CBP signals major overhaul of import disclosure requirements - what importers need to know
Date of publication: September 9, 2026.
At a glance
: U.S. Customs and Border Protection (CBP) published an Advance Notice of Proposed Rulemaking (ANPRM) that could reshape how importers document, identify, and provide greater visibility into their supply chains and origin-related information. Comments are due on December 1, 2026, 90 days after the September 2, 2026 Federal Register Notice.What happened
CBP has issued an Advance Notice of Proposed Rulemaking (ANPRM) titled "Heightened Import Disclosures for Supply Chain Visibility" (Docket No. USCBP-2026-1058, RIN 1685-AA47). The notice implements Executive Order 14411, "Strengthening Customs Enforcement," signed June 3, 2026, which directed the Department of Homeland Security to develop new mechanisms for verifying importer identity, supply chain provenance, and compliance with U.S. trade laws - with a particular focus on stopping illegal transshipment.
This is not yet a binding rule. An ANPRM is CBP's mechanism for gathering industry input before drafting a formal Notice of Proposed Rulemaking (NPRM). But the scope and detail of the questions posed - 64 in total - signal that CBP intends to move forward with substantial changes, and companies that engage now will have more influence over the eventual rule's shape and implementation timeline.
Three areas of focus
1. Foreign export documentation
CBP is considering requiring importers of record to obtain and submit documentation that foreign exporters already file with their own customs authorities - such as export declarations, commercial invoices, packing lists, certificates of origin, export licenses, and transport documents. The stated goal is to cross-check declared values, quantities, and classifications against what CBP receives at U.S. entry, helping detect discrepancies such as dual invoicing. CBP is also weighing whether certain high-risk product categories could require this documentation as a condition of entry.2. Identifying supply chain parties
CBP is reconsidering the long-standing Manufacturer Identification Code (MID), which it says is inconsistent and doesn't always identify the party CBP needs to know. Options on the table include replacing the MID with more robust identifiers - potentially building on CBP's existing Global Business Identifier (GBI) test, which uses identifiers such as D-U-N-S, GLN, LEI, or Altana ID - and expanding disclosure to cover manufacturers, shippers, sellers, exporters, distributors, and even marketplaces or ultimate consignees.3. Technology and CTPAT
CBP is exploring how AI-driven and other traceability technologies, including tools that can help flag illegal transshipment before goods reach the U.S. border. It is also studying how the CTPAT program's minimum-security criteria might expand to include cybersecurity, data integrity requirements, and restrictions on the use of "covered logistics platforms" (e.g., foreign-controlled systems flagged as national security risks).Why this matters for your business
- Documentation burden could increase materially.If foreign export records become a standard part of entry or recordkeeping obligations, importers will need new processes - and possibly new supplier agreements - to reliably obtain this data.
- Reconciliation risk.Discrepancies between foreign export filings and U.S. entry data (value, quantity, classification) could draw new scrutiny, even where differences are legitimate and explainable.
- CTPAT participants should watch closely.CBP is exploring differentiated treatment for CTPAT-validated importers, as well as new technology and cybersecurity requirements tied to program membership.
- Technology investment could become more important to meeting future compliance or CTPAT expectations,not just a competitive advantage, particularly around entity identification and shipment-level traceability.
What to do now
This ANPRM is a genuine opportunity to shape the eventual rule. Companies should consider:
- Reviewing current visibility into upstream suppliers, manufacturers, and foreign export documentation practices.
- Assessing the feasibility and cost of obtaining/retaining foreign export records for your supply chains.
- Evaluating current use (or non-use) of GBIs and other entity-identification tools.
- Submitting comments - directly or through trade associations - before the deadline, particularly on cost, timeline, and small-business impact, since CBP has explicitly invited that input.
Comments can be submitted via the Federal eRulemaking Portal at regulations.gov under Docket No. USCBP-2026-1058, and are due December 1, 2026, 90 days after the September 2, 2026 Federal Register publication date.
This article is for general informational purposes and does not constitute legal advice. Companies should consult trade counsel regarding the specific implications for their operations.
For more information on how ONESOURCE Global Trade solutions can assist you in managing supply chain risk, tariff challenges, and regulatory compliance, please contact your Account Manager or Customer Success Manager.