Friday, September 4, 2026
CBP Considering Major Expansion of Importer Supply Chain Requirements-Seeks Input
U.S. Customs and Border Protection (CBP) has issued an Advance Notice of Proposed Rulemaking that could significantly increase supply chain transparency, documentation, and recordkeeping requirements for U.S. importers. They are requesting input from the trade on implementation of portions of the president’s June 3, 2026 Executive Order on strengthening Customs enforcement. These changes, if implemented, could lead to significant new documentation, data, recordkeeping and supply chain tracing requirements for all U.S. importers.
Key proposals under consideration include:
✅ Requiring importers to obtain and retain foreign export documentation such as export declarations, commercial invoices, certificates of origin, permits, packing lists, and transportation records.
✅ Replacing or enhancing Manufacturer Identification Codes (MIDs) with Global Business Identifiers (GBIs) to improve visibility into manufacturers, suppliers, and other supply chain participants.
✅ Expanding the use of supply chain tracing technologies, AI, and origin verification tools.
✅ Strengthening CTPAT requirements, including potential cybersecurity, data integrity, and supply chain visibility obligations.
✅ Applying enhanced documentation requirements to higher-risk products and countries.
While no new requirements have been implemented yet, this notice provides a strong indication of CBP's future enforcement priorities. Importers should evaluate their ability to access supplier documentation, validate upstream supply chain information, and support enhanced traceability requirements.
We will keep you updated as we receive information. Please contact us if you have any questions about this or any other trade matter.
Key proposals under consideration include:
✅ Requiring importers to obtain and retain foreign export documentation such as export declarations, commercial invoices, certificates of origin, permits, packing lists, and transportation records.
✅ Replacing or enhancing Manufacturer Identification Codes (MIDs) with Global Business Identifiers (GBIs) to improve visibility into manufacturers, suppliers, and other supply chain participants.
✅ Expanding the use of supply chain tracing technologies, AI, and origin verification tools.
✅ Strengthening CTPAT requirements, including potential cybersecurity, data integrity, and supply chain visibility obligations.
✅ Applying enhanced documentation requirements to higher-risk products and countries.
While no new requirements have been implemented yet, this notice provides a strong indication of CBP's future enforcement priorities. Importers should evaluate their ability to access supplier documentation, validate upstream supply chain information, and support enhanced traceability requirements.
We will keep you updated as we receive information. Please contact us if you have any questions about this or any other trade matter.
