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More Information Required on Importer ID Input Record Under CBP Proposal

Thursday, October 09, 2014
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection is accepting through Dec. 8 comments on its proposal to expand the type and amount of information required on CBP Form 5106, the Importer ID Input Record (which would be renamed the Create/Update Importer Identity Form).

According to CBP, the collection of the information on this form is the basis for establishing bond coverage, release and entry of merchandise, liquidation, and the issuance of bills and refunds. Each person, business firm, government agency or other organization that intends to file an import entry must file this form with the first formal entry or request for services that will result in the issuance of a bill or a refund check upon adjustment of a cash collection. This form is also filed for the ultimate consignee for whom an entry is being made.

CBP is proposing to revise Form 5106 to gather the following additional information about companies and their officers.

- if an importer, the number of entries anticipated to be filed in a year

- how the identification number will be utilized

- program code (for future use)

- type of address (for mailing address)

- type of address (for physical location)

- phone number

- fax number

- email address

- Web site

- brief business description

- six-digit North American Industry Classification System code for this business

- DUNS number for the importer

- filer code if submitting as a broker/self-filer

- year established

- primary banking institution

- certificate or articles of incorporation (locator ID)

- certificate or articles of incorporation (reference number)

- business structure/company officers

- company position title

- name

- direct phone number

- direct email

- Social Security number

- passport number

- passport country of issuance

- passport expiration date

- passport type

- broker name

- broker telephone number

CBP believes this additional information will enhance its ability to make an informative assessment of risk prior to the initial importation and provide it with improved awareness regarding companies, their officers and their previous business practices. CBP is also requesting that the company officers whose information will be submitted on this form have importing and financial business knowledge of their companies as well as the legal authority to make decisions on their behalf.

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