CBP Moves to Strengthen Import Supply Chain Transparency

On September 2, 2026, U.S. Customs and Border Protection (CBP) published an Advance Notice of Proposed Rulemaking (ANPRM) titled “Heightened Import Disclosures for Supply Chain Visibility.” The initiative explores whether U.S. importers may eventually be required to provide and retain more detailed information about the foreign suppliers, manufacturers, exporters and other parties involved in an international transaction.

Importantly, this is not a final rule and does not create new mandatory requirements today. Instead, CBP is asking the trade community to provide feedback on how expanded import disclosures could work in practice. Comments are currently due by December 1, 2026.

However, the proposal provides an important indication of where U.S. customs compliance may be heading.

From Import Documentation to Supply Chain Visibility

Traditionally, U.S. import compliance has focused heavily on information such as the importer of record, tariff classification, customs value, country of origin and entry documentation.

CBP’s latest proposal suggests a broader approach.

The agency is considering whether importers should have greater visibility into the supply chain behind an imported product, potentially including information generated before the goods reach the United States.

Areas being examined include:

• Foreign export declarations and related customs documents
• Commercial invoices and packing information
• Certificates of origin and other supporting records
• Identification of manufacturers, exporters, sellers and other supply chain participants
• More detailed business identification information
• Technologies that can help trace products and supply chains
• Potential changes involving the Customs Trade Partnership Against Terrorism (CTPAT) program

The underlying objective is straightforward: CBP wants to be able to connect the information reported at U.S. entry with the commercial and manufacturing activities that occurred earlier in the supply chain.

Why Country of Origin Is Becoming More Important

For U.S. importers, one of the most important implications is the growing importance of country of origin compliance.

The issue is particularly relevant when products move through multiple countries before entering the United States.

For example, a product may be manufactured in China, shipped to Vietnam for additional processing, and subsequently exported to the United States. Simply changing the shipping route does not automatically change the product’s country of origin.

This distinction has become increasingly important as U.S. authorities intensify efforts to identify illegal transshipment and tariff evasion.

A recent White House report has highlighted concerns about goods being rerouted through third countries to avoid U.S. tariffs. The report specifically discussed transshipment risks involving countries across Asia and other major trading partners.

For importers, this means that “Where was the shipment exported from?” and “Where was the product actually manufactured?” are not necessarily the same question.

What This Could Mean for U.S. Importers

If elements of the proposal eventually become mandatory, importers may need to work more closely with overseas suppliers to obtain reliable supply chain information before goods are shipped.

This could affect several areas of an importer’s compliance program.

1. Supplier Documentation

Importers may need stronger procedures for collecting and retaining documentation from overseas suppliers.

Commercial invoices, packing lists, certificates of origin, export declarations and transportation records could become increasingly important when CBP reviews the consistency of an import transaction.

2. Manufacturer and Supplier Identification

Knowing the immediate seller may no longer be sufficient for some higher-risk transactions.

Importers may need to understand who actually manufactured the goods, where production occurred and which companies participated in the transaction.

3. Data Consistency

Information provided to U.S. Customs should be consistent with the underlying commercial records.

Differences in product descriptions, quantities, values, classification or country of origin can create additional questions during a customs review.

4. Transshipment Risk

Companies sourcing from multiple Asian countries should pay particular attention to country of origin and substantial transformation.

This is especially relevant for businesses using manufacturing or sourcing networks involving China, Vietnam, Thailand, Malaysia and other regional production hubs.

5. Customs Compliance Systems

The proposal also points toward greater use of technology and supply chain tracing.

For larger importers, this could eventually increase the importance of integrating supplier information, customs records and logistics data into a more consistent import compliance management system.

Why This Matters Even Before a Final Rule

The most important point for importers is that the proposal is not yet a new customs filing requirement.

Nevertheless, it should not be ignored.

The direction of U.S. trade enforcement is becoming increasingly clear: customs authorities are seeking greater visibility into the parties, documents and activities behind imported goods.

Recent trade developments also show that U.S. authorities are paying closer attention to tariff avoidance, origin claims and supply chain structures. At the same time, U.S. import volumes remain substantial, keeping customs enforcement and supply chain efficiency high on the agenda for retailers and importers. The Wall Street Journal recently reported that September 2026 is expected to be one of the busiest months of the year for U.S. imports, despite tariff and logistics pressures.

For companies importing regularly into the United States, this makes data accuracy and supply chain visibility increasingly important parts of customs compliance.

What Should U.S. Importers Do Now?

There is no need to change every import procedure immediately based on a proposal that has not yet become final.

However, importers can use this period to review their current compliance processes.

A practical checklist includes:

Review your suppliers
Can you identify the actual manufacturer and exporter behind your products?

Check country-of-origin records
Can you clearly explain where the product was manufactured and whether any processing occurred in a third country?

Keep supporting documents
Maintain commercial invoices, packing lists, certificates of origin, export documents and transportation records where applicable.

Review product data
Make sure descriptions, quantities, values and HS classifications are consistent across commercial and customs documentation.

Assess transshipment exposure
If your products move through several countries, confirm that the origin determination is properly supported.

Communicate with your customs broker and logistics partners
A strong customs compliance process depends on accurate information being shared before the shipment reaches the U.S. port.

The Bigger Picture

The latest CBP proposal represents more than another documentation discussion.

It reflects a broader shift in U.S. import compliance—from checking individual customs declarations toward gaining greater visibility into the supply chain behind those declarations.

For U.S. importers, the message is clear: knowing your supplier may no longer be enough. Understanding your supply chain is becoming increasingly important.

Companies that maintain accurate supplier records, reliable country-of-origin information and consistent import documentation will be better positioned to respond as U.S. Customs continues to strengthen enforcement.

As CBP reviews industry feedback through December 1, 2026, importers should continue monitoring the development and be prepared for potential changes to future customs clearance, import documentation and supply chain compliance requirements.

Disclaimer: This article is provided for general trade and logistics information only. The CBP initiative discussed above is a proposed regulatory approach, not a final rule. Importers should consult their customs broker or qualified trade counsel regarding specific compliance requirements.