New Manifest Policy for China Imports and Exports
 
As you are undoubtedly aware, the People's Republic of China's General Administration of Customs ("GACC") has issued a new rule, effective June 1, 2018, requiring the provision of new data elements related to goods being imported and exported from China.  One of the new data elements required is the Employer Identification Number ("EIN") or Central Index Key (CIK) (or the comparable government identification for shippers or forwarders in other countries) of U.S.-based shippers and forwarders.  This information must be declared on shipping documents, which means that the EINs will be disclosed to both the carrier and GACC. 
 
The NCBFAA understands that many parties are concerned regarding potential liability for disclosing EINs to GACC and third parties.  The association believes that EINs are not, however, protected in the same manner as Social Security Numbers ("SSNs"), and are instead considered to be public information. 
 
The Association is not aware of any law prohibiting the disclosure of EINs, particularly when the EIN is required by a government authority to facilitate an underlying transaction.  Accordingly, the NCBFAA believes that forwarders can lawfully generally abide by GACC's new EIN disclosure rules.  As always, please feel free to consult counsel to assess the applicability of GACC's new disclosure rules to your situation.
 
The NCBFAA would also like to note that one option to address any concerns your company may have regarding EIN disclosure would be to revise your Terms and Conditions of Services to include a sentence by which the shipper grants consent for a forwarder to disclose EIN information as necessary to facilitate the transactions.
 
The Association understands that the new data elements required under the GACC manifest rules are as follows below.  It's possible that carriers may request that forwarders provide additional information.  The Association simply suggests that you do so.  There is a lot of confusion surrounding these new regulations, and the path of least resistance may help facilitate transactions until the industry comes to an agreement on how to address the new rules.  
 
AIR CARGO
Type of Manifest / Document
Party
Information Required*
 
 
 
 
 
 
 
Master Air Waybill (MAWB)
 
Forwarder / IAC
 
EIN, Name, Street Address, City, Country, Telephone Number
 
 
Consignee (Generally Destination Forwarder)
 
Unified Social Credit Identifier Code (USCI) or Organization Code (OC), Name, Street Address, City, Country, Contact Number
 
If consignment not under a Bank Endorsement, also include: Contact Person
 
 
Notify Party (if consignment is under a Bank Endorsement)
 
USCI/OC, Name, Street Address, City, Country, Contact Number, Contact Person
 
 
 
 
 
 
 
House Air Waybill (HAWB)
 
Shipper
 
EIN, Name, Street Address, City, Country, Telephone Number
 
 
Consignee
 
USCI/OC, Name, Street Address, City, Country, Contact Number,
 
If consignment not under a Bank Endorsement, also include: Contact Person
 
 
Notify Party (if consignment is under a Bank Endorsement)
 
USCI/OC, Name, Street Address, City, Country, Contact Number, Contact Person
 
 
 
 
 
 
 
 
Direct Air Waybill (Direct AWB)
 
Shipper
 
EIN, Name, Street Address, City, Country, Telephone Number
 
 
Consignee
 
USCI/OC, Name, Street Address, City, Country, Contact Number
 
If consignment not under a Bank Endorsement, also include: Contact Person
 
 
Notify Party (if consignment is under a Bank Endorsement)
 
USCI/OC, Name, Street Address, City, Country, Contact Number, Contact Person
 
 
OCEAN CARGO
Type of Manifest / Document
Party
Information Required*
 
 
 
 
 
 
 
Master Bill of Lading
 
Forwarder / NVOCC
 
EIN, Name, Street Address, City, Country, Telephone Number
 
 
Destination NVOCC Agent
 
Unified Social Credit Identifier Code (USCI) or Organization Code (OC), Name, Street Address, City, Country, Contact Number
 
If consignment not under a Bank Endorsement, also include: Contact Person
 
 
Notify Party (if consignment is under a Bank Endorsement)
 
USCI/OC, Name, Street Address, City, Country, Contact Number, Contact Person
 
 
 
 
 
 
 
Direct Bill of Lading
 
Shipper
 
EIN, Name, Street Address, City, Country, Telephone Number
 
 
Consignee
 
USCI/OC, Name, Street Address, City, Country, Contact Number
 
If consignment not under a Bank Endorsement, also include: Contact Person
 
 
Notify Party (if consignment is under a Bank Endorsement)
 
USCI/OC, Name, Street Address, City, Country, Contact Number, Contact Person
 
 
*For exports out of China, please note that the shipper, forwarder, and NVOCC information would require a USCI code, and the consignee and notify party information would require an EIN or a comparable foreign government identification number.

 

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