Plain-English, general-public article based on CBP’s September 2026 Advance Notice of Proposed Rulemaking.

U.S. Customs and Border Protection (CBP) is considering a significant shift in how much supply chain information businesses may eventually need to provide for goods entering the United States.

On September 2, 2026, CBP scheduled publication of “Heightened Import Disclosures for Supply Chain Visibility,” an Advance Notice of Proposed Rulemaking (ANPRM) under Docket USCBP-2026-1058. The notice addresses 19 CFR Parts 141, 142, 143 and 163 and asks the public for input on stronger identification of supply chain parties, foreign export documentation, business identifiers, traceability technology, and possible CTPAT changes.

IMPORTANT: THIS IS NOT A FINAL RULE. An ANPRM is an early rulemaking step. CBP is asking questions and collecting public input. The notice says the comments may later be used to develop a Notice of Proposed Rulemaking. Businesses should not describe these ideas as current mandatory requirements.

Why CBP Is Looking at Supply Chain Visibility

The notice follows Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026. CBP explains that the order directs DHS toward heightened import disclosures involving foreign tax and global business identifiers, more detailed supply chain and production information, and documentation that foreign exporters were required to provide to foreign customs authorities before export to the United States.

In plain English: CBP is exploring ways to see more of the transaction behind an import—not only the U.S. entry data.

Quick Takeaways

• CBP is considering whether importers should obtain, retain or submit certain foreign export documents.
• CBP is questioning whether the traditional Manufacturer Identification Code (MID) gives enough reliable information.
• The agency is exploring Global Business Identifiers (GBIs) and other ways to identify manufacturers, shippers, sellers and exporters.
• CBP is asking how technology—including AI—could improve supply chain tracing and origin verification.
• CTPAT partners could eventually face stronger expectations involving traceability, cybersecurity and data integrity.
• No final rule has been adopted through this ANPRM.

The 12-Point CBP Supply Chain Visibility Checklist

1. Can You Identify Who Actually Made the Product?

CBP says the current MID can provide limited identifying information, may not always identify the actual party of enforcement interest, and is not always consistent or unique. The agency is asking whether the MID should be redefined, supplemented or replaced.

• Actual manufacturer
• Physical manufacturing location
• Shipper
• Exporter
• Seller
• Producer, when different from the manufacturer
• Other important parties involved in moving the goods

Simple test: If CBP asked, “Who physically produced this product and where?” could your company answer with documents instead of an assumption?

Source in notice: Section III.B.1, Q24-Q36.

2. Can Your U.S. Import Data Be Matched to the Foreign Export Records?

CBP is considering whether foreign export documentation could help verify and reconcile U.S. entry and entry summary information. The notice specifically mentions the possibility of detecting discrepancies such as dual invoicing.

• Foreign export declaration
• Commercial invoice
• Packing list
• Certificate of origin
• Export license or permit
• Bill of lading or air waybill
• Other records required by the exporting country’s customs or export authority

The core question is straightforward: Does the story reported abroad match the story reported in the United States?

Source in notice: Section III.A, Q1-Q18.

3. Do You Have a Process for Explaining Differences?

A difference between a foreign export document and a U.S. customs entry does not automatically mean misconduct. Different countries can use different reporting concepts. But CBP is explicitly asking what internal controls importers should use to identify and reconcile discrepancies in value, quantity, classification and other data.

• Why is the foreign export value different from the U.S. customs value?
• Why is the quantity different?
• Why is the tariff classification different?
• Why does one document identify a different party?
• Why does the stated origin differ?
• What evidence supports the explanation?

A defensible file should explain the difference, preserve the evidence and show who reviewed it.

Source in notice: Q10-Q13.

4. Can You Show That Foreign Documents Are Authentic?

CBP asks how an importer could ensure that a foreign export document provided to CBP is the exact document that was submitted to the foreign customs administration and has not been modified. The agency also asks whether it should verify authenticity with foreign customs administrations.

• Where did the document originate?
• Who obtained it?
• Who can modify it?
• Is the original version preserved?
• Can you establish an audit trail?
• Can you show when and from whom the record was received?

Saving a PDF is useful. Showing where that PDF came from is stronger.

Source in notice: Q12-Q13.

