Executive Summary
Twice each year, the Department of Homeland Security and the Department of the Treasury publish a regulatory agenda outlining the customs rules U.S. Customs and Border Protection is developing, revising, or has quietly dropped. The current agenda points to a wave of modernization efforts arriving over the next year: mandatory electronic bond filing, further rulemaking to cement the suspension of the Section 321 de minimis exemption and the new low-value mail entry process, advance electronic export manifest requirements for rail and vessel cargo, and a broader overhaul of vessel entry and clearance procedures. Other long-standing proposals—covering broker verification of importer identity, enhanced air cargo security data, and electronic duty refunds—remain in development on a longer timeline. This analysis walks through what is coming, what has quietly disappeared from CBP’s agenda, and what importers, brokers, and freight forwarders should be doing now to prepare.

CBP’s Regulatory Pipeline: What’s Coming Next in Customs Rulemaking

(CBP监管议程解读：进口商与报关行需要关注的新规)

1 · What the Regulatory Agenda Actually Tells You

Twice a year, federal agencies are required to publish a Unified Agenda of Regulatory and Deregulatory Actions, listing the rules they plan to issue, revise, or withdraw. CBP’s entries appear under both DHS and Treasury, since customs revenue functions sit at the intersection of border security and fiscal policy. For importers, brokers, and freight forwarders, this agenda functions less like an official announcement and more like a forecast: it signals CBP’s regulatory priorities before formal rule text is published, giving the trade community a window to prepare operationally and, where a comment period is available, to weigh in before a rule is finalized.

Why This Matters for Planning: unlike a final rule, which carries a hard compliance date, an agenda entry is a statement of intent. Timeframes shift, some proposals stall in long-term status for years, and others disappear from the agenda entirely without public explanation. Reading the agenda well means distinguishing between rules that are actively moving—often because a notice of proposed rulemaking has already been published in the Federal Register—and rules that remain conceptual. The distinction matters because it tells a company whether to begin operational preparation now or simply keep the item on a watch list.

2 · Short-Term Actions: Rules Expected Within the Year

Mandatory Electronic Bond Transmission

CBP has proposed to eliminate the paper-based bond application and approval process, requiring that most customs bonds, bond amendments, and terminations be transmitted electronically—either through a dedicated electronic data interchange system or, in specified circumstances, by email to CBP’s Revenue Division. Sureties would generally be responsible for transmitting bonds they secure, while bonds secured by cash in lieu of surety would be transmitted by the principal.

Why This Matters Operationally: the current paper-based bond process is slow relative to the pace of modern cargo release, and CBP has framed this change as a way to speed processing, extend bond transmission capability beyond normal business hours, and improve audit traceability. For importers and brokers, this means the days of a mailed or hand-delivered bond application are numbered. Companies that still rely on paper bond processes—or on a surety relationship that has not modernized its own submission capability—should begin confirming that their surety can transmit electronically before this becomes mandatory rather than optional. A final rule date has not yet been set, but the proposed rule has already been published and its comment period has closed, which typically signals that a final rule is not far behind.

Formalizing the De Minimis Suspension and Low-Value Mail Entry Process

CBP is advancing rulemaking to formally implement the indefinite suspension of the Section 321 de minimis exemption, modify electronic filing requirements for informal entries of goods valued at $2,500 or less, and establish a new electronic informal entry type specifically for international mail shipments. This tracks closely with the interim final rules CBP has already issued suspending duty-free treatment for low-value shipments across every entry mode and creating an interim spreadsheet-based process for low-value mail entries, discussed in detail in our previous analysis of CBP’s low-value import entry procedures.

Why This Matters Operationally: this rulemaking represents CBP’s effort to move from interim, stopgap measures toward a more permanent regulatory framework—and, notably, toward electronic filing for informal mail entries rather than the manual spreadsheet submission process currently in place. Importers and brokers who have already adjusted operations to the interim spreadsheet-based process should not treat that adjustment as final. The direction of travel is toward full electronic integration, and companies that build lasting infrastructure now should design it with that eventual electronic filing environment in mind rather than around the current manual workaround.

Advance Export Manifest Data for Rail Cargo

CBP intends to finalize a rule requiring the advance submission of export manifest data through the Automated Commercial Environment for cargo transported by rail—mirroring similar advance data requirements already in place or under development for air and vessel cargo. The underlying proposed rule was published in early 2025, meaning this rulemaking has had an extended comment and review period before reaching the final rule stage.

Why This Matters Operationally: advance export manifest requirements shift compliance obligations earlier in the shipping process, requiring exporters, carriers, and their authorized agents to ensure export data is complete and accurate well before a train departs the United States rather than after the fact. Companies moving freight by rail across the northern or southern border should confirm that their systems can generate and transmit the required data elements within CBP’s specified timeframes, since this final rule is expected to convert what has been a voluntary ACE test program into a mandatory requirement.

Modernizing Vessel Entry, Clearance, and Manifest Procedures

CBP has also signaled a proposed rule to require electronic transmission of certain vessel entry and clearance data, allow electronic transmission of vessel arrival data and related requests, and streamline the broader vessel manifest, entry, and coastwise procedures to reflect how vessels actually operate today. This would be the first time this particular rulemaking has been published.

Why This Matters Operationally: ocean carriers and their agents should expect this proposal to formalize electronic processes that, in many cases, already exist informally or through pilot programs—but formalization typically comes with firmer deadlines and stricter data requirements than voluntary participation. Companies with significant vessel cargo exposure should watch for the proposed rule’s publication and consider submitting comments identifying operational concerns, since this is a first-time rulemaking where CBP’s initial proposal is likely to shape the final framework significantly.

