US Customs and Border Protection (CBP) is considering new requirements that could significantly increase supply chain visibility and importer reporting obligations.
Through an Advance Notice of Proposed Rulemaking (ANPRM), CBP is seeking industry feedback on ways to obtain more information about the production, movement, and exportation of goods entering the United States.
No new requirements are in effect yet, but the ANPRM signals a potential shift toward greater supply chain transparency, traceability, and documentation.
What Is CBP Considering?
CBP is exploring several ways to strengthen supply chain visibility, including:
- Foreign export documentation: Importers may be required to obtain and potentially submit export declarations, commercial invoices, packing lists, certificates of origin, and other documents.
- Supply chain participant information: CBP is considering more detailed identification of manufacturers, exporters, sellers, shippers, and other parties involved in international transactions.
- Global Business Identifiers: CBP is evaluating identifiers such as D-U-N-S® Numbers, Global Location Numbers (GLNs), Legal Entity Identifiers (LEIs), and Altana IDs.
- Traceability technology: CBP is seeking input on the use of supply chain technology and artificial intelligence to verify sourcing, country of origin, and potential illegal transshipment.
For CTPAT participants, CBP is also considering whether enhanced traceability could become part of future program requirements.
What Should Importers Do Now?
While these proposals are not yet regulations, importers should review how heightened disclosure and traceability requirements could affect their supply chains.
Consider:
- Can suppliers consistently provide required documentation?
- How much visibility do you have beyond your immediate suppliers?
- Can your systems support additional recordkeeping and traceability?
- Where could obtaining and validating this information create operational challenges?
Importers are strongly encourage to submit comments to CBP on how these potential requirements could affect their operations and supply chains. Feedback submitted during the ANPRM process can help inform how future requirements are developed.
Key Takeaway
CBP is moving toward greater supply chain transparency and importer accountability. Although no new requirements have been finalized, importers should begin evaluating their documentation, data, and traceability capabilities now.
This ANPRM provides an important opportunity for importers to review the potential impact on their supply chains and submit comments before CBP develops a formal proposed rule.
Comments should reference Docket No. USCBP-2026-1058 and be submitted through the Federal eRulemaking Portal. CBP will accept comments for 90 days following publication in the Federal Register.