U.S. CBP seeks comments on heightened import disclosure and supply chain visibility requirements
Notice requests input on foreign export documentation, traceability tools, global business identifiers, and CTPAT enhancements.
U.S. Customs and Border Protection (CBP) today released an advance notice of proposed rulemaking (ANPRM) requesting comments on potential amendments to regulations intended to increase visibility into the supply chains of goods imported into the United States. The ANPRM is issued in response to Executive Order 14411, “Strengthening Customs Enforcement,” and seeks input on measures designed to enhance customs enforcement and improve CBP’s ability to detect illicit importations, including goods that may be illegally transshipped to evade U.S. customs and trade laws.
CBP is requesting comments on a broad range of potential requirements and policy approaches, including:
- Whether importers of record should be required to submit or retain foreign export documentation provided to foreign customs or export authorities, including export declarations, commercial invoices, certificates of origin, export licenses or permits, packing lists, and transportation documents
- The scope, timing, retention periods, and operational considerations associated with any foreign export documentation requirements
- Whether certain imports posing national security concerns should be subject to heightened documentation requirements as a condition of entry
- Potential revisions to the Manufacturer Identification Code (MID) system, including whether CBP should require additional identifying information for manufacturers, shippers, exporters, sellers, or other supply chain participants
- The use of Global Business Identifiers (GBIs), foreign tax identifiers, and other business identifiers to improve supply chain visibility
- Whether additional supply chain participants, such as online marketplaces or ultimate delivery recipients, should be identified to CBP
- The use of technologies to trace supply chains, verify origin, and identify illegal transshipment, including the role of artificial intelligence and interoperability standards
- Potential changes to filing timelines to allow CBP additional time to review supply chain information before imported goods are released
- Potential enhancements to the Customs Trade Partnership Against Terrorism (CTPAT) program, including supply chain traceability, cybersecurity, data integrity, and the use of logistics platforms
The ANPRM contains 64 questions seeking information on existing business practices, implementation challenges, compliance costs, and potential benefits associated with these approaches. CBP states that comments received may be used to develop a future notice of proposed rulemaking
Comments are due within 90 days of publication of the ANPRM in the Federal Register, scheduled for September 2, 2026.