Supply Chain

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. 

FDA Update: Increased Cosmetics Oversight Under MoCRA 

The U.S. Food and Drug Administration (FDA) recently published a Voices blog, highlighting the progress the agency has made in implementing the Modernization of Cosmetics Regulation Act of 2022 (MoCRA).

MoCRA Background

MoCRA instituted a sweeping overhaul of federal cosmetics regulation that significantly expanded the FDA’s authority over the cosmetics and personal care industry. The FDA views MoCRA as the most substantial expansion of FDA cosmetics oversight since the Federal Food, Drug, and Cosmetic Act was enacted in 1938.

MoCRA was signed into law in December 2022 and introduced a broad range of new regulatory requirements aimed at improving consumer safety, increasing transparency, and strengthening FDA enforcement capabilities. The law applies to a wide array of cosmetic products, including makeup, skincare, fragrances, shampoos, and other personal care items used daily by consumers.

Implementation Update

In its recent update, the FDA highlighted several ways the legislation is already reshaping the cosmetics industry. One of the most significant developments is the agency’s increased visibility into cosmetic manufacturing and ingredient use through mandatory facility registration and product listing requirements. The FDA reported:

  • 15,000 unique, active cosmetic product facility registrations
  • Over 1 million unique, active cosmetic product listings.
  • adverse events reported by industry increased by more than threefold

Before MoCRA, the FDA received just 5,176 cosmetic establishment registrations and 35,102 cosmetic product listings through the Voluntary Cosmetic Registration Program. This […]

Trade-Based Money Laundering Red Flags: What CBP’s New CTPAT AML Guidance Means for Importers

As global supply chains grow more complex, regulators are increasingly focused on how legitimate trade can be exploited to move illicit funds. In July 2025, U.S. Customs and Border Protection (CBP) reinforced this focus by issuing updated CTPAT Warning Indicators for Trade‑Based Money Laundering (TBML) and Terrorist Financing.  

Although the target audience for this guidance is CTPAT participants, all importers, logistics providers, and financial institutions can be implicated in TBML schemes if they don’t proactively screen for such activity in their supply chains. The Department of the Treasury released its 2026 National Money Laundering Assessment, which further highlights how TBML schemes are used to facilitate the transfer of illicit proceeds. Any business engaged in international trade that is unaware of how TBML works or fails to screen for such practices is exposed to engaging in TBML. 

CBP’s message is simple: trade compliance and anti‑money laundering (AML) expectations are converging, and companies that fail to adapt face growing regulatory, operational, and reputational risk. CBP also emphasizes that TBML rarely presents as a single red flag; instead, it emerges through patterns that deserve closer scrutiny and informed judgment.  

Warning Indicators 

One of the most significant risk areas identified by CBP involves pricing and payment anomalies that defy commercial logic. Persistent over‑ or under‑invoicing, unexplained invoice changes, or pricing that is misaligned with market norms may indicate that a trade […]

U.S. Department of Labor Introduces New Tools to Support Supply Chain Integrity and Address Unfair Foreign Labor Practices

On April 8, 2026, the U.S. Department of Labor (DOL) announced the launch of several tools to empower U.S. companies to strengthen their supply chains and defend against unfair competition stemming from overseas labor abuses.

Self-Assessment Tools

DOL launched four voluntary self-assessment tools that provide practical, user-friendly guidance to help companies map supply-chain risks and evaluate labor practices. The tools can also guide companies in taking steps to ensure alignment with U.S. forced labor laws and strengthen supply chains that support American workers and American industry.

The new tools are: 

  • LaborShield: A mobile app that features information on egregious labor violations in over 145 countries (formerly the Sweat and Toil app).
  • ImportWatch: A resource that brings together the department’s labor abuse research with U.S. import data from the U.S. Census Bureau to produce a red-flag list of all high-risk goods for U.S. importers.
  • SourcingStrong: A tool to help U.S. businesses build strong labor due diligence systems to identify and manage risk in their supply chains.
  • Supply Chain Traceability Portal: The portal provides visibility across supply chains and beyond the first tier to expose where exploitative labor hides.

Announcement Insights 

Diaz Trade Law was in attendance at the launch event in Washington, D.C. – hosted by the DOL and […]

New Executive Order Adjusting Imports of Aluminum, Steel, and Copper into the United States

Authors:

Jennifer Diaz, President, Diaz Trade Law
Amber Pirson, Attorney, Diaz Trade Law

On April 2, 2026, the President issued a proclamation strengthening Section 232 actions to adjust imports of aluminum, steel, and copper, continuing to cite national security concerns and the need to reinforce domestic metals industries. 

Key elements include: a tiered tariff structure and some products exempt from Sec. 232 tariffs, effective at 12:01 am on April 6, 2026; and manufacturing drawback claims.  

Generally, tariffs will be assessed to the full value of imported products, “regardless of their metal content,” with reduced rates for certain products from the United Kingdom (UK) and the same 200% ad valorem duty for subject metal articles from Russia. 

  • Aluminum and steel articles, most copper articles, and certain derivative articles of aluminum and steel…  
    • 50%, unless either the 25% or 10% rates listed below can apply. 
      • 25% for UK products, the aluminum content of which is composed entirely of aluminum that was smelted or most recently cast in the UK, or the steel content of which is composed entirely of steel that was melted and poured in the UK. 
      • 10% for derivative articles, steel or copper content, when the metal content was smelted and cast in the U.S. 
  • For certain copper and […]
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