Contributing Lawyers


Cyndee Todgham Cherniak

United States

Susan Kohn Ross


Andrew Hudson

Import Safety Commercial Targeting And Analysis Center

Continuing to ramp-up product safety enforcement, DHS has announced the creation of the Import Safety Commercial Targeting and Analysis Center (CTAC). Modeled after current Customs targeting centers, CTAC is supposed to "streamline and enhance federal efforts to address import safety issues."

Led by Customs and located adjacent to Customs’ Office of International Trade in Washington, D.C., CTAC will combine the resources of Customs, ICE, CPSC, FDA, and FSIS. A staff of about 30 is expected to get the effort started. Whereas Customs targeting centers (passenger and cargo) are designed to address risk management pre-entry, CTAC is said to be designed to deal with post-entry events. It seems reasonable to anticipate that the issues found at Customs targeting centers, plus those identified through the FDA’s PREDICT risk-based screening module, will be handed off to CTAC to address under domestic law. It is likely CTAC’s findings would then be fed back to Customs  and FDA for use with their targeting systems.

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