5. Do You Know the Companies Behind the Company Names?

CBP is evaluating Global Business Identifiers (GBIs) as a way to provide more precise information about parties in the supply chain. The current GBI test includes D-U-N-S®, Global Location Number (GLN), Legal Entity Identifier (LEI) and Altana ID.

• Do key manufacturers have stable business identifiers?
• Can the identifier be matched to the correct legal entity?
• Can it identify a specific business location?
• Can your broker or filing system capture the identifier?
• Who is responsible for maintaining the identifier data?

A company name by itself may not always be enough to distinguish one legal entity or location from another.

Source in notice: Section III.B.2, Q37-Q45.

6. Can You See Beyond the Direct Supplier?

CBP asks what technology is available to verify the origin of raw materials and bridge the visibility gap between suppliers and raw material sources. This shows that the agency is thinking beyond the immediate seller in certain supply chains.

• Direct supplier identified
• Actual producer identified
• Key component sources known when relevant
• Raw material origins known when legally relevant
• Supporting records connect the finished product to the upstream source

The deeper the legal requirement depends on origin or production, the more important upstream visibility becomes.

Source in notice: Q46-Q55, especially Q50.

7. Can You Support Country of Origin?

The notice describes illegal transshipment as routing goods through a third country to obscure or misrepresent their true country of origin. CBP says it has intensified enforcement and is evaluating AI-driven solutions to identify transshipment risk.

• Country of manufacture confirmed
• Production process documented
• Relevant processing steps documented
• Supplier statements supported by evidence
• Transportation route reviewed
• Unusual third-country routing investigated
• Origin records retained

“Our supplier told us” and “we can prove it” are not the same standard of readiness.

Source in notice: Section III.C.

8. Does Your Technology Provide Traceability—or Just Store Data?

CBP asks about supply chain visibility technologies, AI, integration with ACE, raw-material traceability, unique entity identifiers, tamper-resistant credentials and technology that could certify required entry data such as country of origin.

• Can your system show the source of a data element?
• Can it preserve version history?
• Can it connect supplier records to entry data?
• Can it identify who changed information?
• Can it exchange data with other systems?
• Can it support an audit or review?

The useful question is not simply, “Do we have software?” It is, “Can the software help us verify and defend the data?”

Source in notice: Q46-Q55.

9. Do You Know Where Your Logistics Data Goes?

CBP asks businesses to identify software platforms and service providers used to transmit shipping instructions, book freight and manage logistics data. It also asks what visibility businesses have into those platforms’ privacy and security practices.

• Which logistics platforms do we use?
• Where is our data stored?
• Who can access it?
• Can the data be altered?
• Are there audit logs?
• Do overseas suppliers require particular platforms?
• Have those platforms been reviewed for privacy and cybersecurity risk?

Supply chain visibility is not only about seeing the cargo. It is also about knowing who controls the information about the cargo.

Source in notice: Q35-Q36.

10. Are You a CTPAT Partner? Pay Close Attention.

CBP is asking whether CTPAT partners should use enhanced supply chain tracing technologies, make that visibility available to CBP, and meet expanded minimum security criteria related to cybersecurity and data integrity. The notice also asks about possible benefits for partners that use trusted technologies and data-chain partners.

• Current traceability tools documented
• Cybersecurity controls reviewed
• Data integrity controls documented
• Logistics platforms inventoried
• Supply chain partners assessed
• Potential system-transition costs understood

The notice continues to describe CTPAT as a voluntary program, but CBP is exploring whether technology and data integrity should play a larger role in the program.

Source in notice: Section III.C.2, Q56-Q61.

11. Can Your Customs Broker Get the Information It Needs?

Many of the data elements CBP is discussing originate far upstream from the customs broker. That means importer-broker coordination could become even more important if future rules require earlier or deeper supply chain information.

• Broker receives accurate manufacturer information
• Exporter, seller and shipper roles are clearly identified
• Foreign export documents can be obtained when needed
• Supplier data can be validated before filing
• Inconsistencies are escalated before transmission
• Responsibility for missing data is assigned

CBP also asks whether earlier entry filing could improve its ability to review supply chain documentation before admissibility decisions.

Source in notice: Q31 and Q43-Q45.

12. Could You Survive a ‘Show Me the File’ Request?

A simple readiness exercise is to select one recent imported product and see how quickly your team can build a complete, consistent evidence file.

