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CBP Proposes Significant Changes to Data Elements on Importer ID Form

In the October 9, 2014 Federal Register, U.S. Customs and Border Protection (CBP) published a notice to amend its Importer ID Input Record / Form 5106. CBP advises that by collecting additional information regarding importers and ultimate consignees in advance of an initial importation, it will be able to better perform its risk assessments.

Current data elements included on the CBP Form 5106 are essentially limited to the entity’s IRS number, name, type of entity, physical and mailing addresses, name and telephone number of person signing the form. The new form would be renamed Create/Update Importer Identity Form. It would include the additional data:

  • How many entries the importer plans to make annually
  • How will the ID number be used, i.e. importer of record, ultimate consignee, drawback, refunds/bills, or other
  • Specify whether an address is a residence, corporate office, warehouse, retail location, office building, business service center, post office box, or other
  • Email address and website URL
  • Brief description of the business
  • North American Industry Classification System (NAICS) 6-digit code
  • DUNS number
  • Filer code of broker or self-filer that will conduct business
  • Year the business was established
  • Names and IRS numbers of related entities
  • Primary banking institution with routing number, name and location
  • Certificate or Articles of Incorporation locator ID and reference number
  • Listing of officers that have importing and financial business knowledge of the company, having legal authority to make decisions on behalf of the company
    • Name, direct telephone number, and email address
    • Social Security number and passport information

CBP recognizes the increased information will have an impact on the time requirements to complete the form and to update their system electronically.

CBP’s website posts links to the Federal Register notice of proposed rulemaking and to the proposed form 5106. Schenker encourages all importers to carefully read this notice of proposed rulemaking and its associated form, and issue comments to CBP with any concerns. The deadline for written comments is December 8, 2014.

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