CBP Wants Your Supplier's Export Declaration: The Heightened Import Disclosures ANPRM, Explained (Comments Due December 1, 2026)

CBP Wants Your Supplier's Export Declaration: The Heightened Import Disclosures ANPRM, Explained (Comments Due December 1, 2026)

On Wednesday, September 2, 2026, U.S. Customs and Border Protection published an advance notice of proposed rulemaking in the Federal Register titled "Heightened Import Disclosures for Supply Chain Visibility" (91 FR 56408, Docket No. USCBP-2026-1058, RIN 1685-AA47). It is seven pages long, asks 64 numbered questions, and proposes nothing that is enforceable today. Comments are due December 1, 2026.

Read it anyway. An ANPRM is where CBP tells you what the next rule is going to look like before it writes it, and this one describes the largest change to the entry data set since the Mod Act. Four of its proposals would touch every formal entry filed in the United States: a requirement to submit the foreign export declaration your supplier filed with its own customs authority, a replacement for the manufacturer identification code (MID) with real business identifiers, disclosure of the ultimate delivery party behind the consignee, and a shorter entry filing deadline than the current 15 days. A fifth would turn CTPAT from a voluntary security program into a data-sharing program with a prohibition on foreign-controlled logistics platforms.

None of this is effective. All of it is coming. Here is what the document actually says, in the order CBP wrote it.

Where This Came From

The ANPRM implements Section 3 of Executive Order 14411, "Strengthening Customs Enforcement," signed June 3, 2026 (91 FR 35125). Section 3(a) told DHS to require disclosure of foreign tax and global business identifiers and "detailed information about the supply chain and production methods" of imported goods. Section 3(b) told DHS to mandate submission of "any documentation or information that the foreign exporter was required to submit to the foreign customs administration prior to exporting to the United States." The same order produced the August 19 CBP notice on importer-of-record data accuracy that brokers have been circulating for two weeks.

CBP grounds its authority in 19 U.S.C. 1484 and 1485 (entry documentation), 1431 (manifest), 1508 and 1509 (recordkeeping and audit), and the general rulemaking power in 19 U.S.C. 1624. The regulations in play are 19 CFR parts 141, 142, 143, and 163. That list matters: it means CBP believes it can do most of this by regulation, without new legislation.

Proposal 1: The Foreign Export Declaration Comes to CBP

This is the headline. CBP is considering requiring the importer of record to obtain and either transmit or retain the documentation the foreign exporter submitted to *its* customs authority for the same shipment. The notice lists what that could include:

- The export declaration itself, showing the value, classification, and quantity declared on the way out - The commercial invoice as presented to the foreign customs authority - Packing lists, certificates of origin, export licenses or permits, and the transport documents filed with the foreign export manifest

CBP says the purpose is "verifying and reconciling entry and entry summary information" and detecting "dual-invoicing" — the practice of showing one value to the exporting country and a lower one to CBP. Questions 1 through 18 ask whether this should apply to all goods or a subset, whether the document should travel with the entry or sit in the importer's records under 19 U.S.C. 1508, whether CBP should pull it randomly, how long it should be retained, how a non-English declaration should be handled, and — the question every importer should answer — what it costs and how long it takes to get the document from a supplier today (Q16, Q18).

Questions 19 through 23 add a national-security layer: authority for the Secretary to designate categories of imports as posing "an unusually high or grave risk" and require the foreign export documentation as a condition of entry for those categories. That phrase — condition of entry — is the one that moves cargo. A document you can supply later is a recordkeeping burden. A document you must supply before release is a hold.

Proposal 2: The MID Is Going Away

CBP says plainly that the manufacturer identification code "provides limited identifying information," "is not always a consistent or unique number," and can produce "the same MID for multiple entities." It is asking (Q24–Q36) whether to replace it with the actual name and physical address of the manufacturer, shipper, and exporter; whether to collect the producer as defined in 19 CFR part 102 rather than the manufacturer; whether the identifier should be required at entry, entry summary, *and* on the manifest; and whether online marketplaces that facilitated the sale should be named.

