How CBP’s ANPRM on Heightened Import Disclosures could change shippers’ compliance work

United States Customs and Border Protection issued an advanced notice of proposed rulemaking titled "Heightened Import Disclosures for Supply Chain Visibility." The ANPRM aims to give CBP more visibility into where goods are made, who participated in transactions, and what foreign export authorities were told. Pete Mento, Managing Director and Practice Leader for Global Trade Management at Baker Tilly, reviewed the ANPRM's implications for shippers.

CBP has criticized the existing Manufacturer/Shipper Identification (MID) system as insufficient. The agency is considering replacing or supplementing it with full legal company names and addresses and more granular labels for manufacturer, producer, shipper, exporter, seller, and potentially distributor. The aim is to make it harder to hide dual invoicing, illegal transshipment, and origin manipulation.

The ANPRM also signals interest in technology that provides verifiable visibility: supply-chain tracing platforms, methods to verify raw material origin, tamper-proof credentials, digital entry identifiers, and tighter integration with CBP's Automated Commercial Environment (ACE). CBP explicitly tied this push to an executive order on strengthening customs enforcement.

Practical implications for shippers

Mento's main point is that this is more than a new data field for entries. It asks whether importers should identify who made the goods, who exported them, who moved them, what foreign governments were told, which technology platforms touched the transaction, and possibly upstream production details. For compliant companies, better data and identifiers could reduce unnecessary examinations and speed predictable clearance by letting CBP focus on legitimately risky shipments.

• Map where export and transport documents currently live for each supplier and trading lane.
• Assess how reliably supplier identifiers (legal name, address, manufacturer ID) are captured across systems.
• Review contracts and data-access rights with suppliers, forwarders, and consolidators.
• Evaluate traceability tools and how they would integrate with ACE and existing entry processes.

If the proposal moves forward, shippers that already maintain consolidated, verified supplier and export documentation will likely have an advantage in avoiding delays and additional scrutiny.

The ANPRM moves customs compliance toward supply-chain governance. It promises better targeting by CBP and potential clearance efficiencies for compliant importers, but it also shifts practical burdens onto importers to assemble and verify foreign-sourced records and participant identities.