CBP to Begin Testing Global Business Identifier Program

U.S. Customs and Border Protection (CBP) will begin testing a new “Global Business Identifier Evaluative Proof of Concept” this month. In a notice published last week, CBP is seeking volunteer importers to participate in the pilot, which will run from December 19, 2022 through July 21, 2023.

CBP says the test participants “must arrange to obtain the required D–U–N–S®, GLN, and LEI entity identifiers (the GBIs) from the manufacturers, shippers, and sellers of merchandise that are intended to be covered by future entries that will meet the conditions of the test (commodity + country of origin).” CBP says it will be optional for participants “to obtain the GBIs for exporters, distributors, and packagers.” See CBP’s notice on the GBI Test.

Senators Object to IPEF Process

A bipartisan group of Senators, including the leadership of Senate Finance Committee, is objecting to the way the Biden Administration is handling the proposed Indo-Pacific Economic Framework for Prosperity (IPEF). In a letter to the White House last week, the Senators said the Constitution requires that Congress must be involved in the approval and implementation of a “significant binding trade agreement” under Article I, Section 8.

The Senators are asking the Biden Administration to provide “robust consultation with Congress” on IPEF; “heightened transparency” with the public; and, work with Congress to arrive at “a common understanding” of the IPEF’s approval and implementation process. Read the Senators’ letter.

AAEI Makes Recommendations to CBP on Importing Issues

AAEI’s Aerospace and Defense Committee sent two letters to U.S. Customs and Border Protection (CBP) recommending actions that will improve the importing process.

One recommendation would allow importers to provide CBP their HTS Chapter 9808 duty-free certificates “upon CBP’s request,” instead of including them for each importer filing. As AAEI points out, the Defense Contract Management Agency’s (DCMA’s) 9808 program already has several layers of validation, including copies of the duty-free certificates in its e-tools system.

Separately, AAEI’s Aerospace and Defense Committee sent CBP a letter asking for clarification on the use of machine learning and artificial intelligence (AI) in HTS classification and is recommending that CBP modify its reasonable care standard to accommodate automation. The letter says that in “Harmonized Schedule (HS) assignment… these technologies help reduce complexities, increase accuracy, and better allocate Subject Matter Expert (SME) labor to the greatest area of need. Read AAEI’s Aerospace and Defense Committee’s letter on Reasonable Care here and letter on 9808 Declaration here.

COAC Holds Public Meeting, CBP Provides Forced Labor Update

The Commercial Customs Operations Advisory Committee (COAC) held a public meeting today in Washington, DC, highlighting big trade issues, including U.S. Customs and Border Protection’s (CBP’s) Global Business Identifier pilot program, Forced Labor enforcement and 21st Century Customs Framework (21CCF).

On Forced Labor, CBP says it currently has 55 shipments that were issued Withhold Release Orders (WROs). Acting CBP Commissioner Troy Miller says the “vast majority of companies are working to comply” with Forced Labor laws. The agency is working to add a web-based dashboard on Forced Labor that will be updated quarterly and will include chat box for relevant information. CBP also says there will be a technical expo scheduled this spring for tech companies to show their Forced Labor compliance tools.

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