Background

U.S. Customs and Border Protection has announced that it is partnering with the Food and Drug Administration to expand the focus of the Global Business Identifier test. According to a CBP press release, the expanded test will explore how identifiers – unique numbers that capture information about legal business entities and their functions – can be leveraged to address a range of supply chain traceability needs for government and industry. Acting CBP Commissioner Troy Miller said this test “could enhance predictability, lower costs, and create the opportunity for additional facilitation benefits for compliant trade.”

On the grounds that the manufacturer identification code now in use is not always a consistent or unique number and provides only limited identifying information, CBP has been conducting for some time the GBI test, an interagency project that aims to develop a single entity identifier solution that will improve the ability of CBP and partner government agencies to pinpoint high-risk shipments and bad actors 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 provide one or more of 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.

CBP recently extended this test for three years and expanded it to all product categories and countries of origin.

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

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