Q34 asks whether CBP should require identification of "the party to which the merchandise is ultimately intended to be delivered, who may not be the initial recipient or the consignee." That is a direct shot at the consolidator, 3PL, and forwarder-as-consignee models, and at bonded and in-bond moves where the party of record at the pier is not the party that ends up with the goods. Q35 and Q36 ask which booking and logistics platforms you use to transmit shipping instructions, and whether you can verify your data is not being "altered, shared with, or stored by unauthorized entities" — with LOGINK named by name.

The replacement CBP is pointing toward is the Global Business Identifier test it has run since December 2022 (87 FR 74157), which accepts D-U-N-S, GLN, LEI, and Altana ID for the manufacturer, shipper, and seller. Q37–Q45 ask whether a GBI should become mandatory at entry, whether foreign tax IDs should accompany it, and whether a product-level identifier (model number, composition, grade) should be added.

Proposal 3: A Shorter Entry Window

Buried at Q43: "Would requiring entry to be filed sooner benefit CBP in reviewing supply chain documentation, and determining the admissibility of merchandise sooner?" The current rule, 19 CFR 141.5, allows entry within 15 calendar days after landing, or after arrival at the port of destination for merchandise transported in bond. The ANPRM's own footnote notes that Entry Type 86 filers were already required to file prior to or upon arrival. CBP is asking what an earlier deadline does to data availability, broker operations, and cost.

Put Proposal 1 and Proposal 3 together and the operational picture is clear: CBP would like more documents, from a party overseas you do not control, on a shorter clock. Whatever the final rule says, the importers who get hurt are the ones whose suppliers cannot produce an export declaration inside the entry window.

Proposal 4: Supply Chain Tracing Technology and a New CTPAT

Section III.C (Q46–Q55) asks what traceability tools the private sector already uses, whether importers should be *responsible* for using them to give CBP visibility, and whether technology can "certify" data elements like country of origin. The stated target is illegal transshipment, and CBP references its own AI-driven screening.

Section III.C.2 (Q56–Q61) is the CTPAT rewrite. CBP asks whether all CTPAT partners, or certain tiers, should be required to use supply chain tracing technology and make it "visible to CBP"; whether the minimum security criteria should add cybersecurity and data-integrity requirements; and whether the criteria should prohibit the use of "covered logistics platforms" identified as national security risks, again naming LOGINK. Q61 asks for the capital, training, and integration cost of migrating off such a platform. If your forwarder, NVOCC, or overseas supplier books on a platform CBP later designates, CTPAT status could turn on switching.

What It Would Cost

CBP does not estimate a cost. It designates the ANPRM a "significant regulatory action" under E.O. 12866 and asks importers to supply the numbers (Q62–Q64), with specific attention to small businesses and to "the availability and continuity of critical goods (including medical products)." The most useful comments, CBP says, are the ones with data it can recreate.

The honest answer for most mid-market importers is that the cost is not the filing — brokers will build the ABI fields the way they built Type 12 for copper. The cost is the lead time. A supplier's export declaration is filed by the supplier's forwarder or trading company with the supplier's customs authority, in the supplier's language, often after the vessel has sailed. If that document becomes a condition of entry for a designated category, or entry has to be filed sooner than day 15, the gap between arrival and a complete entry package is measured in dwell days.

The Number to Watch Is 15

Every proposal in this ANPRM lands on the same rule: 19 CFR 141.5, entry within 15 days of arrival. Under 19 CFR part 127, merchandise not entered within that window is sent to General Order — moved by the carrier to a bonded GO warehouse at the importer's expense, where it accrues storage until entered, exported, or, after six months, sold at auction.

If foreign export documentation becomes a condition of entry, GO is the default destination for any container whose supplier is slow. That is not hypothetical: it is how CBP already handles cargo with an incomplete package today, and CBP's own August 19 notice on importer-of-record accuracy has brokers reporting more rejected entries, not fewer. A shorter filing deadline makes the same outcome arrive faster.

