Overview of the new five-year pilot

The U.S. Customs and Border Protection (CBP) has announced a five-year pilot that, for the first time, opens participation in the Customs-Trade Partnership Against Terrorism (CTPAT) to non-asset-based third-party logistics providers, including freight brokers and warehouse-based 3PLs.

Purpose and scope of CTPAT

CTPAT is a voluntary public-private partnership that forms part of CBP’s layered cargo enforcement strategy. The program partners with the trade community to harden international supply chains and bolster border security.

CTPAT recognizes that CBP can only achieve the highest level of cargo security through collaboration with principal supply-chain stakeholders such as importers, carriers, consolidators, licensed customs brokers and manufacturers. Since its launch in November 2001, the program has expanded to more than 11,400 certified partners across the trade community.

Federal Register notice describing the pilot

A notice in the Federal Register explains the Department of Homeland Security, acting through the Commissioner of U.S. Customs and Border Protection (CBP), “plans to conduct a pilot for Asset-Based and Non-Asset-Based Third Party Logistics Providers to participate in the CTPAT Program to determine whether allowing such entities to participate in CTPAT would enhance port security, combat terrorism, prevent supply chain security breaches, or otherwise meet the goals of CTPAT as provided for by Congress.”

Legal authority and timeline for the pilot

The pilot follows the CTPAT Pilot Program Act of 2023, which the Federal Register notice says was passed in October 2024 and addresses the prior exclusion of certain 3PL types from CTPAT. According to the notice, the pilot is slated to begin by December 1 and will run for no more than five years.

The notice also states that Congress recognized both non-asset-based and asset-based 3PLs play roles in international supply-chain safety and national security, and that the act directed DHS “to assess whether allowing both non-asset-based 3PLs and asset-based 3PLs to participate in CTPAT would enhance port security, assist in combatting terrorism, prevent supply chain breaches, or otherwise meet the goals of CTPAT.”

Industry reaction from the Transportation Intermediaries Association

Chris Burroughs, president and CEO of the Transportation Intermediaries Association (TIA), said the pilot represents years of advocacy by the association. He likened CTPAT to a TSA PreCheck–style program for cross-border freight and said TIA has long sought inclusion for its members.

Burroughs said CBP historically argued that DOT-licensed property brokers lacked sufficient control over freight security because they do not own trucks. He noted the inconsistency that three other non-asset entities—Customs brokers, indirect air carriers and non-vessel-operating common carriers—never physically touch cargo yet have been eligible to participate in CTPAT.

TIA’s case for inclusion and how brokers would contribute

TIA pressed Congress for change, arguing many freight brokers handling cross-border traffic were excluded despite meeting minimum security standards. The association said brokers that comply could help close an existing security gap by working directly with shippers, knowing commodity details and coordinating with carriers that already participate in CTPAT.

Burroughs also said exclusion created a competitive disadvantage for compliant brokers and that including them in the voluntary program makes practical sense for supply-chain security.

Next steps, requirements and expected impact

With the Federal Register notice published, companies will enter a formal vetting process. TIA and CBP have held multiple discussions about implementation, and the pilot will involve setting and applying minimum-security requirements.

Burroughs estimated there are roughly 30,000 brokerage licenses but only about 10,000 to 12,000 active brokers, with far fewer conducting substantial cross-border freight who are likely to participate. He stressed participation carries strict obligations—including reporting, on-site inspections, investigations and detailed paperwork—and is not as straightforward as obtaining a TSA PreCheck background clearance.

Despite the administrative demands, Burroughs said he does not expect the pilot to cause a large influx of resource needs and expressed hope CBP will recognize the program’s value once vetted participants demonstrate their contributions to supply-chain security.

Broader implications for supply-chain security

If the pilot demonstrates that admitting both asset-based and non-asset-based 3PLs strengthens port security and reduces vulnerabilities, it could reshape who can formally participate in CTPAT and how the program advances national security objectives.

The pilot will serve as a test of whether broadening eligibility improves cooperation across the trade community and helps prevent supply-chain security breaches while meeting the statutory goals Congress outlined.