U.S. Customs & Border Protection (CBP) has issued the following warning pertaining to Manufacturer’s Identification Numbers (MIDs).

If the importer cannot provide the name of the manufacturer who produced the goods when those goods are subject to quota/visa admissibility issues, the goods can be denied entry. The MID number is constructed from the name and address of the entity performing the origin-conferring operations pursuant to 19 CFR 102.21 or 19 CFR 102.22.

If CBP determines that an MID is calculated from a party that did not produce the goods, then the importer and broker may be subject to penalties. Importers can show that they exercised reasonable care by providing the broker with a statement naming the producer of the merchandise or including this information on the invoice. The importer should obtain a statement from their agent providing the name and address of the factory that produced the merchandise.

On October 20, 2005, CBP provided a grace period until November 18, 2005 not to enforce the MID requirement. This was done to give the trade community some time to establish procedures to comply with this regulation and provide accurate MID information for shipments of textile and textile products.

All importers of textile goods must ensure that their customs invoices contain accurate MID numbers or manufacturer’s names in order to avoid penalties. It should be noted that if goods are produced by a sub-contractor, we are required to report the MID for the sub-contractor.

Information on this and other recent developments can be obtained from our technical consulting group.