Advisory on China Customs Advanced Manifest requirements

Starting today June 1st ,2018, the General Administration of Customs of the People’s Republic of China (GACC) is changing its China Customs Advanced Manifest (CCAM) requirements for imports and exports according according to GACC Announcement No. 56. The new requirements include data that must be electronically shared with the GACC for all inbound and outbound imports and exports from China. This includes sensitive identification numbers for corporations, sole-proprietors, and individuals importing and exporting in China — including Employee Identification Number (EIN) and Social Security Number (SSN).

Implementation includes the following:

1. China Customs Advanced Manifest (CCAM) enforcement wherein Advanced Manifest must be submitted to China Customs 24 hours prior to cargo loading on vessels sailing to/from China mainland ports.
2. The manifest data must be accurate and complete for all goods under the Bill of Lading (BL).
3. Full details of the Shipper and Consignee (or Notify Party if Consignee is To Order) must be provided in the shipping instruction (SI). Due to this adjustment in policy, Enterprise codes are newly required as follows-

• Enterprise code of shipper/consignee/notify party in China

  • Unified Social Credit Code (USCC) or Organization Code (OC) is required as Enterprise codes.
  • If the shipper or consignee in China has a Unified Social Credit Code (USCC), provide the
  • USCC in the form of “USCI + USCC code”.
  • If there is no USCC, provide the organization code in the form of “OC + organization code”

• Enterprise code of shipper/consignee/notify party other than China

  • Non-China shipper/consignee/notify party’s Enterprise code is required.
  • Since different Enterprise codes are used in each country, please check and provide it.
  • Examples of Enterprise code:
    • Japan – Legal Entity Identifier (LEI)
    • USA – Employer Identification Number (EIN) or Central Index Key (CIK)
    • UK – Company Number or VAT Number

It is likely if you are an individual or sole operator shipping goods to and from China to the U.S., that GACC will require your personal SSN to satisfy the new requirement. We strongly recommend signing up for an EIN instead – and where possible incorporate to an LLC to limit any potential exposure. The process to get an EIN is easy and low-cost with the IRS.

Exactly why the Chinese Government has chosen this moment to begin collecting this sensitive data will be discussed in the coming weeks. We’ll be monitoring the situation closely on behalf of our clients and providing more analysis as the implications (and implementations) begin to play out over the coming days.