On February 12, 2024, CBP announced key updates to the ongoing Global Business Identifier Evaluative Proof of Concept (GBI EPoC). The agency extended the test from February 12, 2024, through February 23, 2027, clarified the purpose and scope of the test, and expanded the test to include more entry types and countries of origin.

GBI EPoC Background

The Automated Commercial Environment (ACE) is the system through which the U.S. Government processes trade-related import and export data. The transition away from paper-based procedures has resulted in faster, more streamlined processes for both the U.S. Government and industry. To continue this progress, CBP began working with the Border Interagency Executive Council (BIEC) and the Commercial Customs Operations Advisory Committee (COAC) starting in 2017, to discuss the continuing viability of the data element known as the manufacturer or shipper identification code (MID).

Although use of the MID has served CBP and the international trade community well in the past, it became apparent that the MID is not always a consistent or unique number. 

CBP thus engaged in regular outreach with stakeholders in the trade community with the goal of establishing a global entity identifier system. As a result of these discussions, CBP developed GBI EPoC, an interagency trade transformation project that aims to test and develop a single entity identifier solution. 

Through the GBI EPoC, CBP aims to develop a systematic, accurate, and efficient method for the U.S. Government to uniquely identify, legal business entities, their different business locations and addresses, and their various functions and supply chain roles. 

February 2024 Updates

In the February 12, 2024 Federal Register Notice, CBP announced three key updates to the GBI EPoC.

First, the test period has been extended from February 14, 2024 through February 23, 2027.

Second, CBP made changes to the evaluation criteria to clarify the purpose and scope of the test. In addition to continuing to assess how GBIs can address the unreliability of MIDs, CBP will also now explore opportunities to enhance supply chain traceability and visibility more broadly—including examining how CBP, Partner Government Agencies (PGAs), and the trade industry might leverage GBIs to comply with growing supply chain traceability requirements.

Third, CBP expanded the test to include merchandise under any subheading of the Harmonized Tariff Schedule (HTSUS) and entries of imported merchandise from any county of origin. Originally, the test was limited to merchandise in five categories (alcohol, toys, seafood, personal items, and medical devices) and merchandise with 10 countries of origin (Australia, Canada, China, France, Italy, Mexico, New Zealand, Singapore, United Kingdom, and Vietnam).

You Can Still Participate in the Test!

CBP is still accepting requests from importers of record and licensed customs brokers to participate in the test. The agency will also continue accepting comments for the duration of the test period.

To participate you must get (one of the following three) GBIs (D–U–N–S®, GLN, or LEI), or be in the process of obtaining a GBI from the manufacturers, shippers, and sellers.

CBP will get and examine:

  1. entity identifier numbers,
  2. official business titles
  3. names
  4. addresses
  5. financial data
  6. trade names
  7. payment history
  8. economic status; and
  9. executive names.

Note that after an initial six-month period (or at such earlier time as CBP deems appropriate), a test participant may be subject to discontinuance from participation in this test for any of the following repeated actions:

  • Failure to follow the terms and conditions of this test;
  • Failure to exercise due diligence in the execution of participant obligations;
  • Failure to abide by applicable laws and regulations that have not been waived; or
  • Failure to deposit duties or fees in a timely manner.

Additionally, participation in this test is not confidential. Upon receipt of a written Freedom of Information Act request, the name of a participant will be disclosed by CBP.

Want more information on participating or assistance with submitting comments? Contact Diaz Trade Law today at info@diaztradelaw.com.

Read more on the GBI EPoC here: The Beginning of the End of the MID