Two things stop the clock. A type 21 warehouse entry is an entry — it satisfies 141.5, takes the container off the terminal and out of demurrage, and lets the goods sit in a CBP-bonded warehouse for up to five years with no duty assessed until withdrawal. The consumption entry, with whatever documentation CBP ends up requiring, gets filed when the package is complete. And if a container has already tipped into General Order, it can still be entered from the GO warehouse, exported, or transferred into bond — as long as the importer moves before the six-month auction date.

The practical read: importers whose overseas documentation is reliably available at departure will absorb this rule as a broker line item. Importers whose documentation arrives late — trading-company sourcing, consolidated origins, suppliers who file export declarations post-sailing — should already have a bonded warehouse and a GO plan at their port of entry, because the ANPRM describes a regime in which "we're waiting on the supplier" is the reason cargo stops.

What to Do Before December 1

File a comment. This is the one window where importers set the terms. Answer Q7 and Q16 (do you retain export documentation today, and how long does it take to get it), Q18 (the cost), Q43 (what an earlier entry deadline does to your operation), and Q62 (small-business and critical-goods impact). Reference the question numbers; CBP asked for that. Submit via regulations.gov under Docket USCBP-2026-1058.

Ask every supplier for last quarter's export declarations now. Not because you have to, but because the answer — how long it takes and whether the value matches your entry — tells you which SKUs and suppliers become a problem when the rule is real. Dual-invoicing you did not know about is the discrepancy CBP built this rule to find.

Get a GBI. The D-U-N-S / GLN / LEI test is voluntary today and the identifier CBP is pointing toward tomorrow. Collecting your suppliers' identifiers now is cheap; doing it under a mandate with a deadline is not.

Audit your logistics platform exposure. If any party in your chain books on LOGINK or another platform that could be designated, find out now. The CTPAT questions make clear CBP intends to draw that line.

Map your GO exposure at each port. Know which bonded and General Order warehouses serve your port of entry, what a type 21 entry costs per pallet, and who calls the carrier before the container is moved to GO. Estimate what you would be deferring with the Duty Deferral Calculator, and see how the bonded route interacts with the current duty stack in our in-bond transit guide and the General Order cargo explainer.

Importers reconciling supplier export values against their own entry lines — the exact comparison this rule would institutionalize — often run classification and landed-cost checks per SKU through software such as Zonos before the container ships. (Disclosure: this is an affiliate link — FreightFigures may earn a commission if you sign up, at no additional cost to you. See our full affiliate disclosure.)

FAQ

Is any of this in effect now? No. The September 2, 2026 document is an advance notice of proposed rulemaking. It proposes nothing binding; it collects comments through December 1, 2026 that CBP says it may use to draft a Notice of Proposed Rulemaking. A final rule would follow a second comment period.

What foreign export documentation would CBP require? The ANPRM lists export declarations, commercial invoices as presented to the foreign customs authority, packing lists, certificates of origin, export licenses or permits, and transport documents filed with the foreign export manifest. CBP is asking whether these should be transmitted with the entry, retained as records, pulled at random, or required as a condition of entry for designated high-risk categories.

Is the MID being eliminated? CBP says the MID is inconsistent, non-unique, and often unavailable early enough to be useful, and asks whether to replace it with the actual identity of the manufacturer, shipper, and exporter, potentially via Global Business Identifiers (D-U-N-S, GLN, LEI, Altana ID) already accepted in the voluntary GBI test.

Would the entry filing deadline change? Q43 asks whether requiring entry sooner than the current 15 days after arrival (19 CFR 141.5) would benefit CBP and what it would cost brokers and carriers. No new deadline is proposed yet.

How does a bonded warehouse fit? A type 21 warehouse entry satisfies the 15-day entry requirement and stops the General Order clock without assessing duty. Goods can remain in bond up to five years while the importer assembles whatever documentation the consumption entry requires. It does not exempt the eventual consumption entry from any disclosure rule CBP adopts.

How do I comment? Submit through regulations.gov, Docket No. USCBP-2026-1058, by December 1, 2026, referencing the specific question numbers you are addressing. CBP has said the most useful comments include cost data it can recreate.

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