CBP to Begin MID Replacement Pilot, Accepting Requests to Participate
CBP announced it will formally begin its long-planned pilot program to test use of global business identifiers to replace the manufacturer identification code (MID) on entry documentation. The Global Business Identifier Evaluative Proof of Concept (GBI EPoC) will begin Dec. 19, and CBP will begin accepting requests from customs brokers and importers to participate in the pilot on Dec. 2, the agency said in a notice.
Sign up for a free preview to unlock the rest of this article
Export Compliance Daily combines U.S. export control news, foreign border import regulation and policy developments into a single daily information service that reliably informs its trade professional readers about important current issues affecting their operations.
The pilot has been in the works since at least 2018 (see 1808150076). Through the pilot, broker and importer participants will provide three business identifiers -- a nine-digit DUNS number from Dun & Bradstreet, a 13 digit Global Location Number (GLN) from GS1, and a 20-digit Legal Entity Identifier (LEI) from the Global Legal Entity Identifier Foundation (GLEIF) -- from the manufacturers, shippers and sellers for all entries that will be included under the pilot.
CBP will use the pilot, which will run until July 21, 2023, unless extended, to evaluate “whether these three GBI, singly, or in concert, ensure that CBP and PGAs receive standardized trade data in a universally compatible trade language,” the agency said. “Moreover, CBP will examine whether the GBIs submitted to CBP can be easily verified, thus reducing uncertainties that may be associated with the information related to shipments of imported merchandise.”
CBP initially will allow only certain goods and countries of origin in the pilot. Entries will be limited to a set of subheadings listed in CBP’s notice under Harmonized Tariff Schedule Chapters 3, 16, 22, 30, 33, 63, 90, and 95, the agency said. The countries of origin of goods entered under the pilot are initially limited to Australia, Canada, China, France, Italy, Mexico, New Zealand, Singapore, the U.K. and Vietnam. Additional commodities and countries of origin may be added in future Federal Register notices, CBP said. Only type 01 and type 11 entries will be allowed.
“Test participants are encouraged to submit GBIs with all qualified entry filings that meet the conditions of the test so that CBP has a fulsome data set to evaluate; however, entries will not be rejected if GBIs are not submitted,” the agency said.
Test participants will need to work with their software vendors or technical teams to ensure their electronic systems are capable of transmitting the DUNS number, GLN and LEI GBIs to CBP, the agency said. “Upon selection to participate in the test, the test participants will be provided with technical information and guidance regarding the transmission of the GBIs to CBP with the CBP Form 3461 filings. The assigned ABI client representatives of the test participants will provide additional technical support, as needed,” CBP said.
Partner government agencies are “intended as core test beneficiaries,” and CBP may bring on other agencies to test use of GBIs in PGA data, it said. “CBP will announce the PGAs who will receive GBIs and GBI data pursuant to the test in a notice to be published in the Federal Register at a later date.”
“The test is open to all importers of record and licensed customs brokers provided that these parties have requested permission and are approved by CBP to participate in the test,” CBP said. Those seeking to participate in the test “should email the GBI Inbox (GBI@cbp.dhs.gov) with the subject heading ‘Request to Participate in the GBI EPoC,’” CBP said.
Requests must include the participant’s filer code and evidence they have obtained “all three GBIs (D-U-N-S®, GLN, and LEI), or are in the process of obtaining them, from the manufacturers, shippers, and sellers (and, optionally, exporters, distributors, and packagers) of merchandise that is subject to the conditions of the test (commodity + country of origin),” CBP said. Requesters must “also advise that they intend to import commodities that are subject to the test from the countries of origin that are subject to the test,” the agency said.