Plain-English, general-public guidance based on CBP’s September 2026 Advance Notice of Proposed Rulemaking on heightened import disclosures and supply chain visibility.
U.S. Customs and Border Protection is considering a significant shift in how much supply chain information businesses may eventually need to provide for goods entering the United States.
The September 2, 2026 ANPRM asks the public for input on stronger identification of supply chain parties, foreign export documentation, business identifiers, traceability technology, and possible CTPAT changes.
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.
Check the individual evidence points you can support today. This score is only a self-assessment tool; it is not a CBP rating or legal conclusion.
CBP says the current Manufacturer Identification Code (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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
A simple readiness exercise is to select one recent imported product and see how quickly your team can build a complete, consistent evidence file.
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.
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.
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.
No. It is an Advance Notice of Proposed Rulemaking (ANPRM). CBP is gathering information and public comments before deciding whether to propose regulations.
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.
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.
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.
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.
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.
These links mirror the official-reference section in the article.