CBP Opens Rulemaking on "Heightened Import Disclosures for Supply Chain Visibility" — 64 Questions on Naming Upstream Suppliers, Retaining Foreign Export Documents, and Tracing Technology, With Comments Due December 1, 2026
U.S. Customs and Border Protection published an Advance Notice of Proposed Rulemaking on September 2, 2026 titled "Heightened Import Disclosures for Supply Chain Visibility," asking the trade community whether importers should be required to disclose substantially more about where their goods actually come from. CBP describes three areas it is exploring: enhancing visibility into the parties involved in an importation, integrating technical solutions for tracing supply chains, and collecting the export documentation that foreign exporters file with their own customs authority before shipping to the United States. The agency frames the effort as a way to detect and interdict illicit imports, especially goods illegally transshipped to evade U.S. customs and trade laws, and ties it to Executive Order 14411, "Strengthening Customs Enforcement." This is an ANPRM, not a rule — nothing is required of importers today, and any obligation would come only after a later proposed rule and final rule. But it is the clearest signal yet of the direction CBP intends to take on origin documentation, and the comment window closes December 1, 2026.
Real-World Impact
The notice poses 64 questions and gives the trade 90 days to answer them — from the September 2, 2026 publication date to the December 1, 2026 comment deadline. No cost, fee, or data-element count is fixed in the notice, because an ANPRM asks what the requirements should be rather than setting them.
Key Points
- CBP announced the ANPRM "Heightened Import Disclosures for Supply Chain Visibility" on September 2, 2026; it was published in the Federal Register the same day under document number 2026-17926
- Comments are due on or before December 1, 2026, submitted through regulations.gov under docket USCBP-2026-1058 — a 90-day comment period
- CBP names three areas it is exploring: enhancing visibility into the parties involved in the importation of goods, integrating innovative technical solutions for tracing supply chains, and collecting the foreign export documentation exporters must file with their own customs authority before exporting to the United States
- Trade-bar analysis of the notice counts 64 questions posed to the trade community, covering whether importers should identify parties beyond their direct suppliers — manufacturers, producers, shippers, and distributors — and whether business identifiers should be improved
- One line of questioning covers requiring importers to obtain and retain documents exporters provide to foreign customs authorities, such as export declarations and certificates of origin — records many ecommerce importers have never handled
- Another covers traceability technologies, artificial intelligence, unique identifiers, and tamper-proof credentials for verifying origin and production
- CBP Commissioner Rodney S. Scott framed the effort as national security, saying border security is national security and that knowing what is coming into the country is vital; Susan S. Thomas of CBP's Office of Trade said greater supply chain visibility is critical to detecting and stopping illegal trade activities
- The ANPRM supports implementation of Executive Order 14411, "Strengthening Customs Enforcement," the same order behind CBP's August 19, 2026 Form 5106 accuracy notice and the September 1, 2026 penalty-mitigation deadline
- An ANPRM imposes no obligations — it precedes a notice of proposed rulemaking, which would itself carry another comment period before any final rule; there is no compliance date in this notice
- CBP says the goal is to more effectively detect and interdict illicit importations, especially those illegally transshipped to evade compliance with U.S. customs and trade laws
What You Should Do Now
- 1Read the ANPRM in the Federal Register (document 2026-17926) before assuming it changes anything today — it is a request for comment, and no importer obligation attaches until a later rule
- 2Map how far upstream you can actually see right now: for each major ASIN, can you name the manufacturer and production facility, or does your visibility stop at a trading company?
- 3Ask your suppliers now whether they can provide the export declarations and certificates of origin they file with their own customs authority, so you know where the gaps are before a rule requires them
- 4If the questions would be costly or infeasible for your sourcing model, file a comment through regulations.gov under docket USCBP-2026-1058 with concrete cost estimates and timelines by December 1, 2026 — ANPRM comments are the stage where scope is still genuinely open
- 5Treat this alongside the other Executive Order 14411 workstreams already on the calendar — the September 18, 2026 Form 5106 voiding date and the penalty-mitigation revisions — rather than as an isolated notice