Importers may soon have to surrender their foreign suppliers' domestic customs filings to U.S. border officials before cargo clears clearance checkpoints. On September 2, 2026, U.S. Customs and Border Protection (CBP) officially published an Advance Notice of Proposed Rulemaking (ANPRM) titled "Heightened Import Disclosures for Supply Chain Visibility" (91 FR 56408, Docket No. USCBP-2026-1058, RIN 1685-AA47). The seven-page notice presents 64 numbered questions, marking the most ambitious overhaul of formal entry declarations since the 1993 Customs Modernization Act.

The notice directly implements Section 3 of Executive Order 14411, "Strengthening Customs Enforcement," signed earlier this year. Through this rulemaking, CBP targets trade fraud, illicit transshipment, tariff evasion, and forced labor. The agency signals a decisive transition from post-importation review to upstream verification.

The End of the Traditional Entry Paradigm

CBP is weighing structural revisions across Title 19 of the Code of Federal Regulations, explicitly naming Parts 141 (Entry of Merchandise), 142 (Entry Process), 143 (Automated Broker Interface), and 163 (Recordkeeping). Four proposals stand out for customs brokers, trade attorneys, and forwarders managing entry filings in the Automated Commercial Environment (ACE).

First, CBP contemplates requiring importers of record to obtain and submit the actual foreign export declaration filed by their supplier with origin customs authorities. Cross-border enforcement teams want to compare export classifications, reported values, and declared origins against incoming U.S. entry summaries. If discrepancies appear, ACE targeting algorithms will trigger holds.

Second, CBP is preparing to eliminate the decades-old Manufacturer Identification Code (MID). Long criticized by enforcement personnel as vague and prone to abuse, the alphanumeric MID would be replaced by authenticated Global Business Identifiers (GBIs), corporate registry records, and verified foreign tax IDs.

Third, CBP intends to shorten entry filing timeframes. The standard 15-calendar-day window under 19 CFR Part 142 may be sharply reduced to afford CBP analysts advance visibility before goods enter domestic commerce. The notice also proposes requiring the identification of the "ultimate delivery party" behind nominal consignees.

Rewriting CTPAT and Restricting Logistics Platforms

The ANPRM extends beyond commercial entry data. Questions 46 through 61 indicate a fundamental restructuring of the Customs Trade Partnership Against Terrorism (CTPAT). CBP is asking whether CTPAT Tier 2 and Tier 3 partners should be compelled to implement origin-tracing technologies accessible directly by agency personnel.

Critically, CBP is considering establishing a formal ban on "covered logistics platforms" designated as foreign national security risks, citing state-sponsored networks such as LOGINK. If forwarders, non-vessel operating common carriers (NVOCCs), or tier-1 suppliers utilize flagged platforms, importers could face immediate revocation of their trusted trader benefits.

What this means for you

  • Audit supplier documentation capabilities immediately: Contact tier-1 overseas vendors this week to determine whether they can legally and contractually provide official domestic export declarations within compressed timelines.
  • Evaluate your identifier exposure: Review active MID databases across your ABI software; begin cross-referencing suppliers against corporate registries and Global Business Identifier frameworks to prevent future clearance delays.
  • Inspect logistics software and supply-chain tech stacks: Audit the shipping platforms, digital portals, and tracking systems used by foreign agents and third-party logistics providers to confirm no reliance on vulnerable or state-controlled logistics networks like LOGINK.
  • Submit formal public comments before December 1, 2026: Convene internal trade compliance committees and industry working groups to draft data-backed responses to Docket USCBP-2026-1058, specifically addressing the cost and commercial disruption of shortened entry windows.

While an ANPRM creates no immediate statutory obligations today, it establishes the precise operational architecture of the forthcoming Notice of Proposed Rulemaking (NPRM). U.S. trade policy has firmly departed from passive clearance models. Compliance teams that treat upstream documentation as an afterthought risk finding their supply chains immobilized at the port of entry once these proposals become binding federal law.