U.S. Customs and Border Protection (CBP) has published an Advance Notice of Proposed Rulemaking (ANPRM) on heightened import disclosures and supply-chain visibility.
The notice was published on 2 September 2026 in Federal Register volume 91, number 169. It appears under Docket USCBP-2026-1058 and implements part of Executive Order 14411, “Strengthening Customs Enforcement,” issued on 3 June 2026.
This is not final law. It does not yet create new filing duties. CBP is asking businesses and other stakeholders how expanded requirements should work.
Comments are due by 1 December 2026.
What is CBP considering?
CBP wants greater visibility into the goods, parties, documents and technology connected with imports into the United States.
The proposals could affect international sellers, manufacturers, online marketplaces, customs brokers, freight forwarders and U.S. importers of record.
CBP is considering requirements covering:
- Foreign export documentation.
- Manufacturer, shipper and exporter identification.
- Global business identifiers.
- Product-level supply-chain information.
- Earlier entry filing.
- Reconciliation between foreign export and U.S. import data.
- Artificial intelligence and supply-chain tracing technology.
- CTPAT participation and security controls.
- The use of certain foreign-controlled logistics platforms.
The official Federal Register notice contains 64 questions for public comment.
Keep foreign export documents for every shipment
CBP is considering requiring importers of record to submit, retain or provide foreign export documents that the exporter filed with its own customs authority before the goods were shipped to the United States.
The documents under consideration include:
- Foreign export declarations.
- Commercial invoices.
- Packing lists.
- Certificates of origin.
- Export licences and permits.
- Bills of lading and air waybills.
- Other transport or export-manifest documents.
These documents may show the value, quantity, classification, origin, description and movement of the goods.
CBP says the information could help identify discrepancies. It could also help detect undervaluation, misclassification, illegal transshipment and possible dual invoicing.
The practical message is clear. Do not rely only on the final U.S. entry summary. Your business should be able to connect the U.S. customs entry to the supplier’s original export records.
Build a SKU-level customs data file now
International sellers should begin creating a structured customs file for each product and shipment.
Your file should connect:
- SKU and product description.
- Manufacturer and supplier.
- Exporter and shipper.
- Country of manufacture and export.
- Harmonized tariff classification.
- Quantity and unit of measure.
- Commercial value and currency.
- Incoterms.
- Freight, insurance and other relevant costs.
- Foreign export declaration reference.
- U.S. entry and entry-summary reference.
- Customs broker and freight-forwarder details.
- Certificates, licences and origin evidence.
This process will make future reconciliation faster. It will also help you answer customs queries without searching through disconnected emails, spreadsheets and marketplace reports.
Keep the supplier’s export declaration and commercial invoice with the shipment record. Doing this creates a reliable audit trail and reduces the risk of inconsistent information being filed in different countries.
Reconcile foreign export data with U.S. entry data
CBP is specifically asking what controls importers should use to identify differences between foreign export documentation and U.S. entry summaries.
Differences can arise for legitimate reasons. For example:
- Export and import customs rules may use different valuation methods.
- Currency conversion may change the reported amount.
- Freight and insurance may be treated differently.
- The importer may have paid additional charges after export.
- Quantities may change because of partial shipments or damaged goods.
- Classification may need further review at import.
- A trading company may appear on the foreign export filing while another entity imports the goods into the United States.
The issue is not that every figure must always be identical. The issue is whether you can explain the difference and retain supporting evidence.
Create a reconciliation control that compares, at minimum:
- Product and SKU.
- Quantity.
- Customs value.
- Currency.
- Country of origin.
- Classification.
- Supplier and exporter.
- Shipment and transport references.
Record the reason for each material difference. Keep the evidence supporting your conclusion.
Many of these habits mirror what a compliant importer should already maintain. Structured, reconciled records reduce penalty exposure if CBP later introduces wider disclosure requirements.
Prepare for more detailed party identification
CBP is also reviewing the current Manufacturer Identification Code, or MID.
The notice states that the MID can provide limited information and may not always identify the party CBP needs to assess. CBP is therefore considering whether to replace or supplement the MID with fuller identifying information.
The agency is asking about:
- Manufacturer.
- Producer.
- Supplier.
- Shipper.
- Seller.
- Exporter.
- Distributor.
- Packager.
- Final intended recipient.
- Online marketplace that facilitated the sale.
CBP is also considering global business identifiers, including:
- D-U-N-S.
- Global Location Number (GLN).
- Legal Entity Identifier (LEI).
- Altana ID.
Review your supplier master data now. Make sure legal names, trading names, physical addresses and supply-chain roles are not mixed together.
A marketplace seller should also identify which party controls each data point. Your marketplace may provide sales and fulfilment data, but it may not hold the supplier’s foreign export declaration or manufacturing details.
Do not assume a U.S. company solves the IOR issue
Forming a U.S. entity does not automatically make your business a compliant importer of record.
Executive Order 14411 directs CBP to review importer eligibility, domestic assets, bonding, ownership and beneficial ownership disclosures. It also directs attention to anticipated import volumes, business affiliations and the importer’s domestic presence.