• Manufacturer name and address
• Exporter
• Seller
• Shipper
• Country of origin
• Commercial invoice
• Packing list
• Foreign export declaration, if available
• Transportation document
• Origin support
• Classification support
• Value support
• Explanation of inconsistencies
• Record of who supplied and reviewed the information

If collecting these records takes days—or nobody knows who owns them—that is useful information about your current process.

Readiness exercise derived from the documentation, identification and traceability questions throughout Sections III.A-III.C.

What Is CBP Trying to Accomplish?

The notice repeatedly returns to one objective: giving CBP greater visibility into the parties, records and production history behind imported goods.

CBP says the proposals could help it detect and interdict illicit importations, especially goods illegally transshipped to evade U.S. customs and trade laws. The agency also links the initiative to enforcement involving forced labor, rules of origin, origin marking, intellectual property, revenue collection and product safety.

For the general public, the practical message is simple: customs compliance is increasingly connected to supply chain data quality.

What Should Businesses Do Today?

DO NOT TREAT THE ANPRM AS A CURRENT MANDATE. The notice is asking questions about possible future rules. A practical response today is to assess data gaps, document ownership and supplier readiness—not to claim that CBP has already imposed every proposal discussed in the notice.

A useful readiness framework is: KNOW → VERIFY → DOCUMENT → RECONCILE → RETAIN → DEFEND

• KNOW: who participates in the supply chain.
• VERIFY: the information received from suppliers and partners.
• DOCUMENT: the transaction and the basis for customs data.
• RECONCILE: differences between foreign export and U.S. import information.
• RETAIN: supporting records in a retrievable form.
• DEFEND: what was ultimately reported to CBP.

One-Minute Final Checklist

• WHO made it?
• WHERE was it actually made?
• WHO sold, shipped and exported it?
• WHAT did the foreign country receive or require for export?
• WHAT did we report to CBP?
• DO the two records agree?
• IF NOT, can we explain the difference?
• CAN we support the country of origin?
• CAN we trace the source of the data?
• CAN we retrieve the evidence quickly?

If several answers are “we do not know,” supply chain visibility is no longer only a logistics or IT issue. It may become an increasingly important customs compliance issue.

Frequently Asked Questions

Is CBP’s September 2026 supply chain visibility notice a final rule?

No. It is an Advance Notice of Proposed Rulemaking (ANPRM). CBP is gathering information and public comments before deciding whether to propose regulations.

What foreign export documents is CBP considering?

The notice discusses export declarations, commercial invoices, packing lists, certificates of origin, export licenses or permits, and transport documents such as bills of lading or air waybills, among other possible records.

Is CBP planning to eliminate the MID?

CBP has not made that decision in this notice. It is asking whether the current Manufacturer Identification Code should continue, be improved, or be replaced or supplemented by other identifying information.

What are Global Business Identifiers?

CBP’s current GBI test includes identifiers such as D-U-N-S®, GLN, LEI and Altana ID. CBP is asking whether such identifiers could improve the identification of parties in international supply chains.

Does the notice affect CTPAT?

CBP is asking whether CTPAT partners should face enhanced expectations involving supply chain tracing technology, cybersecurity and data integrity, and what additional benefits could be offered to qualifying partners.

When are public comments due?

The scheduled notice states that comments are due 90 days after publication in the Federal Register. With publication scheduled for September 2, 2026, that corresponds to December 1, 2026.

Official References

1. U.S. Customs and Border Protection — Heightened Import Disclosures for Supply Chain Visibility. FR Doc. 2026-17926; Docket USCBP-2026-1058; RIN 1685-AA47; 19 CFR Parts 141, 142, 143 and 163. Scheduled Federal Register publication: September 2, 2026. federalregister.gov/d/2026-17926
2. Regulations.gov — Docket USCBP-2026-1058. Use this docket to review materials and submit comments. regulations.gov/docket/USCBP-2026-1058
3. Executive Order 14411 — “Strengthening Customs Enforcement,” signed June 3, 2026; cited in the CBP notice as 91 FR 35125 (June 10, 2026).
4. CBP CTPAT Program — official CBP program information cited in the notice. cbp.gov/border-security/ports-entry/cargo-security/ctpat

PUBLICATION NOTE: This article is an educational summary of CBP’s ANPRM for general informational purposes. It is not legal advice. Because the notice is an early rulemaking document, readers should distinguish between current law and the future requirements CBP is considering.