3 · Long-Term Actions: Still in Development

Several proposals remain in long-term status, meaning CBP does not expect regulatory action within the next year. That does not mean these rules are inactive—it means the trade community has more runway before compliance obligations arrive, but should still track them given their potential operational significance.

Customs Broker Verification of Importer Identity

A long-pending proposed rule would require customs brokers to verify the identity of the importers and non-resident importers they represent, with the underlying proposal dating back to 2019. This rulemaking addresses a persistent CBP concern about identity fraud and the use of shell entities to evade duties, particularly antidumping and countervailing duty obligations.

Why This Matters Operationally: brokers should anticipate that whenever this rule does move forward, it will likely require more rigorous documentation and verification procedures for onboarding new importer clients, especially non-resident importers. Given how long this proposal has remained pending, it is a useful reminder that “long-term” agenda items can still surface with limited notice once an administration prioritizes them.

Enhanced Air Cargo Security Data

CBP has already taken interim action requiring the transmission of additional data elements under the Air Cargo Advance Screening program, with further regulatory action still to be determined. This program strengthens pre-departure risk assessment for air cargo bound for the United States.

Why This Matters Operationally: air cargo carriers, forwarders, and other eligible ACAS filers should treat the interim rule already in effect as the operative compliance standard today, while watching for whatever follow-on action CBP eventually takes—since interim final rules of this kind are frequently adjusted based on comments and real-world implementation experience.

Trade Secrets Disclosure in Counterfeit Cases

A long-pending proposal would create a formal procedure for disclosing information otherwise protected by the Trade Secrets Act to a trademark owner when goods bearing suspected counterfeit marks have been voluntarily abandoned. This proposal, too, dates back to 2019.

Why This Matters Operationally: brand owners engaged in anti-counterfeiting enforcement should understand that, absent this rule, CBP’s current information-sharing practices in abandonment cases remain governed by existing, more limited procedures. This is a lower-urgency item for most importers but a meaningful one for companies actively pursuing IP enforcement at the border.

Electronic Duty Refunds

CBP has taken interim action to require that all refunds be issued electronically, with further action still pending. This is part of a broader shift away from paper-based financial transactions in the customs process.

Why This Matters Operationally: importers who have historically received paper refund checks should confirm that CBP has current electronic payment information on file, to avoid delays once this transition is fully implemented.

4 · What Disappeared From the Agenda—and Why It’s Worth Noting

Several previously listed rulemakings no longer appear in the current agenda, including a proposal to make goods subject to certain trade or national security actions ineligible for the de minimis exemption, due process procedures for suspending or revoking entry filer privileges, amendments to encourage participation in the prior disclosure program, duty-free treatment for goods re-exported and returned within three years, modernization of forced labor enforcement procedures, non-preferential origin rules for USMCA purposes, a Privacy Act exemption for certain enforcement records, and a proposal to improve transparency in Section 337 exclusion order administration.

Why This Matters: an item disappearing from the agenda can mean several different things—the rule may have already been finalized through a different regulatory vehicle, deprioritized, withdrawn, or simply folded into a broader rulemaking not separately listed. The agenda itself does not explain which applies. Companies that were tracking any of these specific proposals for planning purposes should not assume the underlying policy question has been resolved; it is worth confirming current status directly rather than assuming the absence of a listing means the issue is closed.

5 · Practical Considerations for Importers, Brokers, and Freight Forwarders

Prioritize the E-Bond Transition

Since the electronic bond transmission proposal has already cleared its comment period, companies relying on sureties or bond processes that have not modernized should raise the issue now, rather than waiting for a final rule to force the conversation.

Treat the De Minimis Interim Process as Temporary Infrastructure

Given that CBP is actively working toward formalizing—and likely further automating—the low-value mail entry process, avoid building permanent operational infrastructure specifically around the current interim spreadsheet submission method.

Map Rail and Vessel Cargo Exposure

Companies moving significant volumes by rail or ocean vessel should identify which parties in their supply chain will bear responsibility for advance export manifest data submission, and confirm those parties have a plan for electronic transmission well ahead of any final compliance date.

Monitor, Rather Than Ignore, Long-Term Items

Long-term agenda items, particularly broker verification of importer identity, can move faster than their designation suggests once regulatory priorities shift. Brokers in particular should treat this as a standing item for periodic review rather than a closed question.

Verify Rather Than Assume on Delisted Rules

For any previously tracked rulemaking that has disappeared from the current agenda, confirm current status through direct research or professional guidance rather than assuming the issue has been resolved in either direction.

6 · Conclusion: Reading the Agenda as a Planning Tool

A Modernization Agenda, Not a Single Event

Taken together, CBP’s current regulatory agenda reflects a broader institutional push toward electronic processing across nearly every function—bonds, low-value entries, export manifests, refunds—rather than a single isolated policy change. For companies operating in U.S.–China trade lanes and other high-volume import channels, this modernization trend has real operational consequences: paper-based workarounds and manual processes that may work today are unlikely to remain viable indefinitely.

Staying Ahead of the Pipeline

The most effective response to a regulatory agenda is not to wait for each rule’s compliance deadline, but to treat the agenda as an early planning signal. Companies that begin adapting internal systems and vendor relationships toward electronic, ACE-integrated processes now will be better positioned when today’s proposed rules become tomorrow’s compliance deadlines.

If your organization needs help tracking these developments or preparing operationally for CBP’s shift toward electronic customs processing, our trade compliance team is available to help you assess where your current processes stand.

This analysis reflects CBP’s regulatory agenda as reported in the most recent semiannual Unified Agenda entries for the Departments of Homeland Security and the Treasury. Timeframes for proposed and final rules are estimates provided by the issuing agencies and are subject to change. Organizations should consult official Federal Register publications and trade compliance professionals for guidance tailored to their specific operations.