U.S. Customs and Border Protection (CBP) placed an advance notice of proposed rulemaking (ANPRM) on public inspection on September 1, 2026, titled "Heightened Import Disclosures for Supply Chain Visibility." It publishes in the Federal Register on September 2, 2026 under docket USCBP-2026-1058 and RIN 1685-AA47. Nothing in it is a requirement — an ANPRM is CBP asking questions before it drafts a rule — but the questions are pointed, and the biggest one is whether importers of record should have to hand CBP the paperwork their foreign supplier filed with that supplier's own customs authority.
What an ANPRM Is, and What It Is Not
An advance notice of proposed rulemaking is the earliest formal stage of a rulemaking. CBP is not proposing regulatory text. It is describing what it is considering and asking the trade community to answer questions before anything is drafted. The document itself is explicit about the sequence: "The comments received in response to this ANPRM will be used, potentially, to draft a Notice of Proposed Rulemaking (NPRM), which would propose regulations to implement these proposals."
So there are at least two more gates after this one. A notice of proposed rulemaking (NPRM) would publish actual regulatory language with its own comment period, and only a final rule after that would carry an effective date and a compliance obligation. As of September 1, 2026, none of that exists. No importer has a new filing duty because of this notice.
That is worth stating plainly, because ANPRMs get reported as though they were rules. What this document does change today is your window to influence the outcome. The notice identifies 19 CFR parts 141, 142, 143, and 163 as the parts CBP would amend — entry, entry filing, ABI (Automated Broker Interface, the CBP-certified channel filers use to transmit entries) and broker requirements, and recordkeeping. That is the machinery of every entry you file.
Where This Came From: Executive Order 14411
The ANPRM implements Section 3 of Executive Order 14411, "Strengthening Customs Enforcement," signed June 3, 2026 and published at 91 FR 35125 on June 10, 2026. CBP describes the directive in two parts.
Section 3(a) "instructs the Secretary of Homeland Security (Secretary) to take steps to require the disclosure of certain foreign tax and global business identifiers, and detailed information about the supply chain and production methods of goods imported into the United States." Section 3(b) "directs the Secretary to take steps to mandate the submission of 'any documentation or information that the foreign exporter was required to submit to the foreign customs administration prior to exporting to the United States.'"
Read those together and you get the shape of the whole notice. One half is about identifying the parties in your supply chain with something more reliable than what CBP collects today. The other half is about seeing the export side of the transaction — what your supplier told their government, so CBP can compare it to what you told ours.
The Foreign Export Documentation Question
This is the part with the most operational weight. CBP lists six categories of foreign export documentation it is considering:
- "Export Declarations made by the foreign exporter to the foreign customs authority"
- "Commercial Invoices showing the transaction value declared to the foreign customs authority"
- "Packing Lists to verify the contents, weight, and packaging of the shipment"
- "Certificates of Origin submitted to the foreign customs authority"
- "Export Licenses or Permits required for the export of controlled, restricted, or dual-use goods"
- "Transport Documents (e.g., Bill of Lading, Air Waybill) that were required as part of the export manifest filing"
The stated purpose is comparison. CBP says it "is considering whether foreign export documentation may be helpful to CBP in verifying and reconciling entry and entry summary information, and in detecting discrepancies that could indicate violations of U.S. customs and trade laws, such as dual-invoicing." Dual-invoicing — one invoice value shown to the export authority, a different one shown to CBP — is precisely the pattern a side-by-side comparison surfaces. The notice frames illegal transshipment detection the same way.
The scope question is open. CBP's first question asks whether it should require the importer of record to submit foreign export documentation "for all goods imported into the United States," and a later question asks about exemptions to that general rule. The document does not propose a value threshold, and it does not carve out low-value shipments. If you are assuming small entries would fall outside this, the notice gives you no basis for that assumption — which is itself a reason to comment.
Filing Requirement or Recordkeeping Requirement?
The single question that most determines the burden is how the documentation would be delivered. CBP asks it directly: "Under 19 U.S.C. 1508, importers are responsible for maintaining records related to their activities involving importation of goods. Should foreign export documentation be required to be transmitted to CBP as part of an entry or entry summary filing, or should foreign export documentation be a recordkeeping requirement?"
