Possible New Entry Requirements to be Tested

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Dec. 5, 2022
By: Pietro N. Bianchi

On December 2nd Customs announced its newest initiative to increase supply chain visibility. Customs requests that industry volunteers provide three unique identifiers in addition to manufacturer/shipper identification numbers in its pilot program, the Global Business Identifier (“GBI”). The three entity identifiers (“GBI Identifiers”) are: Data Universal Numbering System number, which identifies relationships between corporate entities; Global Location Number, which identifies the legal entity, function, physical location, and digital location of a business; and Legal Entity Identifier. Customs hopes that GBI will provide greater transparency into shipper, seller, and manufacturer data.

Business/Importers who desire to participate in this program must request permission. Customs will accept requests to participate in the GBI from December 19, 2022 until the end of the pilot program, which is currently scheduled for July 21, 2023. The permission request must state an importer’s intent to import goods on GBI’s test list (a complete list can be found in the announcement 87 FR 74157) from one or more of the GBI’s test countries of origin: (1) Australia; (2) Canada; (3) China; (4) France; (5) Italy; (6) Mexico; (7) New Zealand; (8) Singapore; (9) United Kingdom; or (10) Vietnam. The permission request must also include the GBI Identifiers of the importer’s manufacturers, shippers, and sellers for the relevant entries.

Importers are not required to obtain or submit their own GBI Identifiers. Rather, importers must submit GBI Identifiers of the manufacturers, shippers, and sellers on entries. Optionally, importers may also provide GBI Identifiers for exporters, distributors, and packagers on entries. When importers have difficulty obtaining GBI Identifiers, they should notify Customs. To determine the success of the program, Customs will evaluate whether GBI:

(1) improves foreign entity data for trade facilitation, risk management, and statistical integrity;

(2) ensures U.S. Government access to foreign entity data;

(3) institutionalizes a global, managed identification system;

(4) implements a cost-effective solution;

(5) obtains stakeholder buy-in; and

(6) facilitates legal compliance across the U.S. Government.

Customs states that participation will provide benefits to importers, such as the opportunity to feedback to CBP; more accurately identifying their supply chains; allowing the trade community to improve their import data collection processes; and enhancing data analysis. Assuming that Customs will move away from the simple Manufacturer’s Identification Number in the future, participation in this program may give companies an opportunity to help shape the replacement for the MID. At minimum, companies will help determine that does not work before Customs begins implementing a new system.

If you have questions about supply chains or increased importing requirements do not hesitate to contact an attorney at Barnes Richardson, & Colburn LLP.