Importers: Clean Products Clear Quicker—Saving You Money

A CBP agriculture specialist looks over a shipment of papayas at the Otay Mesa, CA, port of entry. (CBP, Glenn Fawcett)

Clean Products Also Safeguard U.S. Agriculture and Natural Resources

By Greg Rosenthal

Importers of fruits and vegetables can reap significant rewards from an inspection program called risk-based sampling at ports of entry (RBS POE). The U.S. Department of Agriculture’s Plant Protection and Quarantine (PPQ) program—in partnership with U.S. Customs and Border Protection (CBP)—implemented the program in 2018. They have been expanding and enhancing it ever since. To prevent destructive invasive plant pests and diseases from entering our country on imported fruits and vegetables, RBS POE follows two strategies:

• Focus resources on high-pest-risk shipments through more frequent intensive inspections
• Reward compliant entities by conducting intensive inspections less frequently on low-pest-risk shipments

“This risk-based approach rewards all the links in a supply chain—like growers, consolidators, and exporters—that work together to ship clean commodities to our ports of entry,” said Darlene Judd, PPQ’s risk-based sampling National Policy Manager. “Their products enter commerce quicker because they have fewer inspections.”

When these entities ship infested or infected commodities, however, their shipments will be subject to more frequent inspections. The importer or responsible entity will face the following outcomes: costly delays, the need to re-export infested or infected material, or the destruction of the goods.

So how does RBS POE determine which shipments are high-risk and which ones are low risk? This is the basic process:

1. CBP agriculture specialists start by inspecting 100 percent of shipments associated with entities in RBS-eligible pathways like cargo vessels, aircraft, and trucks.
2. By demonstrating compliance through consecutive pest-free inspections, entities earn significantly reduced inspection frequencies, decreasing by approximately half with each level of reduction.
3. Should CBP agriculture specialists find a pest problem, however, the inspection frequency for that entity will increase incrementally, perhaps back to 100 percent, depending on how many shipments demonstrate pest problems. Then the count of pest-free shipments can restart.   

When RBS POE first started, its experts focused on the risk posed by specific commodities from specific countries.  That country/commodity combination determined the level of pest risk—and the corresponding level of inspection.

However, on the U.S. southern border, RBS POE began focusing on the compliance of individual entities within eligible commodity pathways like maritime and air cargo. Those entities could include any company or organization that handled that commodity within the supply chain before it reached our borders. The result is more specific accountability for entities and an improved opportunity to qualify for reduced inspections for those that ship clean products.

RBS POE initially tested the entity-based approach for commodities imported via maritime pathways. This year, they implemented the same approach at ports of entry along the U.S.-Mexico border, where RBS truck pathways had been limited to the country/commodity approach. The RBS POE program plans to expand the number of fruit and vegetable commodities included in the program this year. 

“The RBS process has tended to result in greater pest action rates in eligible pathways, despite looking at fewer shipments overall,” said PPQ Risk Analyst Barney Caton. “We attribute that mostly to the more intensive hypergeometric sampling used in RBS, which is a key factor in more effectively safeguarding these products.”

CBP Senior Agriculture Operations Manager Jacob Rodler explained, “RBS POE leverages available data, including the data provided via the Partner Government Agency—or PGA—message set in the Automated Commercial Environment, in an automated fashion. That allows us to assess the compliance of entities in real time. For entities to earn and maintain program benefits, completeness and consistency in filing practices are critical.”

RBS POE has this advice for importers: Ensure you know the import requirements, provide the most accurate data available about your shipments, and do so as early in your import timeline as feasible. When pests are observed in your shipments, reach out within your supply chain to ensure that risks are mitigated appropriately. Clean products will clear quicker, saving companies time and money.