U.S. Customs and Border Protection has indicated that it needs more time to evaluate 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 addition, the agency is expanding the scope of its test and making certain clarifications.

Specifically, CBP is (1) extending the end date of its test of three potential GBIs from Feb. 14, 2024, to Feb. 23, 2027; (2) removing commodity and country of origin limitations on the entries eligible for the test; and (3) clarifying the purpose and scope of the test.

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 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 will 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.

When the test was initially launched it was limited to merchandise entries in five product categories (alcohol, toys, seafood, personal items, and medical devices) and ten countries of origin (Australia, Canada, China, France, Italy, Mexico, New Zealand, Singapore, the United Kingdom, and Vietnam), significantly limiting the range of entries that could be evaluated under the test. CBP is removing these limitations, thereby allowing the inclusion of merchandise entries classifiable in any HTSUS subheading and any country of origin, although the test will continue to apply exclusively to type 01 (formal) and type 11 (informal) entries.

CBP will continue to evaluate whether the three GBIs, singly or together, can ensure that CBP and PGAs receive standardized trade data in a universally compatible trade language. The agency will also examine whether the submitted GBIs can be easily verified, thus reducing uncertainties that may be associated with the information related to shipments of imported merchandise. In addition, CBP will consider whether the Global Business Identifier Evaluative Proof of Concept may ultimately prove to be a more far-reaching interagency initiative that keeps with the vision and actualized promise of the “single window,” by providing better visibility into the supply chain for CBP and PGAs and further reducing paper processing, expediting cargo release, and enhancing the traceability of supply chains.

As regards the scope and purpose of the test, CBP states that it will continue to assess the functionality and effectiveness of universal GBIs to address data gaps caused by the unreliability of the MID, in addition to exploring opportunities to enhance supply chain traceability and visibility more broadly – including examining how CBP, PGAs, and the trade industry might leverage GBIs to comply with growing supply chain traceability requirements.

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

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