U.S. Customs and Border Protection is accepting comments through Dec. 1 on possible changes to its regulations designed to give CBP greater visibility into the supply chains of imported goods. This is one of many actions CBP is expected to pursue to implement a June 2026 executive order directing a broad tightening of U.S. customs enforcement measures.
Overview
CBP is considering (1) new requirements enhancing visibility into the parties involved in the importation of goods, (2) integrating innovative technical solutions for the tracing of supply chains of those goods, and (3) collecting documentation that foreign exporters are required to submit to foreign customs authorities. The intent of these proposals is “to more effectively detect and interdict illicit importations, especially those that are illegally transshipped to evade compliance with U.S. customs and trade laws.”
For importers, these changes could mean expanded recordkeeping obligations, new data collection and validation requirements, greater scrutiny of country-of-origin claims, more responsibility for obtaining information from foreign suppliers, and increased use of digital traceability tools and identifiers.
With respect to the proposals outlined below, CBP is interested in comments on issues like (1) whether the requirements should be phased in by entry type, commodity, country, or mode of transportation, (2) whether different implementation timelines should apply to small entities, foreign importers, CTPAT participants, or high-volume filers, (3) whether any of the proposals are suited to voluntary test programs, (4) what implementation periods would be necessary for affected parties to comply, (5) anticipated effects on compliance with existing legal and regulatory requirements for importation, and (6) potential costs and benefits.
Details
Foreign Export Documentation
CBP is considering requiring importers of record (or possibly other entities) to submit foreign export documentation such as export declarations, commercial invoices, packing lists, certificates of origin, export licenses and permits, and bills of lading and other transport documents. CBP could compare this information with U.S. import filings to detect undervaluation, misclassification, transshipment, dual invoicing, and other customs violations.
CBP poses nearly two dozen questions regarding this potential requirement on issues such as how broad it should be, whether documentation should be required as part of entry or entry summary filing, challenges for importers in obtaining the documentation, and tools importers should use to identify discrepancies on the export documentation and the entry or entry summary.
CBP is also considering a framework under which certain products or sectors deemed to pose a high or grave national security risk could be subject to heightened documentation requirements as a condition of entry.
Supply Chain Party Disclosure
CBP believes the current manufacturer identification code provides incomplete and inconsistent information and is therefore considering redefining or replacing the MID and/or requiring more detailed identification of parties involved in the supply chain, including manufacturers, producers, shippers, exporters, and sellers. Issues under consideration include when identifiers should be provided to CBP, what parties should be identified, and what consequences importers should face for not providing accurate identifiers.
Alternatively, CBP is already conducting a test of global business identifiers that could replace the MID and provide more pertinent and precise information about other entities in the supply chain. This test permits the transmission of four identifiers: DUNS numbers, legal entity identifiers, global location numbers, and Altana IDs. CBP is inviting input on a number of issues concerning GBIs, including the challenges for businesses in obtaining them and for importers in disclosing them, the feasibility of requiring them at entry, and whether they should be replaced by product-level identifiers for each shipment.
Entry
CBP poses several questions about the timing of filing entries, including whether requiring entry to be filed sooner would benefit CBP in reviewing supply chain documentation and determining the admissibility of goods more quickly; how an earlier filing deadline would affect data availability, data accuracy, and broker and carrier operations; and what costs would result from an earlier filing deadline.
Supply Chain Tracing
CBP is considering ways to incorporate advanced supply chain tracing tools as a means to improve detection of illegal transshipment before goods are released. Such tools may include AI-enabled supply chain mapping, product-level traceability systems, raw material origin verification technologies, digital credentials and tamper-resistant records, and integration with ACE and other government trade systems.
CTPAT
For participants in the Customs Trade Partnership Against Terrorism, CBP is considering (1) requiring enhanced supply chain traceability technologies, (2) requiring CBP visibility into those systems, (3) adding cybersecurity and data integrity requirements, (4) restricting the use of certain foreign-controlled logistics platforms viewed as security risks, and (5) providing additional benefits to companies that share supply chain visibility data with CBP.
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