How to keep your supplier list out of public import data

Why is my import data public?

Every ocean carrier files a manifest for each vessel that arrives in the United States. The manifest lists each bill of lading: the shipper, the consignee, the notify party, the goods, the weight and the container numbers.

The press can copy the cargo declaration of an inward manifest (19 CFR 103.31(c)). CBP also makes the daily manifest data from its Automated Manifest System available to the public (19 CFR 103.31(e)). Data vendors buy the data and sell search tools. With them, a competitor can see your suppliers and your volumes.

What does a confidentiality request hide?

When CBP grants the request, it leaves the protected names and addresses out of the data that it releases (19 CFR 103.31(e)).

An exporter can also protect its own name and address on outward manifests (19 CFR 103.31(d)(2)).

How do I file the request, step by step?

The regulation prescribes no format (19 CFR 103.31(d)(1)(ii)). You do not have to show that disclosure would harm your business. These are the steps:

1. Collect every name that carriers use for your company. Look at your recent bills of lading and arrival notices. Include trade names, former names, and the name with and without "Inc." or "LLC".
2. Find your IRS employer identification number (EIN). The regulation asks for it if it is available.
3. Decide the scope: import manifests, export manifests or both. For imports, decide if you also want to protect the names of all your shippers.
4. File the certification with CBP. Use the Vessel Manifest Confidentiality online application on cbp.gov, or email it to vesselmanifestconfidentiality@cbp.dhs.gov. An employee, an attorney or an official of the company can sign it. The online application also accepts a customs broker as agent.
5. Keep the CBP acknowledgment. It shows the date that the protection starts.
6. Put the renewal date in your calendar. The grant lasts two years.

What mistakes leave my name exposed?

• A missing name variation. Protection works only when the name matches the name that the carrier or filer enters in ACE. A shipper's misspelling is not protected unless you list it.
• Accents and long names. CBP enters each name exactly as you give it. Do not use accents or other marks above letters. Each name can have 35 characters at most.
• One request for a group. Each company of a group is its own entity with its own names. List each one.
• A late renewal. When the two years end, your name goes back into the released data.
• Air, truck and rail. The regulation and the CBP program cover vessel manifests only.

Protection also does not reach data released before the start date. CBP states that it cannot guarantee that a name will never be published. It protects names as far as its computer programs allow.

How long does it last, and when do I renew?

An initial certification is valid for two years from the date that CBP receives it, and it covers all U.S. ports of entry (19 CFR 103.31(d)(1)(iv)).

Send the renewal at least 60 days before the expiry date. The CBP page says 60 to 90 days before. Check the name list again at renewal: new suppliers and new carriers can bring new spellings.

How can Allied help?

Allied is a licensed U.S. customs broker (CBP filer code 9AJ). We file the request as your agent for $150 for a two-year filing.

We compare your names with your bills of lading and entry records, add the variations that carriers use, and send you the CBP acknowledgment. We contact you 90 days before the expiry date for the renewal.