Those are very different worlds. A transmission requirement at entry or entry summary means every shipment waits on documents from a foreign party before it can be filed — a lead-time problem, not a paperwork problem. A recordkeeping requirement under 19 U.S.C. 1508 means you gather and hold the documents, and produce them when CBP asks. CBP also floats a middle path, asking whether it should "randomize requiring the submission of foreign export documentation, both to ensure compliance with any general records retention requirement and to assess the extent of non-compliance with other U.S. law."
Retention length is open too. CBP asks, in effect, how long these records should be kept while "minimizing compliance burdens (to the extent practicable)." It also asks whether the existing duty of reasonable care is the right standard: "If the importer of record is required to submit the records to CBP, is the duty of reasonable care an appropriate standard for the importer to assess and ensure the accuracy of the documentation before submitting it to CBP?" That question matters more than it looks. Reasonable care is the standard you are already held to on your own entry data. Extending it to a document a third party prepared in another jurisdiction is a real expansion of what you are answerable for.
CBP does ask about the cost side. It asks what challenges importers face obtaining and retaining foreign export records, what the current lead time is to get those documents from foreign suppliers, and what costs would be incurred if they had to be provided. It also asks whether CTPAT-validated importers should face different documentation requirements. (CTPAT is the Customs Trade Partnership Against Terrorism, CBP's voluntary supply chain security program.)
When Your Entry and Their Export Declaration Disagree
Assume for a moment the documents get collected. The next problem is that the two filings will not always match, and CBP knows it. The notice asks: "What internal controls and reconciliation processes should importers implement to identify discrepancies between the information on foreign export documentation and the entry or entry summary filed with CBP?" — and, where a discrepancy exists, what evidence the importer should provide "to justify the difference."
Plenty of discrepancies are legitimate. Transaction value for U.S. customs purposes is built under 19 U.S.C. 1401a and does not have to equal whatever number the exporter declared to their own authority for their own reasons. Quantities shift between the export declaration and the shipped container. Classification is jurisdiction-specific below the six-digit level; the Harmonized System (HS) is international to six digits, and the U.S. Harmonized Tariff Schedule (HTSUS) digits beyond that have no foreign counterpart. A well-run import program can explain each of those.
The risk is not that discrepancies exist. It is that you find out about them from CBP instead of from your own file. If you have never compared a supplier's export declaration against your own entry summary, you do not currently know how often yours differ or why. Our customs valuation guide covers how transaction value is actually built, and the HTS classification guide covers documenting a classification decision so it survives a question.
CBP also asks how to handle documents that are not in English — specifically whether it "should also require data fields for specific information to be submitted in English, in addition to providing the accompanying underlying documentation in the foreign language." If your suppliers file in Mandarin, Vietnamese, or Portuguese, that question is directed at you, and it is one where a concrete answer from an actual importer is worth more than a trade association's generality.
Identifying the Parties: MID and Global Business Identifiers
The second half of the notice is about knowing who is who. CBP is candid about the limits of the Manufacturer Identification Code (MID), the code constructed from a manufacturer's or shipper's name, address, and country. The notice states that "the MID is based upon the manufacturer or shipper name, address, and country of origin, and this data can change over time and/or result in the same MID for multiple entities." CBP asks whether it should abandon the formula in favor of "actual identifying data, such as full company name and physical address or other business identifier," when that identifier should be provided, whether importers use the MID for their own business purposes, and what the consequences should be for inaccurate MID data.
The alternative CBP points to is the Global Business Identifier (GBI). The GBI test, announced at 87 FR 74157 (December 2, 2022) and modified since — most recently at 90 FR 38479 (August 8, 2025) — permits four identifiers: the Data Universal Numbering System number (D-U-N-S), the Global Location Number (GLN), the Legal Entity Identifier (LEI), and the Altana ID. CBP asks whether it is feasible for importers or their brokers "to obtain and disclose to CBP entity-level foreign tax and global business identifiers for the manufacturer, shipper, and/or seller," whether GBIs should be collected at entry, entry summary, or both, and whether disclosure should happen prior to arrival.
There is a notable alternative in the notice. CBP asks whether a product-level identifier would be more feasible than an entity-level one — "a single product-level identifier for each shipment that provides detailed information about the imported good's supply chain and production methods, such as the manufacturer's product identifier (e.g., model or style number)." That is a materially different compliance architecture, and which way it goes will depend partly on what importers say now.
