CBP proposes wider supply-chain data demands for U.S. importers

# What the proposal is U.S. Customs and Border Protection published an advance notice of proposed rulemaking (ANPRM) titled "Heightened Import Disclosures for Supply Chain Visibility." The stated aim is to improve visibility into how goods enter the U.S. so CBP can better detect illicit imports, fraud, undervaluation, and other violations of customs and trade laws.

CBP ties this ANPRM to a June White House executive order called "Strengthening Customs Enforcement," which directs increased customs enforcement, greater transparency in international supply chains, and closing enforcement gaps.

# Three areas CBP is focused on

• Foreign export documentation: CBP may require U.S. importers to provide or retain the documents their foreign suppliers submitted to foreign customs authorities—examples cited include export declarations, commercial invoices, packing lists, certificates of origin, export licenses and permits, bills of lading, and air waybills. CBP plans to use those documents to compare foreign export information with U.S. entry information to identify discrepancies or violations.

• Identification of supply-chain participants: CBP says the current Manufacturer/Shipper Identification (MID) system lacks reliable information. The agency is considering replacing or supplementing MID with full legal company names and addresses and adding fields such as manufacturer, producer, shipper, exporter, seller and possibly distributor information.

• Technology and traceability: CBP is exploring requirements for importers to use technologies that improve provenance and movement visibility. The ANPRM mentions artificial intelligence, supply-chain tracing platforms, technology to verify raw material origins, tamper-proof credentials, digital entry identifiers, and integration with CBP's Automated Commercial Environment (ACE).

# Why CBP says this matters CBP Commissioner Rodney S. Scott is quoted saying, "Border security is national security. Knowing what is coming into this country is vital to our national security." CBP frames the measures as tools to identify high-risk shipments, stop illicit trade, and ensure lawful competition for U.S. businesses.

The agency links the ANPRM to objectives in the executive order: preventing unlawful and dangerous goods, ensuring importers of record are identified and accountable, and enforcing laws governing forced labor, rules of origin, intellectual property, revenue collection, and product safety.

# Industry reaction and implications

# Next steps for the trade community CBP is accepting comments on the ANPRM through Dec. 1, 2026. Submit comments via the Federal Rulemaking Portal at regulations.gov under docket USCBP-2026-1058. CBP says stakeholder feedback will inform how the agency balances enforcement goals with the need to avoid unnecessary burdens, particularly for small businesses.

# Practical takeaway