Background

U.S. Customs and Border Protection has make additional changes to a test of global business identifiers that could replace the manufacturer identification code and provide better information on foreign business entities, supply chain roles, and related data. In February 2024 CBP extended this test through Feb. 23, 2027; removed commodity and country of origin limitations on the entries eligible for the test; and clarified the purpose and scope of the test.

CBP has said 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 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.

GBI 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, sellers, exporters, distributors, and packagers: the 20-digit Legal Entity Identifier, the nine-digit Data Universal Numbering System number, and the 13-digit Global Location Number.

CBP has now made the following changes with respect to this test.

- the test is being renamed from the “Global Business Identifier Evaluative Proof of Concept” (and the resulting acronym “GBI EPoC”) to the “Global Business Identifier Test”, or “GBI test”

- CBP has entered into an agreement with Altana Technologies USG Inc. to serve as an identity management company and has added Altana to the list of existing IMCs, which include Dun & Bradstreet, GS1, and the Global Legal Entity Identifier Foundation

- a reference to Altana has been added to the relevant sections in the GBI test

- subsection III.B of the GBI test is being divided into two subsections, with subsection 1 providing guidance to importers of record and licensed customs brokers wishing to participate in the test and subsection 2 providing guidance to identifier and traceability companies that are interested in supporting CBP by becoming GBI test IMCs

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

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