CBP Seeks Input on Heightened Import Disclosure Requirements
Published Sept. 2, 2026
Key Points
- CBP is considering new requirements to increase visibility into imported goods and their supply chains.
- CBP is seeking comments on foreign export documentation, including export declarations, commercial invoices, packing lists, certificates of origin, licenses, and transport documents.
- The agency is considering replacing or expanding the current Manufacturer or Shipper Identification Code (MID) with more detailed party information or global business identifiers.
- CBP is exploring technology, including AI-driven tools, to improve supply chain traceability and detect illegal transshipment.
- The proposals could expand supply chain data requirements for importers and CTPAT participants.
- Comments on the advance notice of proposed rulemaking (ANPRM) are due by December 1, 2026.
The 
U.S. Customs and Border Protection (CBP) is considering new measures to strengthen supply chain visibility for goods imported into the United States. The agency published an advance notice of proposed rulemaking on September 2, 2026, seeking input on enhanced import disclosures, foreign export documentation, party identification, supply chain tracing technology, and potential changes to CTPAT requirements. The proposals aim to help CBP identify illicit imports and illegal transshipment while improving its ability to verify information provided during the import process. Importers and other trade participants may submit comments by December 1, 2026, through the Federal eRulemaking Portal via Docket No. USCBP-2026-1058.
Foreign Export Documentation
CBP is considering whether importers should provide documents that foreign exporters submit to foreign customs authorities before goods are exported to the United States. According to CBP, foreign export documents may include:
- Export declarations showing declared value, classification, and quantity
- Commercial invoices showing the transaction value declared to the foreign customs authority
- Packing lists verifying contents, weight, and packaging
- Certificates of origin substantiating the country of origin
- Export licenses or permits for controlled, restricted, or dual-use goods
- Transport documents (such as bills of lading or air waybills) required as part of the foreign export manifest
Also, CBP is asking whether this documentation should be required for all imports or only certain categories, whether it should be transmitted at entry or entry summary filing or retained as a recordkeeping obligation, and how CBP should handle documents not written in English.
Changes to Manufacturer Identification
The agency says the existing MID provides limited identifying information and may not consistently identify the party CBP needs for enforcement purposes. CBP is asking whether importers should instead provide information such as the full company name, physical address, or other business identifiers for manufacturers, shippers, and exporters.
Global Business Identifiers
The test currently allows participants to provide identifiers such as:
- Data Universal Numbering System (D-U-N-S)
- Global Location Number (GLN)
- Legal Entity Identifier (LEI)
- Altana ID
CBP is asking whether these identifiers should become part of entry or entry summary data and whether businesses could feasibly obtain and provide them for foreign supply chain parties.
Using Technology and AI to Enhance Traceability
CBP is considering the use of technology to improve supply chain visibility and identify potential illegal transshipment before goods arrive or are released.
The agency is seeking information about:
- Technologies businesses currently use to trace supply chains
- How companies verify supply chain data
- The role of AI in supply chain tracing
- Integration with the Automated Commercial Environment (ACE)
- Technology for verifying the origin of raw materials
- Costs for small businesses and larger companies
CTPAT Considerations
CBP is also asking whether Customs Trade Partnership Against Terrorism (CTPAT) participants should face additional supply chain tracing requirements.
Potential changes could include requiring certain CTPAT partners to use enhanced tracing technology or provide CBP with greater visibility into their supply chain systems.
CBP is also asking about adding cybersecurity and data integrity requirements to the CTPAT minimum security criteria, including possible restrictions on certain logistics platforms.
What Importers Should Watch
The proposals remain under consideration. CBP is using comments from the advance notice of proposed rulemaking to help determine whether to develop a future Notice of Proposed Rulemaking.
Importers and other supply chain participants may want to review how they currently obtain and retain foreign export documents, identify manufacturers and suppliers, and manage supply chain data. CBP is specifically seeking information about the operational costs, technology requirements, data accuracy, and compliance effects of the proposals.
Again, importers and other trade participants have until December 1, 2026, to submit comments through the Federal eRulemaking Portal via Docket No. USCBP-2026-1058.
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