Executive Summary On September 2, 2026, U.S. Customs and Border Protection published an Advance Notice of Proposed Rulemaking titled “Heightened Import Disclosures for Supply Chain Visibility” (Docket No. USCBP-2026-1058). The ANPRM implements Executive Order 14411 (it begins the rulemaking for significant portions of Section 3 of the order and contemplates amendments to 19 CFR Parts 141, 142, 143, and 163) and seeks public comment on 64 specific questions covering three core areas: foreign export documentation, enhanced identification of supply chain parties, and technology-enabled traceability. The notice does not impose new obligations—it is a preliminary step to inform a future Notice of Proposed Rulemaking. But the breadth of the questions and the potential operational consequences make this a critical development for every importer with international supply chains. Comments are due by December 1, 2026, and CBP used its September Trade and Cargo Security Summit to encourage the trade community to file them. This analysis, which complements our earlier overview of the proposals, focuses on what the notice asks and how to prepare a useful comment.

CBP’s Supply Chain Visibility ANPRM: The December 1 Comment Deadline Is Approaching

(CBP供应链可见性ANPRM：12月1日意见征询截止日临近)

1 · Why This ANPRM Matters

The Policy Foundation: Executive Order 14411

The ANPRM is a direct implementation of Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026. Section 3 of the order directs the Secretary of Homeland Security to take steps to:

• Require disclosure of foreign tax and global business identifiers, along with detailed information about supply chains and production methods
• Mandate submission of any documentation or information that the foreign exporter was required to submit to foreign customs authorities prior to exporting to the United States
• Leverage the CTPAT program to strengthen customs enforcement

The Enforcement Context

The ANPRM is one of several enforcement steps taken under or alongside the executive order in 2026:

CBP’s stated goal is to “more effectively detect and interdict illicit importations, especially those that are illegally transshipped to evade compliance with U.S. customs and trade laws.” CBP itself classifies the ANPRM as a “significant regulatory action.”

The CBP Commissioner’s Framing

CBP Commissioner Rodney S. Scott framed the initiative in national security terms:

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

2 · The Three Pillars of the ANPRM

Pillar 1: Foreign Export Documentation

The most 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:

Source: 91 FR 56408; JETRO

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. CBP explicitly states that foreign export documents could be used to reconcile U.S. entry declarations for value, classification, and quantity, and to detect illegal transshipment.

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?
• Should submission be randomized or targeted at high-risk products and countries?

Pillar 2: Enhanced Identification of Supply Chain Parties

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

The Problem with MID: CBP argues that the existing Manufacturer Identification Code (MID)—derived from name and address data—has significant shortcomings: it is not always unique or consistent, and is not always available to CBP early enough in the entry process to be operationally useful.

The Proposed Solution: CBP is evaluating replacing or supplementing the MID with more detailed information identifying:

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

Global Business Identifiers (GBIs): CBP is testing four global business identifiers as potential replacements or supplements to the MID:

Source: Barnes Richardson; Federal Register

The GBI concept reflects CBP’s desire to track all parties involved in the supply chain or chain of title to the goods and detect any intermediaries of interest or concern.

Key Questions CBP Is Asking:

• What data elements should be required for each party?
• When should GBI data be submitted—before arrival, at entry, or at entry summary?
• Should product-level identifiers (model, style, composition, grade, size) be required?
• How should CBP address confidentiality and competitive concerns?

Pillar 3: Technology-Enabled Traceability

CBP is exploring how traceability technologies, artificial intelligence, and unique identifiers could verify origin, production methods, and the movement of goods.

The Technologies Under Consideration:

Source: Federal Register; Barnes Richardson

The LOGINK Concern: CBP specifically asks companies (Question 35) to describe the software platforms and service providers they use to transmit shipping instructions, book freight, or manage logistics data—and specifically mentions LOGINK and other foreign-controlled logistics platforms that may pose national security risks.

CTPAT Integration: CBP is considering whether CTPAT participants should be required to use enhanced traceability technologies and whether CBP should receive greater visibility into those systems. The agency is also exploring whether CTPAT security criteria should address cybersecurity, data integrity, and risky foreign-controlled logistics platforms (Question 61 asks what administrative, operational, or software-transition costs a company would incur if the criteria restricted or prohibited “covered logistics platforms” such as LOGINK), and whether CTPAT members that proactively share supply chain visibility data should receive additional trade facilitation benefits.

3 · The 64 Questions: What CBP Wants to Know

The ANPRM poses 64 specific questions that will shape any future proposed rule. The categories below are our paraphrase of the main themes; the exact wording of Questions 1–64 is in the Federal Register notice and should be reviewed before drafting a comment. Examples of specific questions include whether an online marketplace that facilitated a sale should be identified (and why), which booking platforms such as LOGINK companies use (Q35), and what it would cost to comply if CTPAT criteria restricted covered logistics platforms (Q61).

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 requirements be phased in by entry type, commodity, country, or mode of transportation—or apply differently to small entities, foreign importers, CTPAT participants, or high-volume filers?
• Are any proposals suited to a voluntary test program first?
• What are the anticipated costs and benefits of compliance?

4 · What This Means for Logistics Providers

4.1 The New Documentary Layer

The foreign export documentation requirement 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 from suppliers
• Ensure consistency between foreign export data and U.S. entry data
• Maintain records for extended periods
• Explain and document discrepancies in value, classification, and quantity

As legal analysts have noted, this proposal could “effectively create a new documentary layer between the foreign export transaction and the US import entry”.

4.2 Expanded Data Collection

Identifying every party in the supply chain—from raw material suppliers to ultimate consignees—would require significantly more data collection. 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

4.3 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, tamper-resistant credentials)
• Prepare for potential integration with CBP systems such as ACE

4.4 The Compliance Burden Shift

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
• CTPAT compliance

4. Prepare to Comment by December 1

The comment period is a critical opportunity to shape any eventual proposed rule. CBP expressly requests information on implementation costs, data availability, supplier lead times, technology limitations, small-business impacts, critical goods, and potential supply chain disruptions. 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

How to Submit Comments:

Source: Federal Register; CBP

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 is a preliminary step, but one that practitioners are treating as a signal of where customs enforcement is headed. If CBP moves forward with anything like the ideas it is floating, importers could be required to obtain, verify, retain, and potentially transmit far more information about their international supply chains than they do today. No regulatory text has been proposed yet.

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—and whether you will help shape the rules before they are written.

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). Comments are due December 1, 2026, and can be submitted via the Federal eRulemaking Portal 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.