Executive Summary On September 2, 2026, U.S. Customs and Border Protection published an Advance Notice of Proposed Rulemaking (ANPRM) titled “Heightened Import Disclosures for Supply Chain Visibility” (Docket No. USCBP-2026-1058). The ANPRM, which implements directives from Executive Order 14411, “Strengthening Customs Enforcement,” signals CBP’s intent to fundamentally expand the information importers must collect, verify, and provide for goods entering the United States. While the notice does not impose new obligations, it poses 64 specific questions that preview a future rulemaking that could require importers to obtain and retain foreign export documentation, identify every party in the supply chain, and implement technology-enabled traceability. With comments due December 1, 2026, the trade community has a narrow window to shape what could be the most significant expansion of import disclosure requirements in decades.

CBP Proposes Sweeping New Import Disclosure Requirements – Are You Ready?

(CBP拟议全面加强进口信息披露要求)

1 · The Regulatory Context: Why This Is Happening Now

Executive Order 14411: The Driving Force

On June 3, 2026, President Trump signed Executive Order 14411, “Strengthening Customs Enforcement”. Section 1 of the order emphasized that effective customs enforcement is essential for national security, foreign policy, and the U.S. economy. The order directed the Department of Homeland Security and CBP to establish heightened import disclosure requirements and obtain additional information regarding foreign exporters, supply chains, and imported merchandise.

The ANPRM: The First Step

The September 2 ANPRM is the first formal step toward implementing those directives. CBP Commissioner Rodney S. Scott framed the initiative in stark terms: “Border security is national security. Knowing what is coming into this country is vital to our national security.”

What the ANPRM Is—And Is Not

This is not a proposed rule with regulatory text. Rather, it is an Advance Notice of Proposed Rulemaking—a preliminary step where CBP poses questions to the trade community to inform a future proposed rule. The ANPRM asks 64 specific questions about current business practices, available technology, compliance costs, implementation timelines, and potential impacts.

The Comment Deadline

Comments must be received on or before December 1, 2026. Comments can be submitted through the Federal eRulemaking Portal using docket number USCBP-2026-1058 (RIN 1685-AA47). The ANPRM proposes amendments to 19 CFR Parts 141, 142, 143, and 163. For questions regarding the identification of parties involved with imported goods and the collection of foreign export documentation, CBP has designated points of contact by email at supplychainvisibility@cbp.dhs.gov; the full text of the ANPRM, including current contact details, is available via the official Federal Register notice.

⚠️ Critical Takeaway: The ANPRM itself imposes no new requirements. But the breadth of the questions—and the potential operational consequences—make this a critical development for every company with international supply chains.

2 · The Three Pillars of the Proposed Expansion

CBP’s ANPRM identifies three broad areas where it is considering new requirements:

Pillar 1: Foreign Export Documentation

The most potentially consequential proposal would require importers to obtain, retain, and potentially submit documentation that foreign exporters are required to provide to their own customs authorities before shipping goods to the United States.

The documentation contemplated includes:

CBP’s Rationale: These records would help CBP verify entry and entry summary information and detect discrepancies—such as dual invoicing—that may point to valuation, classification, origin, or other compliance concerns.

Key Questions CBP Is Asking:

• Should records be transmitted at entry, maintained as a recordkeeping obligation, or provided only upon request?
• How long should records be retained?
• How would importers reconcile differences between values reported to foreign authorities and those declared to CBP?

Pillar 2: Expanded Identification of Supply Chain Parties

CBP is considering significantly expanding the parties and intermediaries that importers must identify or disclose.

Currently, importers provide a Manufacturer Identification Code (MID). CBP is evaluating replacing or supplementing the MID with more detailed information identifying:

• Manufacturers or producers
• Shippers
• Exporters
• Sellers
• Distributors
• Packagers
• Ultimate consignees
• Other intermediaries

Technology-Enabled Solutions: CBP is also exploring how traceability technologies, artificial intelligence, unique identifiers, and tamper-proof credentials could verify origin, production methods, and the movement of goods. The agency is currently testing four global business identifiers as potential replacements for the MID: DUNS numbers, LEI, GLN, and Altana ID. This is not a new initiative—CBP first established the voluntary GBI test in December 2022, and the ANPRM signals the agency is now considering whether to move the test toward a mandatory requirement.

The “Visibility Gap” Challenge: If CBP adopts requirements along these lines, importers may need information from companies with which they have no direct contract. A first-tier supplier may not possess, control, or readily share data concerning upstream manufacturers, component suppliers, or raw material sources.

Pillar 3: Targeted and Risk-Based Enhancements

CBP is considering whether enhanced documentation and disclosure requirements should apply to:

• Specific products (e.g., those presenting national security risks)
• Specific industries
• Specific countries
• High-risk entry types or transportation modes

The ANPRM also raises national security considerations, asking whether particular products, industries, or countries should be subject to enhanced documentation requirements.

A Notable Specific Target—Foreign-Controlled Logistics Platforms: one of the more concrete proposals in the ANPRM is a possible expansion of CTPAT’s minimum security criteria to restrict or prohibit the use of “covered logistics platforms” identified as security risks. CBP specifically names LOGINK, a Chinese state-linked logistics data platform, as an illustrative example of the kind of foreign-controlled system that could be restricted for CTPAT participants and their supply chain partners. CBP is asking commenters what administrative, operational, and software-transition costs—including capital expenditures, training, and system integration—would result from migrating away from such platforms to certified secure alternatives. Companies using or connected to Chinese-linked logistics platforms through overseas suppliers, carriers, or freight forwarders should treat this as an early signal worth monitoring closely.

