What CBP’s New Supply Chain Visibility Proposal Means for Importers
On September 2, 2026, U.S. Customs and Border Protection (CBP) issued a landmark Advance Notice of Proposed Rulemaking (ANPRM) under Docket No. USCBP-2026-1058. The notice directly supports Executive Order 14411, “Strengthening Customs Enforcement,” issued in June 2026. This proposal marks a fundamental evolution in customs enforcement. CBP is moving aggressively beyond basic entry summaries toward a comprehensive “Know Your Supply Chain” mandate. For trade compliance professionals and importers of record, the agency is signaling that superficial vendor oversight will no longer suffice.
The ANPRM lays out 64 specific questions spanning several core areas, the first of which is mandatory foreign export documentation. CBP is evaluating whether to require Importers of Record to obtain, retain, and potentially submit documentation filed with foreign customs authorities, such as foreign export declarations, foreign commercial invoices, and packing lists. The primary goal is cross-referencing foreign filings against U.S. entries to expose valuation discrepancies, improper classification, and illegal transshipments. The ANPRM also focuses on overhauling or replacing the Manufacturer Identification Code (MID). Recognizing that traditional MIDs provide minimal actionable intelligence and are often generated too late in the entry process, CBP is exploring replacing or supplementing them with Global Business Identifiers (GBIs) or ultimate recipient declarations. The final core area in the ANPRM regards supply chain tracing technologies. CBP is soliciting feedback on private-sector tracing platforms, including AI, digital credentials, and tamper-proof tracking, in order to verify country of origin, map tier-N suppliers, and prevent illegal rerouting through third countries.
These requirements are not yet binding law because this is still only a “Proposed Rulemaking”, making this the most critical window for strategic preparation. Importers are recommended to take action while there are still plenty of options and time before this ruling could potentially take effect. First, importers should submit data-backed public comments before the public comment period closes on December 1, 2026. Rather than waiting for a formal Notice of Proposed Rulemaking (NPRM) where requirements become rigid, importers must submit feedback now. Highlight operational friction points, such as foreign privacy law restrictions, commercial confidentiality around foreign export filings, or the economic impact on small-to-medium enterprises. After submitting a public comment, importers should conduct a foreign export data reconciliation audit. It is important to test your supply chain’s current readiness by requesting foreign export declarations from your top overseas suppliers. Reconcile foreign export values, weights, and tariff classifications against your domestic entry filings (CBP Form 7501). Identify and resolve systemic discrepancies before CBP makes this verification mandatory. It is also important to improve records and tracking of suppliers, as relying on direct vendors is no longer a sustainable compliance option. Evaluate supply chain visibility tools capable of mapping raw material suppliers, secondary processors, and intermediate sub-assemblers. Lastly, importers should review supplier contracts and NDAs. Update vendor agreements to include mandatory clauses requiring foreign manufacturers to furnish export declarations, packing lists, and origin verification materials within set timeframes upon request.
CBP’s message is unequivocal: the burden of supply chain transparency rests on the importer. Importers who actively participate in the comment process and audit their upstream data today will remain resilient as heightened disclosure standards become mandatory. However, this can be a difficult, confusing, and time-consuming process. At Liang + Mooney PLLC, we are here to offer assistance at every step of the importing compliance process. If you reach out while there is still substantial time before the deadline for comments on December 1st, we will be able to draft and file comments for you or your business. Contact us today to learn more about personalized solutions for all of your importing needs.