CBP May Start Asking for the Paperwork Your Supplier Filed Abroad

A new CBP notice floats requiring importers to hand over the export declaration, invoice and origin certificate that the foreign supplier filed with its own customs authority — so CBP can reconcile the two sets of numbers. Nothing is law yet. Comments close December 1, 2026.

On September 2, 2026 CBP published an advance notice of proposed rulemaking (ANPRM) titled Heightened Import Disclosures for Supply Chain Visibility (91 FR 56408, docket USCBP-2026-1058). It is the third piece of Executive Order 14411, Strengthening Customs Enforcement, to reach the Federal Register — after the voiding of inaccurate importer of record numbers and the DOJ trade fraud section.

Read the first two words carefully: advance notice. This is not a rule. CBP has published what it is thinking about and asked 64 questions about it. A proposed rule would come later, and a final rule later still. Nothing here takes effect on a date. What matters now is the direction, and the fact that comments are open until December 1, 2026.

1. The export paperwork your supplier filed on its side

The centerpiece. CBP is considering requiring importers to produce the documents the foreign exporter submitted to its own customs authority before the goods left:

• The export declaration — showing declared value, classification and quantity
• The commercial invoice as declared to the foreign customs authority
• The packing list, for contents, weight and packaging
• Certificates of origin filed on the export side
• Export licenses or permits for controlled, restricted or dual-use goods
• Transport documents (bill of lading, air waybill) filed as part of the export manifest

CBP states the purpose plainly: to reconcile these against the entry and entry summary and to detect discrepancies — it names dual invoicing, one price shown to the exporting country and a different one declared to CBP.

The open questions are the ones that decide how much work this is. Should the documents be transmitted with every entry, or only retained and produced on request? Should CBP request them at random? For how long must they be kept? Should the importer of record be the party responsible, and does reasonable care apply to documents the importer did not create? What about documents not in English? And — a question worth noticing — how would an importer prove the copy it gives CBP is the document actually filed abroad, unmodified?

Separately, CBP asks whether the Secretary should be able to designate categories of imports as posing grave national security risk and require this documentation as a condition of entry for those categories.

2. Knowing who your manufacturer actually is

CBP writes off its own tool: the manufacturer identification code (MID) is derived from a name and address, "provides limited identifying information," is not always unique, changes over time, and often arrives too late in the entry process to be useful. Two entities can share one MID.

The replacement CBP is weighing is either real identifying data — full company name and physical address with each shipment — or a global business identifier (GBI): D-U-N-S, GLN, LEI or Altana ID, tested voluntarily since 2022 for the manufacturer, shipper and seller. CBP asks whether GBIs should be required at entry, whether foreign tax identifiers should come with them, and whether entry should have to be filed earlier so there is time to review all this before arrival.

Two further questions widen the net: whether an online marketplace that facilitated the sale should be named, and whether the party the goods are ultimately destined for must be declared — not just the consignee who takes custody at arrival.

3. Your logistics software is on the list

CBP asks importers to name the platforms they and their supply chain partners use to transmit shipping instructions and book freight, and whether they can verify that their data is not being altered, shared or stored by unauthorized parties. It names LOGINK, the Chinese state-backed logistics data platform, as an example.

It goes further for CTPAT members: CBP asks whether the minimum security criteria should be expanded to cover cybersecurity and data integrity, including a prohibition on the use of covered logistics platforms identified as a security risk, and asks members to estimate what migrating off such a platform would cost them. If you are CTPAT-certified and your overseas partners book through a platform of this kind, that question is about you.

What is worth doing before December 1

Ask one supplier for one export declaration. Not a program — one shipment. CBP itself asks what the lead time is for obtaining these documents, which tells you it expects the answer to be awkward. Finding out now whether your supplier can produce it in two days or three weeks costs nothing and tells you what a rule would mean.

Compare it, field by field, against what was filed here. Value, quantity, classification, origin. If the two disagree, that gap is precisely what this proposal is designed to surface — and there is a large difference between finding it yourself now and having CBP find it later. Some differences are legitimate (FOB versus landed value, for instance); CBP asks how those should be reconciled. Being able to explain a difference is not the same as not knowing there is one.

Check that you can name your manufacturer, shipper and seller in full. Legal name, physical address, and whether each has a D-U-N-S or LEI. If your only record of a factory is a trading company's invoice, a MID replacement will be a problem for you before it is a problem for anyone else.

Comment, if the burden falls on you. CBP asked specifically for small-business cost data and for views on phasing by entry type, commodity, country or mode. Roughly 70% of CTPAT membership is small business. Comments go to regulations.gov under docket USCBP-2026-1058, and they are public.

We do not file your entries and we do not decide your classification or origin — that sits with you and your customs broker. What we hold is the transport side: bills of lading, arrival and delivery records, and the dates for the containers we moved. If you want to run the comparison above for a past period, ask us and we will pull our records together for you. Get in touch.