03.09.2026 Regulation #USA #Import #Logistics

CBP proposes tighter supply chain disclosure rules for importers

U.S. Customs and Border Protection (CBP) published an Advance Notice of Proposed Rulemaking (ANPRM) titled "Heightened Import Disclosures for Supply Chain Visibility" in the Federal Register on September 2, 2026 (full text at federalregister.gov). The notice, filed under docket USCBP-2026-1058, marks an early stage of rulemaking — no binding rule has been adopted yet.

The legal basis is Executive Order 14411, "Strengthening Customs Enforcement," signed June 3, 2026, and published in the Federal Register on June 10, 2026. CBP cites authority under 19 U.S.C. §§ 1484, 1485, 1508, 1509 and 1624.

What CBP wants importers to disclose

The ANPRM raises several potential measures:

Foreign export documentation. Importers of record could be required to submit export declarations, commercial invoices, packing lists, certificates of origin and transport documents filed with foreign customs authorities, giving CBP visibility into the full shipping route and helping it detect illegal transshipment through third countries.
Replacing the Manufacturer Identification Code (MID). CBP says the current MID system "provides limited identifying information" and is exploring alternatives.
Global Business Identifiers (GBIs). A voluntary test program launched in 2022 uses D-U-N-S, GLN, LEI and Altana ID to identify manufacturers, shippers and sellers; CBP is weighing whether to expand or mandate its use.
Supply chain traceability technology, including AI-driven solutions and private-sector platforms for tracking goods and flagging illegal transshipment.
Expanded CTPAT criteria — the trusted-trader program could gain cybersecurity and data-integrity requirements, along with restrictions on foreign-controlled logistics platforms.

Who could be affected and what it means in practice

CBP is explicitly asking the trade community to weigh in on scope: whether the future rule should apply to all imported goods or be limited to specific categories, countries of origin or modes of transport; whether small entities, foreign importers and CTPAT members should get different implementation timelines; and whether critical medical products should be exempted.

The stakes are particularly high for small business: CBP notes that small entities make up roughly 70% of CTPAT membership. The agency also flags the existing informal entry threshold of $2,500 or less, which is likely to factor into decisions on which shipments the new disclosure requirements would cover.

Timeline for the next steps

For now, CBP is only gathering industry input: comments on docket USCBP-2026-1058 are open on regulations.gov through December 1, 2026. Based on the feedback received, the agency may move to the next stage — issuing a formal Notice of Proposed Rulemaking (NPRM) with concrete requirements and an effective date; a compliance timeline for businesses would be announced separately at that stage.

Primary sources

This material is for information only and does not constitute legal advice or customs consulting. Verify changes against the primary sources before acting.