Heightened Import Disclosures ANPRM: supply-chain visibility comments still open
Oct 5 status on CBP's Heightened Import Disclosures ANPRM: comment window still open through December 1, with GBI and IOR identity programs already moving in parallel.
As of October 5, 2026, CBP's advance notice of proposed rulemaking on Heightened Import Disclosures for Supply Chain Visibility is still open for comment. The ANPRM published September 2, 2026 at 91 FR 56408 (FR Doc. 2026-17926; Docket USCBP-2026-1058; RIN 1685-AA47). Comments are due December 1, 2026. This is not a final rule.
The notice implements the public-comment stage for Section 3 of Executive Order 14411 (Strengthening Customs Enforcement; signed June 3, 2026; 91 FR 35125). CBP is asking how to collect foreign export documentation, harden party identifiers (MID / GBI), require tracing technology, and deepen CTPAT criteria so illicit and illegally transshipped imports are easier to detect.
Comment window is open through December 1, 2026 on Docket USCBP-2026-1058. Put cost, lead time, and phased-in design on the record before CBP drafts an NPRM.
How this relates to the earlier Library ANPRM note
We already published a comment-prep walkthrough in CBP Heightened Import Disclosures ANPRM: what to comment on by December 1. Use that for the four proposal buckets and sample comment angles. Use this piece as the Oct 5 status check: the docket is still open, the EO Section 3 mandate has not changed, and related identity / GBI workstreams are moving in parallel.
Docket: USCBP-2026-1058 · RIN 1685-AA47
Comments due: December 1, 2026
EO backdrop: E.O. 14411 §3 · 91 FR 35125
Potential CFR targets: 19 CFR parts 141, 142, 143, and 163
What CBP is testing in the ANPRM
- Foreign export documentation: whether importers must submit (or retain) the pack the foreign exporter filed with the foreign customs authority before export to the United States.
- Party identifiers: whether Manufacturer Identification Codes (MIDs) should be replaced or supplemented with Global Business Identifiers (GBIs), and how manufacturer / shipper / exporter data should be declared.
- Traceability technology: what private-sector supply-chain tracing tools exist, how they verify raw-material origin, and how they could integrate with ACE and PGA data.
- CTPAT: whether minimum security criteria should expand to match the disclosure and tracing asks above.
Even before any NPRM, CBP is tightening importer identity and expanding GBI collection paths. See CBP is voiding IOR numbers for inaccurate Form 5106 data and the Entry PRA GBI expansion. Comments that ignore those live programs will read as outdated to the rule writers.
Broker and importer action while the docket is open
File comments that quantify lead time to obtain foreign export packs, current 19 U.S.C. § 1508 retention practice, GBI readiness (D-U-N-S, GLN, LEI, Altana ID, or none), and CTPAT cost if criteria deepen. Prefer recreatable numbers over general opposition. If you broker foreign IORs, say so explicitly: identity-data quality and GBI adoption are harder when the importer is offshore.
This ANPRM does not change drawback eligibility by itself. If CBP later requires foreign export packs, GBI party identifiers, or tracing artifacts at entry, those same records will become part of the import package you need for a clean drawback claim: matching commercial docs, producer identity, and origin story. Build retention and supplier-access into your comment so a future NPRM does not invent a document set you cannot get when you file for refund.
- ANPRM still open as of Oct 5, 2026: Heightened Import Disclosures for Supply Chain Visibility (91 FR 56408; FR Doc. 2026-17926; Docket USCBP-2026-1058; RIN 1685-AA47).
- Implements E.O. 14411 Section 3. Comments due December 1, 2026. Not a final rule.
- Four buckets: foreign export docs, MID/GBI party identifiers, tracing tech, CTPAT criteria.
- Cross-link live identity programs: Form 5106 voiding and Entry PRA GBI expansion.
- Drawback: no eligibility change yet, but future disclosure rules will harden the import docs refund claims rely on. Comment with cost, lead time, and phased design.
- Heightened Import Disclosures for Supply Chain Visibility (91 FR 56408; FR Doc. 2026-17926) · U.S. Customs and Border Protection
- Strengthening Customs Enforcement (Executive Order 14411; 91 FR 35125) · Executive Office of the President
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.