CBP Moving to Replace MID to Improve Enforcement and Risk Assessment Efforts

U.S. Customs and Border Protection is moving ahead with an effort to replace the manufacturer identification code with a global business identifier intended to provide better information on foreign business entities, supply chain roles, and related data. A test of three potential identifiers will be conducted from Dec. 17, 2022, to July 21, 2023, and importers of record and licensed customs brokers may now submit requests to participate.

CBP states that while the MID has served the agency and the international trade community well in the past, it is not always a consistent or unique number and provides only limited identifying information. CBP has therefore developed the Global Business Identifier Evaluative Proof of Concept, an interagency project that aims to test and develop a single entity identifier solution that will improve the ability of CBP and partner government agencies to pinpoint high-risk shipments and facilitate legitimate trade; create a common language between government and industry; and improve data quality and efficiency for identification, enforcement, and risk assessment.

Test participants will provide the following entity identifiers (in addition to other required entry data, which may include the MID) for manufacturers, shippers, and sellers: the 20-digit Legal Entity Identifier, the nine-digit Data Universal Numbering System number, and the 13-digit Global Location Number. Participants may also (but do not have to) provide these GBIs for exporters, distributors, and packagers.

The test will be limited to type 01 and 11 entries of alcohol, toys, seafood, personal items, and medical devices in specified subheadings of HTSUS Chapters 3, 16, 22, 30, 33, 63, 90, and 95. CBP is also limiting the test to entries of imported goods with the following countries of origin: Australia, Canada, China, France, Italy, Mexico, New Zealand, Singapore, the United Kingdom, and Vietnam. Additional products and countries may be added to the test later.

CBP will evaluate whether these three GBIs, singly or together, can ensure that CBP and PGAs receive standardized trade data in a universally compatible trade language. CBP states that the aim is to develop a systematic, accurate, and efficient method for the trade to report, and federal agencies to uniquely identify, legal business entities, their different business locations and addresses, and their various functions and supply chain roles. CBP believes it can further facilitate and secure trade by obtaining deeper insight into the legal structure of “who is who” across the spectrum of trade entities and by understanding more clearly ownership, affiliation, and parent-subsidiary relationships.

For more information on the GBI test, please contact attorney Lenny Feldman at (305) 894-1011 or via email.