CBP Wants Your Supplier's Export Filing: 5 Things Every Importer Must Know

On September 2, 2026, CBP quietly published the most sweeping proposal to expand importer disclosure requirements in decades. If finalized, you'll need to know — and prove — far more about your foreign suppliers, their export filings, and every party that touches your goods before they reach U.S. soil. Here's exactly what's being proposed, why it matters, and what you should do before the December 1 comment deadline.

Right now, when you file an entry summary with CBP, you provide a Manufacturer Identification Code (MID) — a string of letters and numbers that's supposed to tell CBP who made your goods. In practice, the MID is a mess. CBP says it plainly in the new rulemaking notice: the code "provides limited identifying information," "is not always a consistent or unique number," and frequently produces "the same MID for multiple entities." Two completely different factories can share the same MID, and CBP often doesn't receive it early enough to do anything useful with it.

That system is about to change — potentially in a dramatic way. On September 2, 2026, CBP published an Advance Notice of Proposed Rulemaking (ANPRM) titled "Heightened Import Disclosures for Supply Chain Visibility" (91 FR 56408, Docket No. USCBP-2026-1058). The notice implements Section 3 of Executive Order 14411, "Strengthening Customs Enforcement," signed by President Trump on June 3, 2026, which directed DHS and CBP to overhaul how the government tracks goods, parties, and money flowing through U.S. customs.

This isn't a final rule. It's not even a proposed rule yet. It's CBP asking pointed questions — 50-plus of them — about what importers should be required to know, keep, and disclose. But if you've been in this business long enough, you know that when CBP asks questions this specific, they already have a direction in mind.

What Executive Order 14411 Set in Motion

To understand the ANPRM, you need to understand the executive order behind it. EO 14411, published in the Federal Register at 91 FR 35125 on June 10, 2026, is the most comprehensive customs enforcement directive in years. It covers everything from importer-of-record eligibility to broker penalties to forced-labor enforcement.

The key provisions driving this ANPRM:

• Section 3 directs CBP to establish "heightened import disclosure requirements" and collect additional information about foreign exporters, supply chains, and imported merchandise
• Section 4 establishes a minimum penalty floor of not less than 50% of the assessed penalty for customs violations, absent exceptional circumstances
• Section 2 tightens rules for foreign importers of record, including new bonding, vetting, and disclosure requirements
• The order prioritizes enforcement of forced labor violations, misclassification, undervaluation, and illegal transshipment, including under the Enforce and Protect Act (EAPA)

In other words, the government wants to see deeper into your supply chain, and it's raising the cost of getting caught with bad data.

The Five Big Proposals in the ANPRM

The ANPRM covers five major areas. None of these are requirements yet — CBP is soliciting input — but each one signals where enforcement is heading.

1. Foreign Export Documentation

This is the headline item. CBP is asking whether importers should be required to obtain and retain the export declarations that their foreign suppliers file with their own country's customs authorities. Think about that for a moment: CBP wants to see what your Chinese manufacturer told Chinese customs about the same shipment you're declaring to U.S. customs.

The types of documents CBP is considering requiring include:

The enforcement logic is straightforward: if your entry summary says the goods are worth $50,000 from Vietnam, but the Vietnamese export declaration says they're worth $200,000 from China, CBP has a transshipment case built on your supplier's own paperwork.

2. Replacing the MID with Global Business Identifiers

CBP is done with the MID. The questions in the ANPRM (Q24 through Q36) make clear the agency considers the current system broken and is exploring replacements. The leading candidates are Global Business Identifiers (GBIs) — standardized codes that uniquely identify a legal entity anywhere in the world:

• D-U-N-S Number — Dun & Bradstreet's 9-digit identifier, already widely used in government procurement
• Global Location Number (GLN) — GS1's 13-digit identifier for locations and legal entities
• Legal Entity Identifier (LEI) — the 20-character ISO standard used in financial regulation
• Altana ID — a supply-chain-specific identifier already accepted in CBP's voluntary GBI pilot

CBP is asking whether GBIs should be required for manufacturers, shippers, and exporters — and whether they should be provided at the time of entry, not just entry summary. That's a critical distinction. Entry happens when goods arrive; entry summary happens up to 10 working days later. Requiring GBIs at entry means the data has to be ready before your goods hit the dock.

3. Foreign Tax and Business Identifiers

Beyond GBIs, CBP is exploring whether to collect foreign tax identification numbers for manufacturers and sellers. The idea is that a foreign tax ID ties a supplier to a specific legal entity in a specific jurisdiction — making it much harder to hide behind shell companies or opaque intermediary structures.

CBP is also asking about identifying online marketplaces and the ultimate delivery party for e-commerce shipments. This signals that the de minimis loophole and direct-to-consumer imports from platforms like Temu and Shein are squarely in CBP's crosshairs.

4. Supply Chain Tracing Technology

The ANPRM asks whether CBP should require or incentivize supply chain tracing and mapping technology — including AI-driven tools that can detect anomalies, flag transshipment patterns, and verify origin claims. CBP is exploring whether importers should be expected to deploy supply chain analytics as part of their reasonable care obligations.

This is where the ANPRM connects to the broader enforcement environment. CBP's Enforce and Protect Act (EAPA) investigations have surged — the agency announced over $1 billion in duty evasion cases in July 2026 alone. Technology-enabled supply chain verification isn't just a nice-to-have anymore; it's becoming the standard CBP expects.

