On September 2, 2026, US Customs and Border Protection (CBP) published an Advanced Notice of Proposed Rulemaking (ANPRM) titled “Heightened Import Disclosures for Supply Chain Visibility” seeking comments on new import requirements designed to ensure compliance with customs laws and increase supply chain visibility. This ANPRM is in response to President Trump’s June 3, 2026, Executive Order titled “Strengthening Customs Enforcement,” directing stricter new requirements for importers of record (IORs), and particularly foreign importers of record. 

This ANPRM will be used to draft the Notice of Proposed Rulemaking (NPRM) (the actual regulations). The ANPRM seeks trade community feedback on the following:

  • Requiring importers to maintain and provide foreign export documentation that had been submitted to foreign customs authorities, including export declarations, commercial invoices, packing lists, export licenses or permits and transport documents (such as bills of lading or airway bills), so that CBP can screen for and identify discrepancies that could indicate violations of customs laws, such as false-invoicing. CBP is seeking information on types of documentation that should be requested, as well as when and how it should be submitted.
  • Redefining or replacing the use of the manufacturer or shipper identification code (MID) with an alternative that provides clearer identifying information of parties to the import transaction to support CBP enforcement purposes in case of violations of customs laws. The MID is a code constructed pursuant to instructions specified by CBP to identify manufacturers and/or shippers.
  • The use of Global Business Identifiers (GBIs) as a replacement or supplement to the MID. A GBI is a unique identifier issued by the private sector to help companies map and trace their supply chains. Use of the GBI reflects a desire by CBP to track all parties that may have been involved in the supply chain or chain of title to the goods and detect any intermediaries of interest or concern.
  • Use of innovative supply chain tracing solutions such as artificial intelligence programs to prevent illegal transshipment.
  • Expanding the Customs Trade Partnership Against Terrorism (CTPAT) program to incentivize supply chain tracking. CTPAT is a voluntary program where businesses agree to work with CBP to increase supply chain visibility, identify security gaps, implement specific security measures and best practices and receive certain benefits such as shorter wait times at the border, reduced CBP examinations, among others.

The ANPRM includes extensive questions on each proposal that can be addressed by interested parties through comments. Comments are due by December 1, 2026.  The ANPRM is available here.