U.S. Customs and Border Protection (CBP) has published an Advance Notice of Proposed Rulemaking (ANPRM), Heightened Import Disclosures for Supply Chain Visibility, inviting public comment on concepts that could fundamentally reshape the information importers must collect, verify and submit when goods enter the United States.
CBP describes the effort as a step toward more effective detection and interdiction of illicit importations, particularly those routed through third countries to evade U.S. customs and trade laws. The scope of the questions CBP is asking signals that the agency is examining changes that go well beyond incremental adjustments to existing entry requirements.
No new requirements are in effect today. This is an early step in the federal rulemaking process, and CBP is gathering industry input before deciding whether, and how, to move forward with a formal proposed rule. Given the breadth of what is under consideration, however, Alba believes this ANPRM deserves close, immediate attention from every importer, broker and supply chain partner we work with.
Why This Could Represent a Fundamental Shift in Import Processing
The ANPRM traces directly to Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026. That order directed the Secretary of Homeland Security to establish heightened import disclosure requirements, including foreign tax and global business identifiers, detailed supply chain and production information, and expanded use of the CTPAT program. This ANPRM is CBP’s first formal step in carrying that mandate forward.
Taken together, the concepts under review would touch nearly every stage of the import transaction: what documentation importers must obtain from foreign suppliers, who must be identified in a shipment, what identifiers replace or supplement today’s Manufacturer Identification Code (MID), and what technology importers may eventually be expected to deploy to prove where their goods really came from.
Potential Impacts for Importers and Trade Compliance Teams
If any of these concepts advance to a formal rule, companies could eventually face:
- Greater due diligence obligations on foreign suppliers
- New recordkeeping requirements
- Collection of foreign customs export data
- Expanded producer and manufacturer disclosures
- Additional data elements at entry and/or entry summary
- Increased scrutiny of country of origin claims
- Greater emphasis on supply chain mapping and traceability systems
- New compliance expectations tied to national security concerns
1. Foreign Export Documentation May Be Required
CBP is considering whether importers should be required to provide or retain documentation that foreign exporters already submit to their own customs authorities, including:
- Export declarations
- Commercial invoices
- Packing lists
- Certificates of origin
- Export licenses and permits
- Transport documents, such as bills of lading and air waybills
CBP states this information could help identify illegal transshipment, dual invoicing, customs fraud, country of origin evasion and national security risks by allowing the agency to compare what was reported abroad against what is reported at entry into the United States. For many importers, obtaining these records will depend heavily on cooperation from foreign suppliers, manufacturers and exporters, some of whom may be reluctant or unable to share them.
2. Expanded Identification of Supply Chain Parties
CBP has concluded that the MID, in use since 1986, does not always provide a unique or reliable way to identify foreign entities. The agency is asking whether importers should instead identify additional parties involved in a transaction, potentially including the manufacturer, producer, supplier, exporter, shipper and seller, as well as online marketplaces and the ultimate delivery recipient.
Expanded party identification could require importers to gather significantly more detail from suppliers and business partners well before goods are ready to ship, reshaping supplier onboarding processes across the board.
3. Global Business Identifiers Could Supplement or Replace the MID
CBP is also reexamining its ongoing Global Business Identifier (GBI) test, which currently allows importers to transmit standardized identifiers such as D-U-N-S®, the Global Location Number (GLN), the Legal Entity Identifier (LEI) and the Altana ID alongside entry data. The agency is asking whether GBIs should become a broader or mandatory requirement, and whether additional identifiers should be added to the test.
A wider GBI requirement would change what information importers need to collect during supplier onboarding, and how that information is maintained inside compliance and customs systems going forward.
4. Technology Could Play a Far Larger Role in Origin Verification
CBP is seeking input on artificial intelligence and other technology tools that could help verify the origin of imported goods and trace supply chains before merchandise is released into U.S. commerce. Areas of interest include digital supply chain mapping, product-level traceability, tamper-resistant documentation, and integration with the Automated Commercial Environment (ACE) and Partner Government Agency data exchanges.
Illegal transshipment is a central concern here. Greater visibility into where goods are produced, processed and shipped would give CBP additional tools to identify attempts to circumvent tariffs by routing goods through third countries, placing added importance on understanding not just direct suppliers but the full upstream manufacturing chain.
5. CTPAT Requirements Could Also Evolve
CBP is evaluating whether Customs Trade Partnership Against Terrorism (CTPAT) participants should be required to adopt enhanced supply chain tracing technologies, and whether companies that voluntarily provide greater transparency should receive additional program benefits. The agency is also asking whether CTPAT’s minimum security criteria should expand to address cybersecurity and logistics platform security, including potential restrictions on the use of foreign-controlled logistics platforms identified as security risks.
Any changes here could affect the compliance investments companies make in exchange for CTPAT participation benefits, and could introduce new costs tied to vetting and transitioning away from certain logistics platforms.
What Importers Should Be Thinking About Now
There is no immediate filing change resulting from this notice, and importers do not need to begin submitting any of these additional data elements today. However, the breadth and direction of CBP’s questions make this a rulemaking worth engaging with directly, not simply monitoring from the sidelines.
Companies should begin evaluating:
- How much visibility they currently have beyond their direct, first-tier suppliers
- What foreign export records they can realistically obtain today, and from whom
- How manufacturers and other supply chain parties are identified within their own systems
- Whether current technology and data systems could support more detailed traceability if required
- What operational, technology or cost challenges should be raised with CBP directly during the comment period
Industry Comments Are Due December 1, 2026
CBP is accepting public comments on the ANPRM through December 1, 2026. The agency is specifically seeking input on current business practices, technological capabilities, implementation considerations, potential costs and benefits, and how additional disclosure requirements could affect importers and other parties throughout the supply chain.
The final scope of any future rule has not been determined. But given the scale of what CBP is considering, and the direct line back to Executive Order 14411, Alba encourages importers to treat this comment period as a genuine opportunity to shape a rule that could touch nearly every import transaction for years to come.
Alba Is Here to Help
Alba Wheels Up will continue monitoring this rulemaking closely and will provide updates as CBP’s approach develops. Importers with questions about how these concepts could affect their current compliance programs, or who want help preparing comments for CBP’s consideration, should contact the Alba team to discuss their operations and supply chain visibility.
Have questions about the ANPRM or your compliance program?
References
CBP.gov – CBP announces advance notice of proposed rulemaking to enhance supply chain visibility
