CBP's Heightened Import Disclosures Proposal: What It Would Require and How to Prepare

What is CBP's heightened import disclosures proposal?

It is an advance notice of proposed rulemaking (ANPRM) that U.S. Customs and Border Protection published in the Federal Register on September 2, 2026, at 91 FR 56408. It asks the trade how CBP should collect foreign export documents, identify the parties behind each shipment, and use supply chain tracing technology.

Is the heightened import disclosures rule in force?

No. The notice proposes no regulatory text and changes nothing at entry today. CBP says comments will be used, potentially, to draft a proposed rule. Comments are due December 1, 2026, under docket USCBP-2026-1058.

TL;DR

The CBP heightened import disclosures notice is a set of 64 numbered questions, not a rule. It covers three things: whether importers of record should submit or keep the documents their foreign exporter filed with the export country's customs authority, whether CBP should redefine or replace the manufacturer identification code (MID), and what tracing technology could verify origin. For a compliance team importing from 40 suppliers in five countries, the useful work now is not compliance, there is nothing to comply with yet. It is finding out which of those 40 suppliers could produce an export declaration and a verified legal name on request, because that answer is both the best comment you can file and the first gap you would have to close.

Last updated: October 2026

What does the CBP notice say, in its own words?

The summary is short and worth reading in full. CBP "is considering amending its regulations to give CBP greater visibility into the supply chains of goods imported into the United States," and is "seeking comments on new requirements enhancing visibility into the parties involved in the importation of goods," on technical solutions for tracing those supply chains, and on "collecting foreign export documentation that foreign exporters are required to submit to the foreign customs authority prior to the exportation of those goods to the United States." The stated aim: "to more effectively detect and interdict illicit importations, especially those that are illegally transshipped."

Bottom line: For a trade compliance manager deciding whether this needs action this quarter, the answer is a comment decision, not a filing change. The notice names the regulations it may amend, but proposes no text for any of them.

The notice traces to Executive Order 14411, signed June 3, 2026. Section 3(a) of the order tells the Secretary of Homeland Security to set "heightened import disclosure and certification requirements," including "disclosing certain foreign tax and global business identifiers" and "detailed information about the imported good's supply chain and production methods." Section 3(b) says that "within 90 days of the date of this order," the Secretary "shall take steps to establish a requirement mandating the submission of any documentation or information that the foreign exporter was required to submit to the foreign customs administration prior to exporting to the United States." Ninety days from June 3 is September 1. The ANPRM was filed for public inspection on September 1 and published the next day. We covered the rest of the order in our guide to the customs enforcement executive order.

One gap is visible on a side-by-side read. Section 3(a) also calls for certifying compliance with laws such as the Countering America's Adversaries Through Sanctions Act and 18 U.S.C. 545. The ANPRM's 64 questions do not take up that certification piece.

Is the heightened import disclosures proposal a rule yet?

No, and the distinction decides what you do next. An ANPRM sits before the proposed rule stage. CBP's own words: "The comments received in response to this ANPRM will be used, potentially, to draft a Notice of Proposed Rulemaking (NPRM), which would propose regulations to implement these proposals, or other suggested proposals received in response to this ANPRM."

Three things follow from that sentence:

1. There is no requirement to meet. No new data element, document or deadline applies to any entry filed today.
2. The content is open. CBP can adopt a proposal, change it, or drop it. The phrase "or other suggested proposals" means commenters can put alternatives on the table.
3. There is no date for the next step. The notice sets no timetable for a proposed rule. A proposed rule, if one comes, would carry its own comment period before anything could become final.

As of October 9, 2026, the Federal Register lists this notice as the only document under RIN 1685-AA47 and docket USCBP-2026-1058. No proposed rule and no comment extension have been published.

What foreign export documentation could CBP require?

CBP lists six document types it "may include," each one filed with the export country's customs authority before the goods leave:

• Export declarations, which "may show declared value, classification, and quantity"
• Commercial invoices "showing the transaction value declared to the foreign customs authority"
• Packing lists
• Certificates of origin submitted to the foreign customs authority
• Export licenses or permits for controlled, restricted or dual-use goods
• Transport documents, such as the bill of lading or air waybill, filed with the foreign export manifest

CBP is open about why it wants them: to verify and reconcile "entry and entry summary information" and detect "discrepancies that could indicate violations of U.S. customs and trade laws, such as dual-invoicing."

