TL;DR
- On September 2, 2026, U.S. Customs and Border Protection (CBP) published an Advance Notice of Proposed Rulemaking seeking input on ways to improve visibility into supply chains for U.S. imports. It is not a final rule and does not create a new filing obligation today. [1]
- CBP is considering whether importers may need to retain or submit foreign export documentation, provide more precise information about supply-chain parties, use stronger business identifiers, and support new tracing approaches. [1]
- The proposal may make supplier-data governance, document access, origin substantiation, and broker collaboration more important to daily import operations.
- Public comments are due December 1, 2026. CBP is specifically seeking practical feedback on cost, confidentiality, data availability, implementation, and small-business impacts. [1]
A Broader View of Customs Compliance
For years, customs compliance has centered on getting the entry right: correct classification, declared value, country of origin, admissibility information, and supporting records. Those disciplines remain foundational. CBP’s newest regulatory initiative, however, signals a broader direction. The question is increasingly not only whether an importer can support a customs entry, but whether it can create a reliable, connected picture of the supply chain behind it.
CBP’s Advance Notice of Proposed Rulemaking, titled “Heightened Import Disclosures for Supply Chain Visibility,” asks the trade community how the agency could obtain better visibility into the parties involved in importation, the movement and production of goods, and foreign export documentation. CBP says the information could help it identify discrepancies and detect illicit importations, including illegal transshipment intended to evade U.S. customs and trade laws. [1]
The legal status matters. This is an early-stage request for public input, not a final regulation. CBP has not prescribed a definitive list of documents or data fields that importers must submit. [1] The proposal nevertheless signals that supply-chain intelligence is moving closer to the center of customs compliance.
What Is CBP Considering?
The ANPRM has four connected themes: foreign export documentation, clearer identification of supply-chain parties, business identifiers and traceability technology, and potential implications for CTPAT participants.
| Area under consideration | What CBP is asking about | What it could mean operationally |
|---|---|---|
| Foreign export documentation | Whether importers should submit or retain documents provided to a foreign customs or export authority. | Review supplier contracts, record access, retention processes, and reconciliation controls. |
| Supply-chain party identification | Whether the existing manufacturer/shipper identification approach should be improved or supplemented. | Maintain accurate, consistent data for manufacturers, shippers, exporters, sellers, and other relevant parties. |
| Identifiers and tracing | Whether global business identifiers and traceability tools could provide more useful visibility. | Strengthen master-data governance, data integrity, and links between products, suppliers, and shipments. |
| CTPAT | Whether enhanced tracing technologies could affect program requirements or benefits. | Consider traceability and cybersecurity as part of broader supply-chain security planning. |
Foreign export documentation
One of the most consequential questions concerns documentation that may already exist outside the United States. CBP is considering whether importers should submit or retain records that a foreign exporter was required to provide to a foreign customs authority before goods were exported to the United States. Examples include export declarations, commercial invoices, packing lists, certificates of origin, export licenses or permits, and transport documents. [1]
CBP asks whether these records should be transmitted with entry or entry-summary filings, maintained for later production, or requested selectively. It also asks how importers could reconcile legitimate differences between foreign export records and information filed with CBP, including differences in value, quantity, or classification. [1]
A difference is not automatically a violation. International transactions can involve different commercial terms, currencies, timing, valuation bases, and regulatory classifications. But an importer should be able to understand the difference, retain evidence, and explain it if asked. The potential compliance advantage is not simply possessing more documents. It is connecting documents to a shipment and resolving discrepancies before they become a customs problem.
Better identification of the parties behind a shipment
CBP also questions whether the current manufacturer or shipper identification code, known as the MID, provides enough visibility. The agency notes that the MID may offer limited information, may not consistently identify the party of interest, and may not be unique. CBP asks whether it should collect fuller information, such as legal names, physical addresses, or other identifiers for manufacturers, shippers, exporters, and sellers. [1]
A shipment can involve manufacturers, sellers, shippers, consolidators, logistics providers, and marketplaces. When their roles or data are unclear, origin verification, supplier accountability, and entry accuracy become more difficult. Supplier onboarding should therefore capture the legal entity, operating location, production role, shipping role, and a process for updating changes.
From identifiers to traceability
The ANPRM discusses Global Business Identifiers, or GBIs. CBP already has a voluntary test through which participants may transmit certain identifiers for supply-chain parties. In the notice, CBP asks whether GBIs should be collected at entry, entry summary, or both, and whether importers and brokers can feasibly obtain and disclose foreign tax and global business identifiers for relevant parties. [1]
The operational challenge is creating a connected data model: linking a product to the right supplier and facility, distinguishing the manufacturer from the exporter, and giving procurement, logistics, finance, and customs a consistent source of truth.
CBP also asks about technologies for supply-chain visibility, validation, proprietary-data protection, interoperability with the Automated Commercial Environment, and scalability. [1] This is not a technology mandate. The immediate question is whether an importer can produce trustworthy answers when needed. Depending on scale, that might involve structured supplier questionnaires and a central document repository, or more integrated data-validation and traceability tools.
What Importers Should Do Now
Because the ANPRM is not a final rule, the right response is preparation, not panic. Use the comment period to identify gaps, test current processes, and offer CBP-grounded feedback.
A short readiness review can start with four questions:
- Who owns key documents? Identify whether suppliers, brokers, carriers, or internal teams hold export declarations, invoices, packing lists, origin records, and transport documents.
- Can we test a shipment end to end? Select imports and link the entry data to the supplier, production location, commercial records, and export-side documents.
- Can we reconcile critical data? Document how the business explains differences in value, quantity, classification, and origin.
- Are data and broker roles aligned? Keep manufacturer, shipper, exporter, and seller data current, and agree on recordkeeping, validation, and escalation paths.
The public comment process is important. CBP seeks information about costs and benefits, effects on small businesses, potential impacts on critical goods, data confidentiality, and appropriate implementation timelines. Companies that can describe real-world constraints, backed by data where possible, can help shape a more workable approach. [1]
The Bigger Takeaway
CBP’s proposal reflects a broader shift in global trade: compliance is becoming inseparable from supply-chain intelligence. The businesses best positioned for this environment will not be those that collect the most documents. They will be those that connect the right information, validate it, protect it, and present it when needed.
The path forward is not predicting every future requirement. It is building a resilient model now: better supplier data, clear document responsibilities, consistent entry controls, and appropriate technology.
Note: This article is for general information only and is not legal or customs advice. Importers should assess their specific obligations with qualified customs, legal, and trade-compliance advisers.
Frequently Asked Questions
1. Is CBP’s supply-chain visibility proposal already in effect?
No. CBP published an Advance Notice of Proposed Rulemaking on September 2, 2026. The notice seeks public input and does not itself establish final, new disclosure or filing requirements. The comment period is scheduled to close on December 1, 2026. [1]
2. Will importers have to submit foreign export documents with every U.S. entry?
CBP has not made that decision. The ANPRM asks whether foreign export documentation should be submitted with entry or entry-summary filings, maintained as part of recordkeeping, requested selectively, or treated differently depending on the transaction. CBP is seeking input on the feasibility, cost, benefits, and scope of any future requirement. [1]
3. What should a company prioritize before any final rule is issued?
Confirm document ownership, maintain accurate supplier and manufacturing data, test reconciliation to supporting records, and align expectations with brokers and suppliers. These practices remain useful even if the final approach changes.
References
[2] The White House, Executive Order 14411: Strengthening Customs Enforcement (June 3, 2026)
[3] U.S. Customs and Border Protection, Strengthening Customs Enforcement
