U.S. Customs and Border Protection is accepting comments through April 1 on a new information collection associated with its forthcoming test of an improved global business identifier. The GBI evaluative proof of concept aims to determine a single identifier solution that will uniquely discern main legal entity and ownership, specific business and global locations, and supply chain roles and functions.

Entry filers must request permission to participate in this test and must obtain and submit as part of the application three GBIs (legal entity identifier, global location number, and DUNS number) for their shippers, manufacturers, and sellers (GBIs for exporters, distributors, and packagers are optional). Automated Broker Interface filers (including brokers and self-filers) will be required to complete a GBI enrollment process, via ABI, prior to submitting the identifiers on an electronic entry (CBP Form 3461). Filers are responsible for the associated costs to obtain all three identifiers.

CBP states that by testing these identifiers it will take its first step in determining whether to amend its regulations to mandate the GBI solution as an alternative for the manufacturer/shipper identification code.

In a related move, CBP is proposing to add the three identifiers listed above for manufacturers/producers, sellers, and shippers (mandatory) and exporters, distributors, and packagers (optional) to the list of information to be collected via ACE cargo release (formerly referred to as simplified entry), which importers or customs brokers may file in lieu of CBP form 3461 (entry/immediate delivery application). Comments on this change are due no later than April 2.

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

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