Executive Summary
U.S. Customs and Border Protection has issued an Advance Notice of Proposed Rulemaking (ANPRM), “Heightened Import Disclosures for Supply Chain Visibility,” seeking public comment through December 1, 2026 on a sweeping set of possible changes designed to give CBP far greater visibility into the supply chains behind imported goods. The ANPRM—published in the Federal Register on September 2, 2026, under docket number USCBP-2026-1058—supports the implementation of Executive Order 14411, “Strengthening Customs Enforcement,” and represents one of many actions CBP is expected to pursue under that order. CBP is weighing new requirements covering foreign export documentation, a redefined or replaced manufacturer identification code, earlier entry filing deadlines, advanced supply chain tracing technology, and enhanced traceability obligations for CTPAT participants. This analysis examines each proposal, the specific questions CBP is asking, and what importers and logistics providers should do to prepare a response before the comment window closes.

CBP Considering Heightened Import Disclosure Requirements: What Importers Should Know

(CBP拟议加强进口信息披露要求：进口商应了解的内容)

1 · The Proposal: Why CBP Is Doing This Now

An ANPRM, Not Yet a Rule

CBP is accepting comments through December 1, 2026, on possible changes to its regulations designed to give the agency greater visibility into the supply chains of imported goods. It is worth being precise about what this is and is not: an Advance Notice of Proposed Rulemaking is a preliminary, exploratory step. CBP has not yet proposed specific regulatory text—it is asking the trade community a detailed set of questions to help shape whatever proposed rule eventually follows. This is one of many actions CBP is expected to pursue to implement the June 2026 executive order directing a broad tightening of U.S. customs enforcement measures.

CBP’s Stated Rationale

CBP Commissioner Rodney S. Scott framed the initiative directly: “Border security is national security. Knowing what is coming into this country is vital to our national security.” CBP has stated that by strengthening visibility into the supply chains behind goods entering the United States, the agency can better identify high-risk shipments, stop illicit trade, and help ensure that American businesses are not undercut by those who evade customs laws.

More specifically, CBP is considering three broad categories of change: (1) new requirements enhancing visibility into the parties involved in the importation of goods, (2) integrating innovative technical solutions for tracing the supply chains of those goods, and (3) collecting documentation that foreign exporters are already required to submit to their own foreign customs authorities. The stated intent is to more effectively detect and interdict illicit importations, especially those illegally transshipped to evade compliance with U.S. customs and trade laws.

The Practical Stakes for Importers

For importers, these changes could mean expanded recordkeeping obligations, new data collection and validation requirements, greater scrutiny of country-of-origin claims, more responsibility for obtaining information from foreign suppliers, and increased use of digital traceability tools and identifiers. Given the ANPRM’s broad framing, CBP has also asked for input on implementation questions that will shape how disruptive any eventual rule proves to be—including whether requirements should be phased in by entry type, commodity, country, or mode of transportation; whether different timelines should apply to small entities, foreign importers, CTPAT participants, or high-volume filers; whether any proposals are suited to voluntary test programs first; what implementation periods affected parties would need to comply; the anticipated effects on compliance with existing legal and regulatory requirements; and the potential costs and benefits involved.

2 · Foreign Export Documentation: A New Cross-Check

What CBP Is Considering

CBP is considering requiring importers of record—or possibly other entities—to submit foreign export documentation such as export declarations, commercial invoices, packing lists, certificates of origin, export licenses and permits, and bills of lading and other transport documents. CBP’s intent is to compare this information against U.S. import filings to detect undervaluation, misclassification, transshipment, dual invoicing, and other customs violations.

The Scope of CBP’s Questions

CBP poses nearly two dozen questions regarding this potential requirement, touching on how broad the requirement should be, whether documentation should be required as part of the entry or entry summary filing, the practical challenges importers would face in obtaining such documentation from foreign counterparties, and what tools importers should use to identify discrepancies between the foreign export documentation and the corresponding U.S. entry or entry summary.

