U.S. Customs and Border Protection has indicated that it intends to 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 now states that it anticipates making the following programming changes with respect to this test.
- allowing the trade to submit one or more of the unique GBIs for a supply chain entity instead of requiring all three
- enabling trade participants to modify or change a previous enrollment, including updating or adding additional GBI numbers (which may include a variety of global identifier types), which would enable GBI numbers to be provided voluntarily when they are known and encourage participants to obtain other GBI numbers and keep supply chain information current
- adding intermediaries and sources to the available GBI supply chain entity party types
- adding optional free text fields for all parties that will allow filers to voluntarily input additional descriptions and information about the specific party type or the underlying entity
- adding new voluntary GBI identifiers, beginning with the Altana ID maintained by Altana Technologies USG Inc., which “offers comprehensive insights across a product's supply chain, thereby enhancing traceability for CBP which may translate to facilitation benefits and reduced industry costs” (other identity management companies may also be added as the test continues)
For more information on the GBI test, please contact attorney Lenny Feldman at (305) 894-1011 or via email.
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