21CCF & The Global Business Identifier Initiative

Global Business Identifier (CBP Logo w/ Digital Background, Numbers, GBI Features)

Trade Update • September 9, 2021

The U.S. Customs and Border Protection’s 21st Century Customs Framework (21CCF) is an agency-wide effort, “providing a structured approach to address modern trade challenges, leverage emerging opportunities, and achieve transformational long-term change.”

CBP states that its mission in this regard is to “develop legal and operational changes that embrace 21st-century processes and emerging technologies to better secure national and economic security, enhance data integrity, account for emerging actors and business practices, and better facilitate trade by reducing financial and administrative burdens and constraints in customs transactions.”

A key 21CCF objective is to improve the quality of the data received on customs transactions in order to enhance risk targeting and better facilitate legitimate trade.

Customs Challenges

Faced with various risk management challenges posed by the growing volume of import shipments – 32.8 million in 2020 – CBP has determined that the Manufacturer/Shipper Identification Number (MID), which filers are currently required to submit for all imports, “lacks the data quality, data richness, and uniqueness required” for the task.

Seeking to address “extensive pain points associated with the MID” and to better screen for high-risk shipments, the Global Business Identifier (GBI) Initiative was formed in 2019 with the aim of developing a single identifier solution that will “modernize the import process by providing the U.S. government with accurate supply chain insights.”

GBI Proposed Solution

CBP proposes to test three entity identifiers and determine the optimal combination that uniquely identifies: main legal entity and ownership; specific business and global locations; and supply chain roles and functions.

The three entity identifiers and their associated companies that will be involved in the Evaluative Proof of Concept (EPoC) are:

Data Universal Numbering System (DUNS) – Dun & Bradstreet
9-digit numeric and non-indicative identifier that identifies unique business establishments with a library of over 200 reference data elements. Over 300 million DUNS issued worldwide.

Global Location Number (GLN) – GS1
13-digit numeric identifier with varying sets of underlying reference data elements customizable to location, function, and operations. Over 2 million companies utilize GS1 company standards, and 100 million products carry GS1 barcodes.

Legal Entity Identifier (LEI) Global Legal Entity Identifier Foundation
20-digit, alphanumeric identifier with underlying reference data elements unique to a legal entity. Over 1.7 million LEIs issued worldwide.

GBI Evaluative Proof of Concept

In its current proposed design, the GBI EPoC will:

  • Operate within the U.S. Government’s Single Window platform
  • Include all three entity identifiers under consideration
  • Require volunteer trade participants to submit all three identifiers (LEI, GLN, DUNS) for the
    manufacturer/producer, seller, and shipper via the CBP Automated Broker Interface

    • Distributer, exporter, and packager will be optional

In a 2021 Virtual Trade Week Briefing on the subject, CBP says that the GBI EPoC implementation will begin at Cargo Release and Targeting and that it is expected to launch in Spring of 2022.

Industry Participation

CBP encourages companies of all sizes to take the opportunity to test and provide feedback on the GBI’s design and scope.

A Federal Register notice in this regard is expected to be published sometime this winter, after which companies may respond to it, expressing their interest to participate in the GBI EPoC. Those wishing to do so will be required to obtain the three identifiers noted above.

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