CBP Call for Heightened Import Disclosure

U.S. Customs and Border Protection (CBP) is considering rules that would require importers to provide more detailed information about imported goods, supply-chain participants, and foreign export filings.

CBP announced the initiative on September 2, 2026, when it published an Advance Notice of Proposed Rulemaking (ANPRM), “Heightened Import Disclosures for Supply Chain Visibility,” at 91 Fed. Reg. 56,408. Comments are due December 1, 2026, under docket USCBP-2026-1058.

The ANPRM does not impose new obligations. It begins a process that may lead to proposed regulations.

CBP seeks comment on whether it should:

• Require importers to obtain, retain, or submit documents filed with foreign customs authorities, including export declarations, invoices, packing lists, certificates of origin, licenses, and transportation records;

• Require identification of manufacturers, producers, sellers, exporters, shippers, online marketplaces, and ultimate delivery recipients;

• Replace or supplement the Manufacturer Identification Code with legal names, physical addresses, foreign tax identifiers, or Global Business Identifiers;

• Require importers to provide supply-chain and production information before goods arrive in the United States;

• Use artificial intelligence and other technology to detect illegal transshipment, false origin claims, and discrepancies between foreign export records and U.S. entry data; and

• Expand Customs Trade Partnership Against Terrorism requirements to include tracing technology, cybersecurity controls, data sharing, and restrictions on logistics platforms considered security risks.

The initiative implements Executive Order 14411, “Strengthening Customs Enforcement”. CBP states that greater visibility would help it identify high-risk shipments, prevent customs fraud, protect revenue, and enforce laws concerning forced labor, origin, intellectual property, product safety, and admissibility.

Implications

The contemplated rules could shift customs compliance from reporting facts about a shipment to verifying the parties, records, and production history behind it.

Importers may need information from manufacturers, raw-material suppliers, exporters, and logistics providers several tiers removed from the U.S. transaction. Contracts may need new provisions addressing document access, data accuracy, retention, audit rights, confidentiality, and responsibility for customs penalties.

Businesses also may face:

• Earlier filing deadlines and longer pre-entry preparation;

• New procedures to reconcile foreign export documents with U.S. customs filings;

• Greater exposure when foreign suppliers provide incomplete or inconsistent information;

• Investments in supplier mapping, entity identifiers, traceability systems, cybersecurity, and data integration;

• Increased scrutiny of goods routed through third countries or involving multiple intermediaries;

• Operational changes for customs brokers, carriers, marketplaces, and logistics providers; and

• Added costs and possible delays, particularly for small importers and complex or fragmented supply chains.

Companies with reliable supplier data and mature tracing systems may benefit from fewer disruptions, stronger origin substantiation, and possible CTPAT advantages. Companies that cannot document upstream parties or obtain foreign export records may face holds, information requests, enforcement inquiries, or difficulty establishing admissibility if CBP adopts the contemplated requirements.

Next Steps

Importers should identify gaps in their ability to map suppliers, obtain authentic foreign export records, verify business identifiers, trace raw materials, and reconcile foreign and U.S. customs data.

Affected companies and trade associations should consider commenting on feasibility, confidentiality, costs, implementation periods, exemptions, phased compliance, and treatment of small businesses, critical goods, and CTPAT participants. Quantified examples will carry more weight than general objections.

Comments must be submitted by December 1, 2026.

Sources: CBP National Media Release; Advance Notice of Proposed Rulemaking, 91 Fed. Reg. 56,408; Executive Order 14411.