Remember when customs compliance was mostly about getting the classification, value, and country of origin right? Those were simpler times.
CBP is considering new requirements that could give the agency much greater visibility into your supply chain, including who manufactured your goods, who sold them, who shipped them, where they came from, and what information was reported to foreign customs authorities.
And yes… CBP may want your receipts.
“But We Already Give You the Invoice…”
Maybe.
CBP is considering whether importers should provide foreign export documentation such as:
- Export declarations
- Commercial invoices
- Packing lists
- Certificates of origin
- Export licenses
- Transportation documents
Why? Because CBP wants to compare the information reported overseas with what appears on the U.S. entry.
Translation: CBP may be comparing the story your supplier told their government with the story your entry told CBP.
And those stories better match.
The MID May Be Getting a Makeover
CBP is also taking a hard look at the Manufacturer Identification Code (MID).
The agency says the current MID does not always uniquely identify the party CBP is interested in, and it’s considering collecting more detailed information about manufacturers, shippers, exporters, sellers, and potentially other supply-chain participants.
It is also exploring the use of Global Business Identifiers (GBIs) to improve supply-chain visibility.
So, yes, your supply chain may soon need more than a name and address to introduce itself.
AI + Supply Chain Data = The New Reality
CBP is also exploring technology and AI to improve supply-chain traceability and identify potential illegal transshipment before goods arrive in the United States or are released by the CBP.
So, if your current supply-chain technology strategy is:
“I have a spreadsheet somewhere…”
…it might be time for an upgrade.
Here’s the Park Importers Shouldn’t Ignore
This is currently an Advance Notice of Proposed Rulemaking (ANPRM), not a final rule. But CBP is asking some very important questions about how importers obtain, verify, reconcile, and retain supply-chain information.
That means now is a good time to ask:
Do you actually know what’s happening upstream?
Not just your direct supplier.
Not just the factory name on the commercial invoice.
The whole chain.
Who manufactured it?
Who sold it?
Who exported it?
Where were the raw materials sourced?
What information did the foreign customs authority receive?
And most importantly…
Does that information match what you’re telling CBP?
Because “That’s what the supplier told us” may not be the answer you want to give when CBP starts asking for supporting documentation.
IMPORTERS – this is your chance to speak up.
Here’s the part you shouldn’t overlook:
CBP is asking for your input.
The agency is seeking comments about the potential costs, operational challenges, documentation requirements, technology requirements, and impact on businesses, including small businesses.
If these proposals could affect your business, tell CBP.
But what should you put in your comments?
5 Things Importers Should Include in their CBP Comments
1. Explain what information you can and cannot get from your suppliers.
Can your suppliers provide foreign export declarations?
Certificates of origin?
Packing lists?
Export permits?
How quickly?
If obtaining these documents is difficult, explain what obstacles you face and why
CBP is specifically asking about the challenges importers face in obtaining and retaining foreign export documentation.
2. Put real numbers behind the compliance burden.
Don’t simply say, “This will be expensive.” Tell CBP what it could actually cost your business.
Consider:
- Software and system changes
- Employee training
- Additional personnel
- Supplier compliance programs
- Data integration
- Document translation
- Record retention
- Potential delays in getting goods released
CBP is asking for specific information about the costs and benefits of these proposals, including impacts on small businesses.
3. Identify the data problems you already encounter.
Do foreign documents use different values?
Different classifications?
Different quantities?
Different descriptions?
Different origin information?
Tell CBP.
The agency is specifically asking how importers should reconcile discrepancies between foreign export documentation and U.S. entry or entry-summary information.
Real-world examples are much more useful than simply saying, “We have a data problem.”
4. Explain what technology you actually have and what you don’t.
CBP is asking about supply-chain technology, AI, traceability systems, entity identifiers, data security, and integration with systems such as ACE.
If your company has sophisticated technology, explain what it does.
If you’re a smaller importer working with spreadsheets, email, and multiple supplier portals…
Say that too.
CBP is specifically asking whether proposed technologies are scalable for both small businesses and large multinational companies.
5. Tell CBP what would make the rules workable.
Don’t just identify the problem. Offer solutions.
For example:
- Phased implementation
- Different requirements based on risk
- Exceptions for certain commodities
- Additional time for small businesses
- Different requirements for CTPAT participants
- Voluntary pilot programs
- Reasonable transition periods
CBP is specifically asking whether requirements should be phased in based on entry type, commodity, country, transportation mode, company size, CTPAT participation, or volume.
In other words: Don’t just identify the challenges. Give CBP something they can work with.
How do you comment?
The proposed rulemaking is identified as Docket No. USCBP-2026-1058.
Comments are submitted through Regulations.gov, and CBP has specifically invited stakeholders to provide data, views, arguments, costs, benefits, and information about how these proposals would affect their businesses.
And remember:
You don’t have to be a multinational corporation to have something valuable to say.
In fact, your experience as a small or mid-sized importer may provide an important perspective for CBP to consider.
THE BOTTOM LINE
Supply-chain visibility is quickly becoming trade compliance visibility.
The importers who get ahead of this will be in a much better position than those who wait until CBP asks for information they don’t have.
Know your supply chain.
Know your data.
Know your risks.
And if these proposals will affect your business, make your voice heard.
Tell CBP what works.
Tell CBP what doesn’t.
Tell CBP what it will cost.
And tell CBP what would make compliance practical.
The ANPRM gives importers an opportunity to provide input while CBP is considering what future requirements should look like.
For importers, the message is simple: knowing what you import may no longer be enough. You need to know who made it, who sold it, who shipped it, where it came from, what documentation exists, and whether all of those pieces tell the same story.
The supply chain has always had a story to tell. CBP appears to be getting more interested in reading the whole thing.
Now is the time to make sure your story is accurate. And if you have something to say, now is the time to say it.
Do you need help with import compliance? Contact Export Solutions to schedule a no-charge consultation today.
Shawna Karajic is a Senior Consultant for Export Solutions -- a full-service consulting firm specializing in U.S. import and export regulations.