On September 2, 2026, U.S. Customs and Border Protection (CBP) issued an advance notice of proposed rulemaking (Notice), titled Heightened Import Disclosures for Supply Chain Visibility (Docket No. USCBP-2026-1058; RIN 1685-AA47).
The Notice, issued as part of Executive Order 14411, “Strengthening Customs Enforcement,” aims to enhance transparency across supply chains and strengthen efforts to detect and prevent illicit imports, including illegal transshipment. To achieve this, CBP is exploring significant changes to import filing and record keeping processes.
CBP indicated in its Notice that it will focus on key areas which include:
- Enhanced Documentation Requirements. Importers may be required to obtain and submit foreign export documentation—such as export declarations, commercial invoices, packing lists, certificates of origin, export licenses, and transport documents—that foreign exporters already file with their own customs authorities. This would allow CBP to cross-check U.S. entry filings against foreign data to detect discrepancies, such as dual-invoicing. CBP is also weighing whether certain high-risk product categories should be subject to mandatory submission of this documentation as a condition of entry.
- Global Business Identifiers. CBP acknowledges that the longstanding Manufacturer Identification Code (MID) provides limited identifying information, is not always unique, and is often unavailable early enough in the entry process to be useful. The agency is evaluating whether to replace or supplement the MID with Global Business Identifiers (GBIs) that are currently the subject of a voluntary test program designed to improve visibility into manufacturers, shippers, and sellers across the supply chain.
- Technology and AI Integration. Citing illegal transshipment as a direct threat to lawful revenue and economic security, CBP intends to leverage artificial intelligence and private-sector traceability technologies to flag transshipment risk earlier in the import process. The agency is also considering whether CTPAT participants should be required to adopt and disclose such technologies to CBP, with particular attention to security risks posed by foreign-controlled logistics platforms
CBP has requested comments on several implementation considerations, including phased rollouts by entry type, commodity, country, or mode of transportation; tailored timelines for small entities, foreign importers, and CTPAT participants; and the costs and benefits of the proposals, including potential effects on critical goods such as medical products. Comments are due by December 1, 2026, and may be submitted through the Federal eRulemaking Portal under Docket No. USCBP-2026-1058.
The Husch Blackwell International Trade and Supply Chain team will continue to monitor this and provide updates as they become available. If you have any questions or concerns, please contact your Husch Blackwell attorney.