The questions that matter most for an importer of record:

Bottom line: For an importer whose suppliers sell through trading companies or consolidators, Q4 and Q11 carry the most risk. CBP notes the export declaration may be filed by "a trading company, distributor, consolidator, or third-party logistics provider," which means the document may come from a party you have never contracted with.

Which supply chain parties would importers have to identify?

Today the entry summary carries the MID, a code built from the manufacturer or shipper's name, address and country under a CBP directive from 1986. CBP lists what is wrong with it: it "provides limited identifying information and does not always identify the actual party that may be of interest to CBP," it "is not always available to CBP early enough in the entry process to be useful," and it "is not always a consistent or unique number." Then the key line: "CBP is interested in proposals to redefine or replace the MID."

The options CBP floats:

• Full identity per shipment. Q28 asks whether "actual identifying data, such as full company name and physical address or other business identifier," should be provided "with each shipment."
• Separate parties. Q25 and Q26 ask whether to identify the manufacturer, shipper and exporter separately, and how to define each. Q27 asks whether to use "producer" instead, to align with 19 CFR part 102 and trade agreements.
• Earlier timing. Q29 asks whether the MID or its replacement should come at entry, entry summary, or on the manifest.
• More parties. Q33 asks whether an online marketplace that facilitated the sale should be named. Q34 asks about the party the goods are ultimately delivered to.
• Consequences. Q30 asks what should happen to importers "who do not provide accurate MID data."

CBP also asks about Global Business Identifiers. Its voluntary GBI test, announced in December 2022 and modified in August 2025, accepts four identifiers with entry data: D-U-N-S, Global Location Number, Legal Entity Identifier and Altana ID. Q40 asks whether it is "feasible for CBP to require the provision of a GBI to identify the manufacturer, shipper, and/or seller at entry."

Q42 deserves the most attention from classification teams. It asks whether, instead of an entity identifier, importers could provide "a single product-level identifier for each shipment that provides detailed information about the imported good's supply chain and production methods, such as the manufacturer's product identifier (e.g., model or style number) or key specifications (e.g., composition, grade, or size)." That wording comes almost verbatim from Section 3(a) of the executive order.

Most of this data would come from the supplier master, which drifts. See our piece on supplier data quality as the foundation of trade compliance accuracy.

What tracing technologies is CBP asking about?

Section C of the notice opens with a definition: illegal transshipment is "the practice of routing goods through a third country to obscure or misrepresent their true country of origin." CBP says it is "evaluating artificial intelligence (AI)-driven solutions for pinpointing illegal transshipment risk" and wants to make decisions "before goods arrive at, or are released from, the U.S. border."

The questions run from general to specific:

• Q46 and Q47: what technology the private sector uses for supply chain visibility, how it verifies the data, and how far importers should be "responsible for using technological tools to provide CBP with visibility."
• Q48: "What is the role of AI in driving these technologies?"
• Q49: integration with ACE and Partner Government Agency data exchanges.
• Q50: technology to verify the origin of raw materials and close the "visibility gap" between suppliers and raw material sources.
• Q54: whether technology could "properly certify required entry data elements, such as the country of origin."

The CTPAT questions are sharper. Q57 asks whether all CTPAT partners should be required to use enhanced tracing technology. Q58 asks whether partners should have to make that technology "visible to CBP." Q60 and Q61 ask about prohibiting "covered logistics platforms," naming LOGINK, and ask what migrating away would cost.

How does this connect to transshipment enforcement?

Every pillar points at the same target. Foreign export documents let CBP compare what left the export country with what arrived. Party identifiers let CBP see who made the goods rather than who shipped them last. Tracing technology aims to test origin before release. Executive Order 14411 Section 4(b) separately directs priority enforcement against "misclassification, undervaluation, and illegal transshipment," including Enforce and Protect Act investigations. If you already run an evasion defense program, our guide to defending an AD/CVD scope ruling and EAPA evasion allegation covers that side.

The classification consequence is the one most teams have not considered. According to the World Customs Organization, the Harmonized System "is used by more than 200 countries and economies as a basis for their Customs tariffs," with each commodity group "identified by a six digit code." The export declaration CBP describes "may show declared value, classification, and quantity."

Quotable insight: If CBP collects foreign export declarations, every entry gains a second classification written by someone else. Most export countries build their tariff on the same six-digit Harmonized System the HTS uses, so a supplier who declares one heading on export while the importer enters another creates a mismatch CBP can see without an audit. Q11 already asks importers how they would explain it.

