USA Tax Update: CBP Proposes Heightened Import Disclosures for Supply Chain Visibility : What International Sellers Must Know

TITLE: CBP Seeks Input on Major Import Disclosure Overhaul — What Businesses Should Know Now

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:

1. SKU and product description.
2. Manufacturer and supplier.
3. Exporter and shipper.
4. Country of manufacture and export.
5. Harmonized tariff classification.
6. Quantity and unit of measure.
7. Commercial value and currency.
8. Incoterms.
9. Freight, insurance and other relevant costs.
10. Foreign export declaration reference.
11. U.S. entry and entry-summary reference.
12. Customs broker and freight-forwarder details.
13. 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 and whether that entity can demonstrate the operational substance, financial security and compliance record that CBP may soon require.