A Heightened Track for High-Risk Products

CBP is also considering a framework under which certain products or sectors deemed to pose a high or grave national security risk could face heightened documentation requirements as a condition of entry—a targeted approach that would layer additional scrutiny on top of the baseline requirements under consideration.

Why This Matters: for many importers, foreign export documentation is generated and held by suppliers or intermediaries rather than the importer itself. A requirement to submit this documentation—particularly if tied to entry timing—would shift meaningful new coordination burden onto import compliance teams, who would need reliable, timely cooperation from foreign counterparties that may have little independent incentive to prioritize U.S. customs deadlines.

3 · Supply Chain Party Disclosure: Rethinking the MID

The Problem CBP Sees

CBP believes the current manufacturer identification code (MID) provides incomplete and inconsistent information. As a result, the agency is considering redefining or replacing the MID, and/or requiring more detailed identification of parties involved in the supply chain, including manufacturers, producers, shippers, exporters, and sellers. Open questions include when identifiers should be provided to CBP, which parties should be identified, and what consequences importers should face for failing to provide accurate identifiers.

The Global Business Identifier Alternative

Separately, CBP is already conducting a test of global business identifiers (GBIs) that could ultimately replace the MID and provide more precise information about other entities in the supply chain. This test permits the transmission of four distinct identifier types: DUNS numbers, legal entity identifiers (LEIs), global location numbers (GLNs), and Altana IDs.

CBP is inviting input on a number of related issues, including the practical challenges businesses face in obtaining these identifiers and importers face in disclosing them, the feasibility of requiring GBIs at entry, and whether product-level identifiers for each individual shipment should eventually replace entity-level identifiers altogether.

Cross-Reference: this GBI expansion effort connects directly to functionality already on CBP’s ACE development roadmap. As we noted in our earlier analysis of ACE system updates, expanding GBI proof-of-concept enrollment—including support for submitting multiple identifier types per party—remains listed as “on hold” in CBP’s most recent ACE functionality schedule, suggesting the ANPRM’s outcome could directly influence when and how that ACE functionality ultimately moves forward.

4 · Entry Timing: Filing Sooner

CBP poses several questions about the timing of filing entries, including whether requiring entry to be filed sooner would benefit the agency in reviewing supply chain documentation and determining the admissibility of goods more quickly; how an earlier filing deadline would affect data availability, data accuracy, and broker and carrier operations; and what costs would result from moving up the filing deadline.

Why This Matters: an earlier entry filing requirement would compress the window importers and brokers currently have to assemble complete and accurate documentation. Depending on how CBP ultimately structures this requirement, it could meaningfully affect operational workflows for brokers managing high shipment volumes on tight timelines.

5 · Supply Chain Tracing: Technology-Enabled Verification

CBP is considering ways to incorporate advanced supply chain tracing tools to improve detection of illegal transshipment before goods are released. Such tools may include AI-enabled supply chain mapping, product-level traceability systems, raw material origin verification technologies, digital credentials and tamper-resistant records, and integration with ACE and other government trade systems.

This represents a notable shift from a documentation-based verification model toward one incorporating real-time, technology-enabled tracing—potentially changing how importers demonstrate supply chain integrity going forward, from a static paper trail toward a more continuously verifiable digital record.

6 · CTPAT: Higher Expectations for Trusted Traders

For participants in the Customs Trade Partnership Against Terrorism, CBP is considering a distinct set of enhancements:

• Requiring enhanced supply chain traceability technologies as a condition of continued CTPAT participation
• Requiring CBP visibility into those systems, rather than relying solely on periodic validation reviews
• Adding cybersecurity and data integrity requirements to the existing security criteria
• Restricting the use of certain foreign-controlled logistics platforms viewed as posing security risks
• Providing additional benefits to companies that voluntarily share supply chain visibility data with CBP

Why This Matters: these proposals arrive at a moment when CTPAT validation is already taking on considerably greater significance for customs brokers under Executive Order 14411’s foreign importer requirements, as we examined in our earlier analysis of the CTPAT opportunity-and-liability dynamic for brokers. If CBP moves forward with heightened traceability and data-sharing expectations specifically for CTPAT participants, the compliance bar for maintaining—not just obtaining—CTPAT status could rise substantially, even as validation itself becomes more commercially valuable.

