPAT’s trusted Members receive benefits for their collaboration in these efforts.
  • New Study on new MSCs:
      • Obtain information on perceptions of CTPAT
      • Evaluate program, identify trouble areas and suggest improvements
      • Identify cost-benefit enhancements for members and the program
      • Establish new performance metrics
    • Specialized SCSSs that will focus on certified partners in the maritime environment
    • Sea carriers, US Marine Port or Terminal Operators and Foreign Based Marine Port Terminal Operators
    • Eventually conduct validations with USCG

CTPAT by the Numbers


Member Benefits:



Contact our Customs and International Law attorneys at info@diaztradelaw.com or 305-456-3830, to discuss the topics discussed at the World Trade Center Miami’s International Trade Week and how they apply to you.