CBP Withholds Support for Ultimate Consignee GIF Over Confidentiality Concerns

CBP declined to support a Great Idea Form (GIF) for ultimate consignee reports due to confidentiality concerns, according to the September Trade Support Network (TSN) report. The GIF was prepared at the request of the Grocery Manufacturers Association (GMA), which is concerned over the ability to fraudulently list GMA members a consignee. CBP said they "cannot support this GIF as it would be a clear violation of confidentiality" because the "importer’s business data is protected information which CBP cannot share with a third party," said the TSN report.

CBP released the TSN reports for July (here), August (here), and September (here).

According to the July TSN report, the GIF was prepared for the GMA because of the need to analyze all areas of risk and to take proactive actions to ensure the safety and security of imported products. GMA members, and other trade participants were especially worried with DDP (Delivery Duty Paid) shipments from a security perspective because a bad actor may be able to list a GMA /Importer company as the consignee on a DDP shipment without their knowledge, the July report said. The Account Management Committee and Broker Account Subcommittee referred the GIF to the Legal Policy Committee for review, said the September report.

Entry Committee Work

The Entry Committee met to discuss the Document Imaging System and drafting recommendations for fewer meta-data requirements, said the August report. The committee also submitted a GIF which outlines a trade need for a report to eliminate the need to run both the ESM-7008 and the AM-100 report to determine duty amounts actually paid and whether or not de minimus was applied.

Export, Multi-Modal Manifest, ITDS Joint Committee Report: Automated Export Task Group

The Automated Export Task Group completed the re-validation of the automated export processing user requirements, said the September report. User Requirements were categorized as In-Scope, Not In-Scope, and Pending Further Review. The In-Scope user requirements were submitted to CBP for documentation and use in the functional requirement development phase. The Pending Further Review user requirements were submitted to CBP for internal legal and policy review by CBP, Census Bureau, and the participating government agencies for determination as to whether they will be in-scope or not in-scope. Updated documentation will be sent to the Automated Export Task Group during this review period, it said.