CBP to Begin Testing Potential Government-wide Company Identifiers as MID Replacement in FY19
ATLANTA -- CBP is set to begin two “proofs of concept” in fiscal year 2019 to test out a single replacement for company unique identifiers used by CBP and its partner government agencies (PGAs), said Danielle Pierson, an international trade specialist at CBP’s Office of Trade Policy and Programs, at the CBP 2018 Trade Symposium on Aug. 15. The goal of the agency’s “global business identifier initiative,” currently under discussion by a Border Interagency Executive Council working group, is to develop a set of identifiers that can be used across the government as well as replace CBP’s own problematic manufacturer ID (MID), Pierson said.
The tests are initially set to evaluate use of two unique identifiers to meet the varying needs of government agencies. One is the Legal Entity Identifier (LEI), administered by the Global Legal Entity Identifier Foundation (GLEIF) and currently used mostly in the financial industry. It contains information on the identifier entity itself, including any parent or subsidiary relationships, and would likely be used to identify shippers and sellers.
The other, the Global Location Number (GLN), administered by GS1, is location based, and would be used to identify the manufacturer or producer. It includes granular data on the place of manufacturing or production -- potentially down to a location within a warehouse or a loading dock -- that is necessary for agencies like the Food and Drug Administration that need to know which facility is involved in production, or the Animal and Plant Health Inspection Service, which is interested in the field where a crop was grown.
The proof of concept will have three goals: to test the feasibility of accepting an identifier other than the MID; to provide ease of use of the identifier of the trade community, keeping the burden as light as possible; and to ensure the usefulness of the data it provides to CBP and the PGAs. As a proof of concept -- not an official pilot -- the unique identifier won’t be automatically adopted if the test is successful. The working group may look at other identifiers in future phases of the proof of concept.
In choosing which unique identifiers were suitable for testing, a major focus for CBP was cost. In the U.S., the LEI costs $75 for the first year and $50 annually every year after that. The cost for GLNs varies by country. In China, the standard price is $125 per year, rising to $183 for conglomerates and $250 if a company both imports and exports. Barebones GLN packages can be had for as little as $11 or $12, Pierson said. CBP will also in the proofs of concept evaluate the costs of each identifier to the U.S. government. DUNS numbers, already in use by the Food and Drug Administration, were not included in early testing partly due to their cost (see 1712080041).
Even if the test is successful and new identifiers are adopted, they should not be expected to replace every ID used across the agency and across the trade community, said Stuart Schmidt, manager-trade compliance at UPS. For example, a new shipper who sets up a website and wants to immediately begin selling its wares online can’t be expected to have an LEI lined up beforehand, he said. The Food and Drug Administration will have to look at its regulations to see where it has flexibility to adopt a governmentwide identifier, said Gayle Gehrman, an FDA consumer safety specialist. The initiative may not be able to get to the point where agencies are demanding an LEI or GLN for everyone, “but we can certainly provide benefits for those that do” adopt the identifiers, Schmidt said.