Executive Summary
CBP’s September 2 advance notice asks whether future regulations should require foreign export documents, more information about supply-chain parties, and new tracing data for imported goods.
The notice does not itself change duties, entry requirements, filing fields, or release conditions.
Comments must be received by December 1, 2026, through the Federal eRulemaking Portal, identified with docket USCBP-2026-1058.
Importers, brokers, carriers, and other supply-chain participants can use comments to address feasibility, costs, data accuracy, implementation timing, and potential differences for small entities or critical goods.
CBP’s supply chain disclosure proposal asks whether future regulations should require additional foreign export documentation, supply-chain party identifiers, and tracing information for imported goods. In its September 2, 2026, advance notice of proposed rulemaking, CBP invites comments by December 1, 2026. The notice seeks input for possible later rulemaking. It does not itself change a duty, entry requirement, filing field, or condition for release.
What Does CBP’s Supply Chain Notice Cover?
CBP is considering ways to increase visibility into the parties and activities involved in manufacturing, producing, moving, and exporting goods imported into the United States. Its stated enforcement aim is to detect and interdict illicit imports, including goods allegedly transshipped to evade U.S. customs and trade laws. The notice asks whether requirements should apply to all imported goods and what benefits they could provide.
No broad requirement or exemption is established. CBP specifically asks whether any future requirements should be phased by entry type, commodity, country, or transportation mode, and whether critical medical products and their key inputs warrant special consideration. It also invites views on different timelines for small entities, foreign importers, CTPAT participants, and high-volume filers. These are questions for commenters, not existing exceptions or compliance obligations.
What Foreign Export Documents Could CBP Require?
CBP asks whether importers of record should provide documents submitted to foreign customs or export authorities, and whether those records should accompany an entry or instead be retained and furnished when requested. Examples in the notice include export declarations, commercial invoices, packing lists, certificates of origin, export licenses or permits, and transport documents such as bills of lading or air waybills. The notice also asks whether documents from foreign government export agencies that are not formal customs authorities should be covered.
The questions address practical problems as well as document types. CBP seeks comment on access to records, retention periods, non-English documents, the ability to confirm a document is the exact version submitted abroad, and possible verification with foreign customs administrations. It also asks how to reconcile differences between foreign export data and U.S. entry information, including differences in value, quantity, or classification. These proposals remain under consideration, not requirements in force.
Could CBP Change Party IDs and Supply Chain Tracing?
The notice asks whether CBP should supplement or replace the manufacturer or shipper identification code, or MID, with actual identifying information such as company name and physical address, other business identifiers, or separate data for manufacturers, shippers, and exporters. CBP says the current MID can provide limited information, may not identify the party relevant to enforcement, and may not be unique or consistent over time. Its MID instructions describe how the code is derived from name, address, and country-of-origin information.
CBP also asks about its voluntary Global Business Identifier test, including whether identifiers should be submitted at entry, entry summary, or both. The notice identifies four test identifiers: D-U-N-S, Global Location Number, Legal Entity Identifier, and Altana ID. It separately seeks views on technology for tracing supply chains and production methods, possible use of artificial intelligence, and whether CTPAT requirements or benefits should change. CTPAT is described as voluntary; the notice does not make tracing technology mandatory for participants.
When Are CBP Supply Chain Comments Due?
- June 3, 2026: The President signed Executive Order 14411, which directs steps toward heightened import disclosures, as described in the notice.
- September 2, 2026: CBP published the advance notice.
- December 1, 2026: Comments must be received on or before this date. Submit through the Federal eRulemaking Portal and identify docket USCBP-2026-1058.
How Should Importers and Brokers Prepare Comments?
Identify affected data flows. Map which parties hold foreign export documents, manufacturer and shipper details, business identifiers, and supply-chain tracing records, and when those records become available.
Answer the questions that affect your operations. Address document access and retention, data accuracy, confidentiality, foreign-language records, technology, and any differences between foreign export data and U.S. entry information. Refer to the specific question numbers in the notice.
Support cost and timing claims. Describe current practices and technology, explain effects on your company or clientele, and provide data supporting cost, benefit, or implementation estimates. CBP asks commenters to provide enough information to reproduce quantitative calculations and to discuss effects on small businesses and critical goods.
What Is Not Decided in CBP’s Supply Chain Notice?
The notice does not decide whether any of the proposed disclosures will be required, which parties would submit or retain records, what data fields or technologies would be accepted, or whether requirements would differ by goods, filer, or CTPAT status. CBP says comments may inform a later notice of proposed rulemaking. Any new obligations would require further action; the advance notice itself creates none.
The notice also leaves open how CBP would address confidentiality, document authenticity, data discrepancies, implementation costs, and supply disruptions. Comments can propose workable standards and exemptions, but respondents should distinguish current practices from the requirements they recommend.
Sources
- Heightened Import Disclosures for Supply Chain Visibility, Federal Register
- 3550-055_3_0.pdf, www.cbp.gov
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