5. CTPAT Overhaul

The Customs-Trade Partnership Against Terrorism (CTPAT) program is getting a potential makeover. CBP is considering:

• Mandatory supply chain tracing technology for CTPAT participants
• Cybersecurity minimum security criteria as a condition of membership
• Restrictions on foreign-controlled logistics platforms — specifically naming LOGINK, the Chinese state-backed logistics platform, as a potential concern
• Enhanced vetting of supply chain partners

For companies that have invested in CTPAT Tier 2 or Tier 3 status, these changes could mean significant new compliance obligations. For companies that haven't joined CTPAT, the enhanced requirements might make the program either more valuable (if it provides enforcement relief) or less attractive (if the compliance cost outweighs the benefits).

Why This Matters More Than You Think

Here's what makes this ANPRM different from the typical Federal Register notice that gets filed and forgotten: it has teeth behind it.

Executive Order 14411 didn't just direct CBP to ask questions. It directed the agency to increase audits, enforce liquidated damages claims against bonds, restrict in-bond utilization, and impose maximum penalties on brokers who fail to conduct due diligence, repeatedly represent noncompliant clients, or fail to cooperate with CBP information requests.

The minimum penalty floor of 50% of assessed penalties means that even if you cooperate fully, your mitigation options are cut in half compared to historical norms. That's a fundamental change in the cost-benefit calculus of customs compliance.

Consider the financial exposure across different violation types:

When CBP can compare your entry data against your supplier's foreign export filing, proving negligence — or worse — becomes dramatically easier. Every inconsistency between the two declarations is a red flag that requires explanation.

The Transshipment Problem Driving Everything

To understand why CBP is pushing this hard, follow the money. The tariff differential between China and virtually every other country has created a massive financial incentive for illegal transshipment. Vietnam at 10% baseline versus China at 10% plus 25-30% Section 301 means a 25-35 percentage point duty gap on most non-metal products. On a $10 million annual import program, that's $2.5 to $3.5 million in potential duty savings — or duty evasion, depending on which side of the origin line you fall.

CBP's EAPA investigations have uncovered billion-dollar schemes involving goods routed through Southeast Asia with minimal processing, fraudulent certificates of origin, and shell companies designed to obscure the true manufacturer. The ANPRM is CBP's attempt to get ahead of this by requiring importers to produce documentation that makes transshipment schemes much harder to execute and much easier to detect.

What to Do Before December 1

The comment period closes on December 1, 2026. Here's how to use the time wisely:

1. Audit your supply chain documentation now — Can you produce a foreign export declaration for every active supplier? If not, start requesting them. Whether or not the rule is finalized, having this documentation demonstrates reasonable care.

2. Identify your suppliers' Global Business Identifiers — Check whether your key manufacturers and shippers already have D-U-N-S numbers, GLNs, or LEIs. If they don't, start the registration conversation now. D-U-N-S registration typically takes 5-10 business days for free or 1-2 days expedited.

3. Map your actual supply chain — Not your assumed supply chain, your actual one. Where are raw materials sourced? Where does manufacturing happen? Where does the export declaration get filed? Every gap in your knowledge is a gap CBP will eventually ask about.

4. Review your MID data — Pull your entry summaries for the past 12 months and verify that every MID maps to the correct, unique manufacturer. If you find duplicates or mismatches, correct them now rather than waiting for CBP to find them.

5. Submit comments — This is your chance to shape the rule. If a proposed requirement would be impractical, cost-prohibitive, or operationally impossible for your business, say so through the Federal eRulemaking Portal at regulations.gov under docket number USCBP-2026-1058. CBP reads these comments, and industry pushback has materially changed final rules in the past.

What Comes Next

The ANPRM is step one. After the December 1 comment deadline, CBP will review submissions and decide whether to issue a Notice of Proposed Rulemaking (NPRM) — the actual draft rule. That NPRM would have its own comment period before becoming final. Realistically, we're looking at 12-18 months before any of these proposals become binding requirements.

But here's the thing: CBP doesn't need a final rule to start asking questions. Under existing law, the agency can request production of records, conduct focused assessments, and investigate potential violations using the tools it already has. The ANPRM tells you what CBP considers important. Smart importers treat that as a preview of the next compliance audit checklist.

And the enforcement environment around this ANPRM is not theoretical. CBP is already voiding IOR numbers for inaccurate Form 5106 data as of September 18. It's already pursuing EAPA cases at record levels. The 50% minimum penalty floor from EO 14411 is already policy. The ANPRM may be aspirational, but the enforcement posture behind it is very much operational.

The Bottom Line

The era of "file and forget" customs compliance is ending. CBP is building toward a system where importers must demonstrate — with verifiable documentation — that they know who made their goods, who shipped them, what was declared on the export side, and how the entire supply chain connects. Whether or not every proposal in this ANPRM survives the rulemaking process, the direction is unmistakable.

The importers who start building this infrastructure now — mapping supply chains, collecting GBIs, obtaining foreign export documentation — won't just be ready for whatever rule CBP finalizes. They'll be demonstrating the kind of reasonable care that keeps auditors satisfied and penalties off the table. TariffLens helps trade teams stay ahead of exactly these kinds of regulatory shifts, tracking compliance requirements and flagging risks before they become enforcement actions.

This article is for informational purposes only and does not constitute legal, tax, or customs advice. Consult a licensed customs broker or trade attorney for guidance specific to your situation.