Executive summary

On 2 September 2026, United States (US) Customs and Border Protection (CBP) published an Advance Notice of Proposed Rulemaking titled "Heightened Import Disclosures for Supply Chain Visibility." The notice is the first step toward the implementation of Section 3 of Executive Order 14411, titled "Strengthening Customs Enforcement," which directed the Department of Homeland Security and CBP to establish heightened import disclosure requirements and obtain additional information regarding foreign exporters, supply chains and imported merchandise.

Consistent with the Executive Order, CBP is evaluating measures that would require disclosure of detailed supply chain information, collection of foreign export documentation and expanded identification of the parties involved in the manufacture, production, movement and exportation of goods imported into the United States. The notice does not impose new obligations. Rather, it signals the data collection, recordkeeping and compliance requirements that CBP may pursue in a future proposed rule, and the breadth of the questions posed suggests that changes could reach importers, brokers, manufacturers, foreign suppliers and logistics providers across a wide range of industries.

For more on Executive Order 14411, see EY Global Tax Alert, US President issues Executive Order strengthening customs enforcement; enhanced importer requirements, disclosure obligations and penalties announced, dated 4 June 2026.

Key proposals

Foreign export documentation

A central focus of the notice is whether importers should be required to obtain, retain and potentially submit the documentation that foreign exporters provide to their own customs authorities before shipping goods to the United States. CBP indicates that these records could assist in verifying entry and entry summary information and in detecting discrepancies, such as dual invoicing, that may point to valuation, classification, origin or other compliance concerns. The documentation contemplated includes:

• Foreign export declarations, which may show declared value, classification, country of origin and quantity
• Commercial invoices reflecting the transaction value declared to the foreign customs authority
• Packing lists verifying the contents, weight and packaging of the shipment
• Certificates of origin substantiating the origin of the goods
• Export licenses or permits required for controlled, restricted or dual-use goods
• Transportation documents, such as bills of lading and air waybills, filed as part of the foreign export manifest

CBP is seeking input on (1) the scope of the requirements, (2) whether records should be transmitted at entry or maintained as a recordkeeping obligation, (3) how long records should be retained and (4) how importers would reconcile differences between the value, quantity or classification reported to a foreign authority and the information declared to CBP. The notice also raises national security considerations, asking whether particular products, industries or countries should be subject to enhanced documentation requirements, and it seeks feedback on the authentication, translation and verification of foreign records.

Identification of supply chain parties

The notice further examines whether CBP should expand the information collected to identify the entities involved in international supply chains. CBP notes that the current Manufacturer Identification Code (MID) provides limited identifying information, is not always unique and available early enough in the entry process to be useful, and it asks whether the MID should be redefined or replaced. Among the questions posed, CBP is considering whether it should:

• Collect full identifying data, such as company name and physical address, for manufacturers, producers, shippers and exporters, rather than relying on the current MID formula
• Require identifying information to be provided at entry, entry summary or both, and potentially on the manifest
• Identify additional parties, such as online marketplaces, ultimate delivery parties and logistics platform providers
• Expand use of Global Business Identifiers, including the Legal Entity Identifier, the Data Universal Numbering System number and the Global Location Number, building on CBP's ongoing test program.

Expanding the Customs Trade Partnership Against Terrorism program requirements and benefits

The notice also identifies the Customs Trade Partnership Against Terrorism (CTPAT) program as an area for potential enhancement. CTPAT is currently a voluntary partnership that extends benefits to members meeting or exceeding the program's security requirements. CBP is seeking input on whether there should be heightened requirements for participation as well as if there should be additional benefits associated with participation in the program. Heightened requirements under consideration for CTPAT include:

• The required use of, and greater visibility into, supply chain traceability solutions
• Expanded minimum security criteria addressing cybersecurity and data integrity, including a prohibition on the use of platforms identified as a security risk

The notice suggests that the primary benefit to CTPAT-validated users would be different documentation requirements, though CBP requests comments from importers on other potential options.

What this means for businesses

Although the notice imposes no immediate obligations, it reflects a continued shift toward greater importer accountability and supply chain transparency. If adopted, the measures under consideration could substantially increase the amount of information that importers must collect, validate and retain in support of their filings. Importers will need to assess (1) their ability to access foreign export documentation generated by overseas suppliers, (2) whether their contracts secure that cooperation and (3) system capabilities to capture and retain the data in a form suitable for CBP review. The proposals also carry implications for reasonable care procedures, supply chain due diligence and technology investment, and may present challenges for companies with complex sourcing structures or limited visibility into upstream suppliers.

Companies importing goods subject to heightened origin, transshipment, forced labor or customs valuation scrutiny should closely monitor for updates related to this rulemaking, as the use of foreign export data to validate US entry information could increase exposure to customs enforcement actions.

Key dates

Comments must be received on or before 1 December 2026 and may be submitted through the Federal eRulemaking Portal at regulations.gov, identified by docket number USCBP-2026—1058. CBP has indicated that the comments received may be used to develop a Notice of Proposed Rulemaking establishing specific regulatory requirements.

Actions to consider

Affected entities should, depending on their particular circumstances, consider the following actions:

• Consider participating in the comment process to provide CBP with practical feedback on implementation timelines, compliance burdens and supply chain impacts.
• Review current processes for obtaining and retaining export documentation from foreign suppliers and assess whether existing supplier contracts secure adequate access to those records.
• Evaluate the availability and quality of manufacturer, producer, exporter and other supply-chain-party data maintained within existing customs compliance systems.
• Identify potential operational, legal and technological challenges associated with capturing, reconciling and retaining the information contemplated by the notice.
• Assess reasonable care and internal control procedures for reconciling foreign export data against US entry and entry summary filings.