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.
Specifically, CBP is (1) extending the end date of its test of three potential GBIs from July 21, 2023, to Feb. 14, 2024, (2) clarifying that it will allow participants to transmit one or more of these three identifiers (not all three) as part of the test, and (3) continuing to accept requests from importers of record and licensed customs brokers to participate in this 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 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.
The test is 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 has said 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.
Copyright © 2025 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.