Background

U.S. Customs and Border Protection is planning to launch in spring 2022 a test of an improved method of identifying foreign business entities, supply chain roles, authorized economic operator program status, and foreign addresses.

In a recent presentation to attendees at its Virtual Trade Week, CBP said that in fiscal year 2020 there were more than 365,000 active importers of record and 16,500 customs brokers. While these filers must submit a manufacturer/shipper identification number for all imports, CBP states that the MID lacks the data quality, richness, and uniqueness necessary to provide it with accurate supply chain insights. This problem is magnified by the sheer number of shipments CBP processes, which in FY 2020 included 28.5 million cargo containers, 32.8 million import entries, and 148 million de minimis value shipments by air and 94 million by truck.

In response, CBP and other agencies are working to develop a single global business identifier that will improve their ability to identify high-risk shipments and facilitate legitimate trade, create a “common language” between the government and the trade community, and improve data quality and efficiency for identification, enforcement, and risk assessments.

CBP states that the following entity identifiers are currently being considered for the GBI.

- the 20-digit Legal Entity Identifier

- the nine-digit Data Universal Numbering System number

- the 13-digit Global Location Number

CBP states that early next year an interagency working group is planning to launch an evaluative proof of concept that will test the proposed solution and identify the optimal combination of these three entity identifiers that uniquely identifies main legal entity and ownership, specific business and global locations, and supply chain roles and functions. Those that voluntarily participate in the test will have to submit all three identifiers for the manufacturer/producer, seller, and shipper, regardless of whether or not they are the same entity, via the Automated Broker Interface. Submission of identifiers for the distributor, exporter, and packager will be optional. CBP states that the MID will still be required and accepted in parallel at import until a full evaluation of the test is conducted.
The test will cover ten countries of origin (Australia, Canada, New Zealand, United Kingdom, China, France, Mexico, Vietnam, Italy, and Singapore) and six product categories (alcohol, medical devices, personal items, seafood, toys, and U.S. goods returned). Trade members that conduct business in one of these countries and import a product in one of these categories will be eligible to participate. A Federal Register notice announcing the test is expected sometime this coming winter.

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

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