BIEC Examining Manufacturer ID Alternatives, Will Next Focus on Detailed Product IDs, CBP Official Says
ATLANTA -- CBP is looking at options to create a “foreign entity ID” to replace the manufacturer ID it currently requires on entry documentation, said Jeff Nii, director of CBP’s interagency collaboration division, at the East Coast Trade Symposium on Dec. 6. Alongside its counterparts on the Border Interagency Executive Council (BIEC), the agency is looking into several options, including working with a non-profit standards organizations and creating the IDs on its own, prioritizing low cost in the hopes that the entity ID system garners worldwide adoption. The BIEC, which is currently finalizing its own operating procedures, will also soon begin consideration of product sub-identifiers that would provide more detail than currently allowed by the Harmonized Tariff Schedule, Nii said.
Work on the MID replacement came out of complaints from CBP’s partner government agencies (PGAs) on the BIEC that the data element didn’t suit their needs, as well as a realization within CBP that MID didn’t fulfill their needs either, Nii said. The lack of standardization associated with the MID means hundreds of MIDs can map to a single entity, requiring hundreds of lines of code to perform “entity resolution” to verify the foreign manufacturer and make sure the importer isn’t masking the manufacturer’s true identity.
The Treasury Department got wind of the effort, referring CBP to the Global Legal Entity Identifier Foundation (GLEIF), which had partnered with Treasury to create identifiers used by banks to perform stress testing after the financial crisis. The Europe-based GLEIF was receptive to CBP’s initial overtures, though IDs issued by the group don’t include personal identifiers like who owns a company, possibly due to EU privacy laws. CBP is also considering working with GS1, another non-profit standards organization that currently provides the Global Locator Number (GLN), which companies are starting to use for supply chain traceability purposes, Nii said.
One potential solution no longer being considered is Dun & Bradstreet’s DUNS number, Nii said. Though it was in the mix early on, CBP found the DUNS number is “extremely expensive,” running counter to the agency’s goal to have something low-cost for easy adoption by other customs administrations. Marianne Rowden, president and CEO of the American Association of Exporters and Importers, urged Nii not to adopt the GS1 identifier for the same reason. Pharmaceutical companies that used GS1 to satisfy new requirements in a World Customs Organization treaty found the license costs each company $50,000, which may work in that industry but not others, Rowden said.
Next, the BIEC will set its sights on the product subdescriptor, Nii said. The current 10-digit subheading level of the Harmonized Tariff Schedule doesn’t meet the needs of a lot of PGAs, notably the Fish and Wildlife Service, which trade groups have criticized for its extensive tariff flagging (see 1611210004), and the National Marine Fisheries Service, which relies on species-level data to identify seafood. The broad scope of HTS numbers “tends to be inefficient,” but if it can be linked to a product subdescriptor ID number, “maybe we can narrow the requirements down,” Nii said. The process will be a “huge effort that we’re going to kick off in January,” he said.
Senior leadership at the departments that oversee the BIEC agencies is voting “as we speak” on final procedures for the committee to prioritize new ACE development, Nii said. The plan is for agencies to make presentations proposing new capabilities -- Nii called it “BIEC idol” – after which members of the BIEC evaluate each on a scale of 1-5, using handheld clickers, for criteria including whether it streamlines trade, whether it saves money for the trade community and the government, and whether it is required to meet the requirements of executive orders or legislative mandates, he said. “We can only develop so many number one priorities,” Nii said.