CBP Heightened Import Disclosures ANPRM: what to comment on by December 1

On September 2, 2026, CBP published an advance notice of proposed rulemaking on Heightened Import Disclosures for Supply Chain Visibility. Comments are due December 1, 2026. This is not a final rule. It is the public comment stage for how CBP may implement Section 3 of Executive Order 14411.

The ANPRM asks whether importers should hand over foreign export documentation, replace or supplement the Manufacturer Identification Code (MID) with Global Business Identifiers (GBIs), adopt supply-chain traceability technology, and accept deeper CTPAT minimum security criteria. If you import or broker, the comment docket is where the compliance cost gets shaped.

Comments on Docket USCBP-2026-1058 close December 1, 2026. The ANPRM is the place to put cost, feasibility, and phased-in design on the record.

EO 14411 Section 3 is the mandate

Executive Order 14411, Strengthening Customs Enforcement (signed June 3, 2026; published at 91 FR 35125), directs heightened import disclosure and certification requirements. Section 3(a) covers foreign tax and global business identifiers, plus detailed supply-chain and production-method information. Section 3(b) directs DHS to require submission of documentation the foreign exporter had to submit to the foreign customs administration before exporting to the United States.

CBP's ANPRM (91 FR 56408; Docket USCBP-2026-1058; RIN 1685-AA47) is the formal ask for data before an NPRM. Comments will feed a potential proposed rule amending 19 CFR parts 141, 142, 143, and 163.

Four proposal buckets to comment on

1. Foreign export documentation

CBP is considering requiring documentation the foreign exporter filed with the foreign customs authority: export declarations, commercial invoices, packing lists, certificates of origin, export licenses or permits, and transport documents that were part of the foreign export manifest. The open questions are hard: transmit at entry vs. retain as a recordkeeping requirement; who is responsible; how long to keep the file; how to handle non-English docs; whether CTPAT-validated importers get different treatment; and whether national-security-designated categories require submission as a condition of entry.

2. MID reform and Global Business Identifiers

The ANPRM flags the limits of today's Manufacturer Identification Code: it is constructed from name and address, is not always unique, and often arrives too late for enforcement. CBP wants views on collecting manufacturer, shipper, and exporter identifying data; defining "producer" consistently with 19 CFR part 102; and whether marketplace facilitators or ultimate-delivery parties should be declared.

On GBIs, CBP points to the voluntary NCAP test (87 FR 74157; updated discussion at 90 FR 38479). Test identifiers include D-U-N-S®, GLN, LEI, and Altana ID. Questions cover whether GBIs should be mandatory at entry or entry summary, whether foreign tax identifiers are feasible, and whether a product-level identifier (model/style, composition, grade, size) is more workable than an entity-level GBI.

3. Traceability technology

CBP frames illegal transshipment as a revenue and economic-security problem and asks what private-sector tracing tools already exist, how they verify origin of raw materials, how they integrate with ACE and PGA data, what AI is doing in those stacks, and what the cost curve looks like for small vs. large importers. This is where importers who already run supplier-mapping or batch-trace systems can put real tooling, not theory, on the docket.

4. CTPAT expansion

The ANPRM asks whether CTPAT partners should be required to use enhanced tracing technologies, share that visibility with CBP, expand minimum security criteria for cybersecurity and data integrity, and restrict "covered logistics platforms" identified as security risks (the notice names LOGINK-style foreign-controlled systems as an example). If you are CTPAT-validated, comment on tiering, benefits that would actually change behavior, and migration cost if logistics-platform restrictions land.

What to prepare before December 1

• Map which foreign export documents your suppliers can produce today, in what language, and in what lead time.
• Inventory MID quality problems and any GBI already held by manufacturers, shippers, or sellers.
• Document current supply-chain visibility tools, ACE touchpoints, and annual cost for small vs. high-volume filing entities.
• If CTPAT, estimate MSC expansion and logistics-platform transition costs with capital, training, and delay figures.
• Answer CBP's phase-in questions: by entry type, commodity, country, mode, small-entity timelines, or voluntary tests.
• File on regulations.gov under docket USCBP-2026-1058; reference specific question numbers (Q1–Q64).

Program contacts listed in the ANPRM for party-identification and foreign-export-documentation questions: Brandon Lord and Salvatore Ingrassia at supplychainvisibility@cbp.dhs.gov or (202) 325-4369. CBP's Strengthening Customs Enforcement trade page collects related EO 14411 implementation items.

This article is for general information and is not legal or tax advice. Drawback eligibility depends on your specific facts, and final refunds are determined by CBP at liquidation. Consult a licensed customs broker or attorney for your situation.