Tracing Technology and CTPAT
The last group of questions is about tooling. CBP asks what supply chain visibility technologies industry already uses and how their accuracy is verified, what role artificial intelligence plays in them, how they could integrate with the Automated Commercial Environment (ACE) — the system that processes essentially all U.S. customs entries — and what technology exists "to verify the origin of raw materials, and bridge the 'visibility gap' between suppliers and raw material sources."
On CTPAT, CBP asks whether all partners should be required to use enhanced tracing technologies or only certain tiers, whether partners should make that tracing visible to CBP, what operational benefits should accrue in return, and whether the minimum security criteria should expand to include cybersecurity requirements and "a prohibition on the use of covered logistics platforms identified as a security risk." It also asks for cost estimates for transitioning away from such platforms.
If you are already doing supplier mapping for forced-labor reasons, much of this will feel familiar — the tracing infrastructure the supply chain due diligence guide describes is the same infrastructure these questions are circling.
What To Actually Do Before December 1, 2026
Two things, and they are separate.
Comment. The filed version of the notice carries the standard bracketed placeholder — comments due 90 days after publication. With publication set for September 2, 2026, that lands on December 1, 2026; confirm the exact date against the published version when it appears. Comments go to regulations.gov under docket number USCBP-2026-1058. The notice also lists a CBP mailbox for the rulemaking, supplychainvisibility@cbp.dhs.gov, and names Brandon Lord and Salvatore Ingrassia as agency contacts. The document contains 64 numbered questions; you do not have to answer all of them. Answering three with real lead-time numbers from your own supplier base is more useful to the record than a general objection.
Start the habit the questions imply. Regardless of what any future rule says, there is a gap worth closing on your own account: most importers have never seen what their supplier declared on the export side. Pick a handful of representative shipments and ask for the export declaration and the invoice presented to the foreign customs authority. Compare declared value, quantity, and classification against your own entry summary. If they match, you have learned your file is clean. If they do not, you have found out on your terms, with time to understand why, rather than during a CBP request for information.
That exercise also tells you something a rule never will — which suppliers can produce these documents at all, and how long they take. That is the single hardest number to estimate from the outside, and it is exactly what CBP is asking for.
No. This is an advance notice of proposed rulemaking, which means CBP is asking questions, not imposing requirements. A notice of proposed rulemaking with actual regulatory text would have to come first, followed by a final rule with an effective date, before any obligation attaches. Collecting some export documents now is a good idea on its own merits, but it is not compliance with anything yet.
When are comments due, and where do they go?
The notice sets comments due 90 days after Federal Register publication. Publication is September 2, 2026, which puts the deadline at December 1, 2026 — verify against the published version. Submit through regulations.gov under docket USCBP-2026-1058. CBP also lists supplychainvisibility@cbp.dhs.gov in the notice for questions about the rulemaking.
Would this apply to every shipment, or only high-risk ones?
That is open. CBP's opening question asks whether the importer of record should submit foreign export documentation "for all goods imported into the United States," and a separate question asks what exemptions should be made. The notice proposes no value threshold and does not exempt low-value entries. It does ask whether CTPAT-validated importers should face different requirements.
What happens if my entry summary does not match my supplier's export declaration?
Nothing automatic, because no rule requires the comparison today. Going forward, CBP is asking what internal controls importers should use to catch such discrepancies and what evidence should justify a difference. Differences are often legitimate — U.S. transaction value is built under its own statute, and classification below six digits is jurisdiction-specific — but they are much easier to explain when you identified them yourself and documented the reason at the time.
Get Ahead of the Comment Window
The most useful thing an importer can do with this notice is answer it with real numbers, and the second most useful is to find out what their own supplier documentation actually looks like before someone else asks. Strix works four ways: we clear your entries as a licensed broker, consult on which of the ANPRM's questions actually touch your program and what a comment should say, help you comply through classification, valuation, and recordkeeping review under compliance consulting, and automate the filing itself with ABI-certified self-filing software. If you want a read on how this ANPRM intersects your supply chain — or help getting a comment on the record before December 1 — talk to our team.