CBP Set to Test 3 Potential MID Replacements Beginning Late Spring, Agency Official Says

CBP plans to begin a pilot in late spring 2022 to test potential new global business identifiers to replace its much-maligned manufacturer/shipper identifier (MID) (see 1712080041), said James Byram, executive director of CBP’s Trade Transformation Office, July 22 at CBP’s Virtual Trade Week. In the pilot, the agency will test three potential business identifiers, with the expectation that, should the pilot succeed, it will end up requiring use of two of them as an MID replacement, Byram said.

The three identifiers are the Global Location Number or GLN, operated by GS1 and currently used by more than 2 million companies; the Data Universal Numbering System number, or DUNS number, with over 300 million issued worldwide by Dun & Bradstreet; and the Legal Entity Identifier, or LEI, of which 1.7 million have been issued worldwide by the Global Legal Entity Identifier Foundation (GLEIF).

Pilot participants will have to obtain, and submit in ACE at time of cargo release, all three identifiers for the manufacturer/producer, shipper and seller, Byram said. CBP will also be collecting optional identifiers for the distributor, exporter and packager.

Costs for the identifiers vary. According to Byram, the DUNS number is free, although requests to obtain a DUNS number within 30 days are subject to fees. The LEI is obtained from local operating units that vary in what they charge, so companies can shop around, Byram said. For example, Bloomberg Finance charges $65 for LEI registration, and $50 for renewal. GLNs must be obtained from the local GS1 office in the country where the entity is located, he said. For example, a company located in Mexico would pay a flat inscription fee of $1,840, and annual renewals cost $260. Prices for U.S.-based companies vary depending on the number of locations and items that a company needs to identify, from a $250 initial fee and a $50 renewal fee for one to two GLNs, up to a $10,500 initial fee and a $2,100 renewal fee for 100,000 or more GLNs, Byram said.

Byram said CBP is “actively” working with the entities that issue the identifiers to potentially offer all three at a reduced price to pilot participants. Once the start date for the pilot is determined, the issuers will set up a designated point of contact to answer any questions participants may have, he said.

CBP will evaluate the identifiers based on how well they meet criteria identified by the agency, including that they are globally unique, are location- and function-specific, track supply chain roles and accommodate sharing of data across agencies. Byram said he does not anticipate the pilot will lead to adoption of a single identifier, and thinks it most likely CBP will have to rely on two of the three, though CBP could adopt all three if it’s the only way to meet the criteria, or none if the pilot does not go as expected.

The pilot, which CBP is calling the GLI evaluative proof of concept (EPOC), will initially focus on six product categories -- alcohol, medical devices, personal items, seafood, toys and U.S. goods returned -- imported from 10 countries: Australia, Canada, New Zealand, the United Kingdom, China, France, Mexico, Vietnam, Italy and Singapore.

Volunteers for the pilot will have to obtain all three identifiers for themselves and submit them prior to the beginning of the pilot, and Byram said CBP will give them plenty of time to do so. Byram anticipates CBP will issue a Federal Register notice in November or December detailing program requirements and soliciting participants. A draft CBP and Trade Automated Interface Requirements document or electronic data interface changes to include the GBI was published in April, and CBP is targeting releasing the GBI capability in the ACE certification testing environment in January, and in the live ACE production environment in late spring.