7 · What Importers and Logistics Providers Should Do Now

1. Review the Full ANPRM Text

Given the breadth and specificity of CBP’s questions—nearly two dozen on foreign export documentation alone—importers with meaningful trade compliance exposure should review the full ANPRM rather than relying solely on summaries, since the specific questions CBP asks often signal where the agency’s thinking is headed.

2. Assess Documentation Feasibility Now

For each major supplier relationship, assess realistically whether foreign export documentation (export declarations, commercial invoices, packing lists, certificates of origin, export licenses, bills of lading) is currently obtainable in a timely, reliable manner. Where gaps exist, consider whether supplier agreements or onboarding processes should be adjusted now, well ahead of any eventual rule.

3. Evaluate Global Business Identifier Readiness

Organizations that have not yet obtained a DUNS number, legal entity identifier, global location number, or Altana ID for relevant supply chain parties should consider doing so proactively, given CBP’s stated direction toward GBI-based identification as a likely MID successor.

4. Consider Submitting Comments

Given the detailed nature of CBP’s questions—particularly around implementation timelines, phase-in approaches, and costs—affected importers, brokers, and industry associations have a genuine opportunity to shape the eventual proposed rule by submitting comments before December 1, 2026. Comments can be submitted through the Federal eRulemaking Portal at www.regulations.gov, referencing docket number USCBP-2026-1058.

5. Map Supply Chain Party Documentation

Begin cataloguing the manufacturers, producers, shippers, exporters, and sellers involved in each significant supply chain, along with the identifiers currently associated with each. This groundwork will be valuable regardless of which specific identifier framework CBP ultimately adopts.

6. CTPAT Participants: Assess Traceability Technology Gaps

Current CTPAT members should evaluate their existing supply chain traceability capabilities against the enhancements CBP is contemplating, including cybersecurity and data integrity standards, to identify gaps before they become validation requirements.

7. Monitor for Related CBP Actions

This ANPRM is explicitly framed as one of several actions CBP is pursuing under Executive Order 14411. Importers should continue monitoring CBP’s Strengthening Customs Enforcement resources for related rulemakings, guidance, and enforcement actions that may develop in parallel.

8 · Conclusion: An Early but Significant Signal

Not Yet a Rule, but a Clear Direction

This ANPRM does not itself impose any new requirement. But the breadth of what CBP is contemplating—foreign export documentation submission, a redefined manufacturer identifier framework, earlier entry filing, AI-enabled supply chain tracing, and heightened CTPAT traceability standards—signals a clear direction of travel toward substantially greater supply chain transparency obligations for U.S. importers.

The Strategic Takeaway

Organizations that begin assessing their documentation practices, supplier relationships, and identifier readiness now will be considerably better positioned than those who wait for a final rule to force the issue. Given CBP’s demonstrated pattern of moving from advance notice to proposed rule to implementation in a matter of months on related initiatives, the window for proactive preparation—and for shaping the eventual rule through comments—may be shorter than the December 1 deadline alone suggests.

If your organization would benefit from an assessment of your current supply chain documentation and identifier readiness, or would like assistance preparing comments on the ANPRM, our trade compliance team is available to help.

This analysis reflects the CBP Advance Notice of Proposed Rulemaking, “Heightened Import Disclosures for Supply Chain Visibility,” published in the Federal Register on September 2, 2026, under docket number USCBP-2026-1058, with comments due on or before December 1, 2026. This ANPRM implements Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026. Specific regulatory requirements remain subject to CBP’s review of public comments and any subsequent proposed rule. Importers and logistics providers should consult with trade counsel and compliance professionals for guidance tailored to their specific circumstances.