That is GingerControl's view of the practical effect, not a prediction of what a final rule will say. It follows from two facts in the record: CBP lists classification among the fields an export declaration may show, and Q11 asks how importers would reconcile "a different value, quantity, or classification." A reconciliation is easier when your own classification has a written rationale from the time of entry, which is also what reasonable care expects.

How can importers comment before December 1, 2026?

The notice gives the instructions. Submit through the Federal eRulemaking Portal at regulations.gov, identified by docket number USCBP-2026-1058. Comments "will be posted without change," including any personal information, so keep commercially sensitive detail general unless you want it public.

CBP is specific about what makes a comment useful:

1. Cite the question numbers you are answering.
2. Give reasons and data. For numbers, "provide CBP with sufficient information to recreate those calculations."
3. Describe current practice and technology you use for supply chain visibility.
4. Address phasing. CBP asks whether requirements should phase in by entry type, commodity, country or transport mode, whether small entities, foreign importers, CTPAT participants or high-volume filers need different timelines, and what implementation period would be needed.
5. Address costs and benefits under Q62 to Q64, including effects on critical goods and medical products.

An importer is well placed to answer Q7 (challenges in obtaining foreign export documents), Q16 (current lead time), Q18 (costs), Q24 (business uses of the MID) and Q39 (which supply chain parties are likely to have a GBI).

What should importers do with their supplier data now?

Nothing in the notice obliges you to act. But each pillar maps to a data check you can run now, and the results serve twice: as evidence for a comment, and as a head start if a proposed rule follows.

Bottom line: For a compliance team with 200 active suppliers, the honest answer to "could we comply?" is usually unknown until someone asks the suppliers. Sampling the top 20 by entered value gives a measured answer for Q7 and Q16 and a gap list you would need anyway.

The product-level row connects directly to classification. The attributes Q42 lists, composition, grade and size, are the facts HTS classification already depends on. If the specification behind a classification and the specification a supplier would report to CBP have drifted apart, a product-level identifier would expose the drift. Retention matters too: records relating to an entry are kept for five years under 19 CFR 163.4, and our guide to customs recordkeeping requirements covers which records carry penalties if you cannot produce them.

Where this fits in your supplier data work

The notice is a question set today. The work it points to, knowing who made each product, what it is made of and what was declared on the way out, is useful whether or not a rule follows.

GingerControl's HTS Classification Researcher records GRI reasoning, Section and Chapter Notes and CROSS citations for each product, so the facts a classification rests on are written down and can be compared against what a supplier reports. GingerControl builds trade compliance AI. It is not a licensed customs broker or Importer of Record, does not provide legal advice, and does not file entries or comments on a client's behalf.

If you want help sizing the supplier data gap before deciding how to comment, our trade advisory team runs compliance and risk assessments for importers.

References

1. U.S. Customs and Border Protection, Heightened Import Disclosures for Supply Chain Visibility, advance notice of proposed rulemaking
   Data cited: status, summary, background, three pillars, questions Q1 to Q64, comment deadline and instructions, docket and RIN
   Source: 91 FR 56408, FR Doc. 2026-17926
   Published: September 2, 2026
2. Executive Office of the President, Executive Order 14411, Strengthening Customs Enforcement
   Data cited: Section 3(a) disclosure and certification requirements, Section 3(b) 90-day directive, Section 4(b) enforcement priorities
   Source: 91 FR 35125, FR Doc. 2026-11595
   Published: June 10, 2026
3. U.S. Customs and Border Protection, Global Business Identifier test announcement
   Data cited: voluntary NCAP test of GBIs
   Source: 87 FR 74157
   Published: December 2, 2022
4. U.S. Customs and Border Protection, Modification of the GBI test
   Data cited: current form of the GBI test
   Source: 90 FR 38479
   Published: August 8, 2025
5. Electronic Code of Federal Regulations, 19 CFR part 163, Recordkeeping
   Data cited: five-year retention for records relating to an entry
   Source: 19 CFR part 163
   Published: current as retrieved October 9, 2026
6. World Customs Organization, What is the Harmonized System
   Data cited: HS used by more than 200 countries and economies; six-digit codes
   Source: WCO Harmonized System overview
   Published: undated page, retrieved October 9, 2026