CBP Wants Your Foreign Export Documents: What the Supply Chain Visibility ANPRM Means for Importers
On September 2, 2026, U.S. Customs and Border Protection published an advance notice of proposed rulemaking that would fundamentally change what importers must know, keep, and disclose about the parties behind every shipment entering the United States. The notice implements Section 3 of Executive Order 14411 and covers foreign export documentation, replacement of the manufacturer identification code, foreign tax and global business identifiers, supply chain tracing technology, and expanded CTPAT requirements. Comments are due December 1, 2026, and the questions CBP is asking tell importers exactly where enforcement is headed.
KEY TAKEAWAYS
- CBP published an advance notice of proposed rulemaking on September 2, 2026 (Docket No. USCBP-2026-1058) that would give the agency visibility into every party in an import supply chain, from the foreign factory to the final delivery address.
- The headline proposal: importers of record may be required to obtain, retain, and submit the export declaration, invoice, packing list, and other documents their foreign supplier filed with its own customs authority. CBP says the purpose is to catch dual invoicing and undervaluation.
