CBP Looks Set for Indefinite Delay, TSN Discussions on New Chinese Postal Code Data Element

CBP officials raised the prospect of an indefinite delay to their plans to add a new data element for the Chinese postal code to cargo release filings, after customs brokers and software developers raised concerns about the new requirement during a regular bi-weekly call to discuss ACE on Oct. 27.

A CBP official on the call said the agency will change its ACE development schedule so that the recently delayed deployment date for the Uyghur Forced Labor Prevention Act “region alert” will be “TBD,” rather than the current Dec. 15. That date itself had been delayed from “November” the day before the ACE call (see 2210260061).

The official said CBP will use the delay to set up a working group through the Trade Support Network to talk through issues related to the deployment, which will add a new required data element for postal code for any entries with a country of origin of China or a manufacturer ID in China. Validations would be set up to warn the entry filer if the postal code is in Xinjiang, or if it’s not a valid Chinese postal code.

CBP officials clarified earlier in the call that the postal code will be required in two contexts: on the cargo release, as well as whenever a manufacturer ID is created or updated. One CBP official said the postal code would not be required for existing manufacturer IDs.

However, software developers on the call pointed out that existing MIDs are often used in the background by filing software to retrieve data for the name and address fields on the cargo release transmission, which is where the Chinese postal code will also go. No postal code would be retrieved from those MIDs, which for brokers can number in the thousands, and there currently exists no way for brokers to update their own MIDs, even if it were feasible.

A CBP official said the agency would not be updating existing MIDs on their end to include the postal code. “The burden that you're putting on the trade without supplying resources to validate … postal code is substantial,” replied a software developer on the call.

Another issue identified by a broker on the call is that the MID on an entry can also be the shipper for cargo that goes through a third country. The broker asked whether the new requirement for Chinese postal code means filers will be obligated to report a Chinese MID for goods with a Chinese origin, or if instead filers can continue to use the third-country MID for the actual shipper. CBP officials on the call had no ready answer.

A CBP official on the call said the TSN working group would consult with other trade participants in addition to software developers. More information about the change, including a detailed information sheet on the requirements, will be out by Nov. 3, another agency official said.