The order distinguishes between U.S. and foreign importers of record. It refers to factors such as:
- Where the entity is organised.
- Where it is located.
- Where its principal place of business operates.
- Whether it has meaningful U.S. business activity.
- Its domestic tangible assets.
- Its beneficial ownership.
- Bonding arrangements.
- Its compliance history.
The ANPRM asks how these proposals should be implemented and phased in. It does not mean that every proposed condition applies today.
However, you should confirm who is actually acting as the importer of record for each shipment. Check your customs power of attorney, bond arrangements, broker instructions and commercial documents.
A foreign seller using a U.S. fulfilment provider should not assume that the warehouse, marketplace or customs broker automatically accepts responsibility for the import.
Review logistics technology and CTPAT readiness
CBP is asking how businesses use technology to trace supply chains and production methods.
The notice discusses AI-driven tools that could help identify illegal transshipment and other supply-chain risks. It also asks whether CTPAT requirements should expand to include cybersecurity, data integrity and the use of trusted logistics systems.
CBP specifically refers to “covered logistics platforms”, including LOGINK or other foreign-controlled systems that may be identified as national security risks.
This is a consultation stage. CBP has not imposed a general prohibition through this ANPRM.
Still, you should document:
- Which platforms your suppliers and freight partners use.
- Where shipment data is stored.
- Who can change shipping instructions.
- How records are protected.
- Whether documents can be retrieved in their original form.
- How your business verifies supplier-provided information.
These controls can improve operational reliability even before any new rule is finalised.
Review your accounting and compliance workflow
Customs data should not sit separately from your accounting records.
A UK-based ecommerce accountant supporting U.S. sales should be able to trace inventory purchases, freight costs, import entries and landed costs. The same applies to an amazon seller accountant uk supporting FBA movements, or a business reviewing its amazon fba accounting uk processes.
Good ecommerce bookkeeping uk systems should connect:
- Supplier invoices.
- Inventory receipts.
- Freight and duty.
- Customs entries.
- Marketplace settlements.
- Returns and adjustments.
- Sales tax reporting.
The same discipline supports shopify accounting uk workflows where goods move through third-party warehouses or cross-border fulfilment networks.
At Sterlinx Global, we operate as a Global Tax Compliance Suite. You provide the underlying business data, and we complete bookkeeping, tax calculations, VAT, GST or Sales Tax filings and year-end compliance through an ongoing process. This helps keep accounting and compliance records aligned as your business grows internationally.
Use the comment period before 1 December 2026
Small and medium-sized sellers should consider submitting comments.
CBP is asking about the costs and benefits of the proposals. It is also asking whether different timelines should apply to:
- Small entities.
- Foreign importers.
- CTPAT participants.
- High-volume filers.
- Different entry types.
- Different products or transport modes.
Your comment could address:
- The time required to obtain foreign export records.
- Supplier data gaps.
- Translation issues.
- Systems and software costs.
- The effect of earlier filing deadlines.
- The cost of obtaining global identifiers.
- The impact on smaller sellers.
- A realistic phased implementation period.
- How existing marketplace and broker systems could be used.
Submit comments through Regulations.gov using Docket USCBP-2026-1058. Include the docket number in your submission and avoid placing unnecessary personal information in the comment or attachments because submissions are published online.
International seller checklist
Use this checklist now:
- Confirm the importer of record for each import route.
- Ask suppliers for copies of foreign export declarations.
- Retain commercial invoices and packing lists.
- Record manufacturer, exporter, shipper and seller details.
- Map each SKU to its classification and origin.
- Reconcile foreign export data with U.S. entry data.
- Document explanations for material differences.
- Review bond and customs broker arrangements.
- Check whether your U.S. entity has meaningful domestic presence and assets.
- Record the logistics platforms used by suppliers and freight partners.
- Assess whether your systems can preserve original documents.
- Consider submitting comments before 1 December 2026.
Frequently asked questions
Is CBP’s new import disclosure rule already in force?
No. The 2 September 2026 notice is an ANPRM. It asks for information before CBP decides whether and how to issue a subsequent proposed regulation. The notice itself does not create all of the new requirements described for consultation.
Who could be affected?
Potentially affected parties include international sellers, manufacturers, exporters, online marketplaces, customs brokers, freight forwarders, fulfilment providers and importers of record.
What records should sellers retain?
You should retain supplier export declarations, commercial invoices, packing lists, certificates of origin, permits where relevant, transport documents and U.S. entry records. Keep them together with SKU, quantity, value, origin and classification data.
Does a U.S. LLC automatically qualify as a U.S. importer of record?
No. Entity formation alone does not establish compliance. Importer eligibility may also involve domestic presence, ownership, beneficial ownership, assets, bonding and other requirements. The specific proposals are not final.
When are comments due?
Comments must be received by 1 December 2026 under Docket USCBP-2026-1058.
Can Sterlinx Global help with the compliance workflow?
Yes. We support international businesses with structured bookkeeping, accounting, VAT, GST, Sales Tax and year-end compliance processes. Contact Sterlinx Global to discuss your cross-border reporting and documentation requirements.