3 · The 64 Questions: What CBP Wants to Know

The ANPRM poses 64 specific questions that will shape any future proposed rule. While a complete list is beyond the scope of this analysis, key question categories include:

Foreign Export Documentation:

• What foreign export documents are currently available to importers?
• What are the practical challenges of obtaining, translating, and verifying foreign records?
• Should submission be randomized or targeted?

Supply Chain Party Identification:

• What parties should be identified beyond the current MID?
• What data elements should be required for each party?
• How should CBP address confidentiality and competitive concerns?

Technology and Traceability:

• What technologies are currently available for supply chain traceability?
• What are the costs and benefits of implementing technology-enabled solutions?
• How should CBP address data security and privacy concerns?

Implementation and Transition:

• What would be a reasonable implementation timeline?
• Should there be phase-in periods or exemptions for small businesses?
• What are the anticipated costs of compliance?

4 · What This Means for Logistics Providers

Direct Impact on Operations

The proposed changes would fundamentally alter how logistics providers interact with importers and CBP:

1. New Documentary Layer The requirement to obtain and retain foreign export documentation would create a new documentary layer between the foreign export transaction and the U.S. import entry. Logistics providers may need to:

• Collect and verify foreign export documents
• Ensure consistency between foreign export data and U.S. entry data
• Maintain records for extended periods

2. Expanded Data Collection Identifying every party in the supply chain—from raw material suppliers to ultimate consignees—would require significantly more data collection at the point of shipment. Logistics providers may need to:

• Develop new data collection protocols
• Implement systems to track and report supply chain party information
• Verify the accuracy of party identification data

3. Technology Integration CBP’s interest in traceability technologies suggests that technology-enabled solutions may become a compliance requirement. Logistics providers should:

• Assess current traceability capabilities
• Evaluate emerging technologies (AI, unique identifiers, blockchain)
• Prepare for potential integration with CBP systems

Indirect Impact on Logistics Providers

Even if logistics providers are not the direct targets of the new requirements, they will feel the effects:

1. Importer Demand for Support Importers facing new documentation and data collection burdens will turn to logistics providers for support. Providers that can offer supply chain visibility services will have a competitive advantage.

2. Increased Scrutiny of Shipments With greater visibility into supply chains, CBP will be better positioned to identify discrepancies and target high-risk shipments. This could lead to:

• More frequent examinations
• Increased detentions
• Greater documentation requests

3. Compliance Risk Transfer As importers face new compliance burdens, they will increasingly look to logistics providers to share the compliance burden. Providers that cannot demonstrate robust supply chain visibility may lose business to competitors that can.

5 · What Importers and Logistics Providers Must Do Now

1. Assess Current Supply Chain Visibility

Importers should inventory information currently available concerning manufacturers, producers, shippers, exporters, sellers, distributors, packagers, ultimate consignees, and other intermediaries. Key questions:

• Do you know who your upstream suppliers are beyond the first tier?
• Can you obtain foreign export documentation from your suppliers?
• Do you have systems in place to verify the accuracy of supplier-provided data?

2. Identify Data Gaps and Discrepancies

Companies should evaluate differences between foreign export data and U.S. entry data, particularly regarding:

• Value
• Quantity
• Classification
• Country of origin

Assess whether existing controls adequately explain and document those differences.

3. Evaluate Technology and Supplier Readiness

Potential requirements could necessitate changes to:

• Supplier relationships
• Contractual obligations
• Data systems
• Traceability technology
• Customs Trade Partnership Against Terrorism (CTPAT) compliance

4. Prepare to Comment by December 1

The comment period is a critical opportunity to shape any eventual proposed rule. Companies should consider submitting comments addressing:

• Requirements that would create significant costs
• Confidentiality concerns
• Technological challenges
• Supplier difficulties
• Potential disruptions to critical supply chains
• Feasibility, cost, timing, phase-in options, exemptions, and data-security safeguards

5. Begin Collecting Data Now

Companies that may comment should begin collecting operational data, implementation timelines, and cost estimates now. This will enable more informed and specific comments.

6. Monitor for Future Rulemaking

The ANPRM is only the first step. Importers and logistics providers should monitor CBP announcements for:

• A Notice of Proposed Rulemaking (NPRM) with specific regulatory text
• Implementation timelines
• Guidance on compliance

6 · Conclusion: A Defining Moment for Supply Chain Transparency

CBP’s ANPRM on heightened import disclosures represents one of the most significant potential expansions of import compliance requirements in decades. If adopted, the proposed changes would:

Key Takeaways

The Bottom Line

The ANPRM signals a fundamental shift in CBP’s approach to import compliance. The era of limited supply chain visibility is ending. Importers and logistics providers that invest in supply chain transparency now will be better positioned to comply with whatever requirements emerge.

The message is clear: CBP wants to know everything about your supply chain. The question is whether you can tell them.

This analysis reflects CBP’s Advance Notice of Proposed Rulemaking, “Heightened Import Disclosures for Supply Chain Visibility,” published in the Federal Register on September 2, 2026 (91 FR 56408–56414, Docket No. USCBP-2026-1058, RIN 1685-AA47). Comments are due December 1, 2026, and can be submitted via www.regulations.gov using docket number USCBP-2026-1058. Organizations engaged in international trade should consult with customs counsel and trade compliance professionals for guidance tailored to their specific circumstances.