Every shipment you import generates two sets of paperwork. You file one with U.S. Customs and Border Protection describing what is arriving. Your supplier files another with their own government describing what is leaving.
Those two documents describe the same goods, and today they never meet. They sit in different countries, in different systems, in different languages, and nobody compares them.
CBP is asking whether it should start collecting the second one.
What Is Actually Proposed
On September 2, 2026, CBP published an advance notice of proposed rulemaking titled Heightened Import Disclosures for Supply Chain Visibility (federalregister.gov). CBP announced it on its own newsroom the same week (cbp.gov), and it sits under the agency's Strengthening Customs Enforcement programme (cbp.gov). An advance notice is the earliest stage of rulemaking: not a rule, not even a proposed rule, but a set of questions the agency is asking before it drafts one. There are sixty-four of them.
Four things are on the table.
Foreign export documentation. The first question in the notice asks whether CBP should require the importer of record to submit foreign export documentation for all goods imported into the United States. That means the export declaration, commercial invoice, packing list and certificate of origin that your supplier lodged with their own customs authority before the goods left.
Party identification. CBP is considering replacing the Manufacturer Identification Code with Global Business Identifiers. The existing code is a string derived from a manufacturer's name and address, which makes it approximate by design; two different factories can produce the same code, and a change of address produces a different one for the same factory. A real entity identifier does not have those properties.
Supply chain tracing technology. The notice asks what technologies the private sector already uses to obtain visibility into supply chains and production methods, and raises artificial intelligence and blockchain approaches to real-time tracing.
CTPAT. The Customs Trade Partnership Against Terrorism programme could see its minimum security criteria expanded, with participants expected to use traceability technology and to avoid logistics platforms identified as security risks.
Why the First One Matters Most
The export document is the significant item, and it is worth being clear about why.
At the moment your declaration is the only account of the shipment that CBP holds. It can be checked against physical inspection, against other importers' entries, and against the reconstructed shipping route, but there is no independent statement of the same facts from the other end.
The foreign export filing is exactly that. It states what the exporter said the goods were, what they were worth, and where they came from, to a government that had no reason to be told anything convenient to a U.S. entry. Where the two accounts agree, that is corroboration. Where they diverge, the divergence is the finding, and it does not require anyone to prove intent to be worth a conversation.
Set next to the AI systems now reconstructing trade routes from shipment records, and the direction is not difficult to read: CBP is assembling the ability to see a shipment from both ends at once.
This Is the Stage Where It Can Still Change
Most compliance writing describes rules that already exist. This one does not exist yet, which makes it unusual and worth acting on.
Comments are open until December 1, 2026, under docket USCBP-2026-1058, and anyone can file one at www.regulations.gov/docket/USCBP-2026-1058 — there is a Comment button on the docket page and no special standing is required. Sixty-four questions is a lot of questions, and several of them are explicitly about feasibility and cost, including for small businesses.
That matters because the practical objections are real and are best made by people who actually import. Can a mid-size importer obtain their supplier's export filing at all? What happens when a supplier declines, or when the document is in a language nobody in the business reads? What is the answer where a trading company sits between the importer and the factory and treats the factory's identity as its commercial asset? None of that is obvious from inside an agency, and the comment period is when it can be said.
An agency that receives no comments from small importers writes a rule for the ones who commented.
What to Do Before Any Rule Exists
There is a readiness question underneath all of this, and it can be answered today without waiting for anything.
Ask your supplier for the export documentation on your most recent shipment. Not because a rule requires it, but to find out what happens when you ask.
Some suppliers will send it the same day. Some will not have it to hand and will need a week. Some will decline, and a few will explain that the entity that filed it is not the entity you buy from. Every one of those answers is useful, and the last two are the ones that would become a problem later.
The same test applies to identity. Do you know the actual manufacturer of each product you import, as a legal entity rather than a brand or a contact? If a Global Business Identifier requirement arrives, that is the question it asks, and an importer who buys through an agent may find they cannot answer it.
The Moral
Strip away the mechanism and the notice is asking one question: can the government see your supply chain?
The uncomfortable version of that question is whether you can. Most of the specific things being contemplated — who made this, where, filed under what identity, described how to whose authority — are things a well-run importing business would want to know regardless of whether anybody required it.
That is not a reason to welcome the rule, and there are legitimate arguments about cost and burden that deserve to be made in the comment period rather than after. But it does suggest where the effort is best spent now. An importer who already knows the answers is looking at a paperwork exercise. An importer who does not is looking at the discovery that they have been buying from somebody they cannot fully identify.
This is general commentary, not legal or customs advice, and it describes a proposal rather than a rule. Nothing here is a requirement yet, and what eventually gets written may differ substantially. Read the notice itself rather than any summary of it, this one included, and take advice from a licensed customs broker or trade counsel on your own position.
So — if you asked your three largest suppliers today for the export declaration they filed on your last shipment, how many could produce it this week? And what would you be using to keep those documents, and the entity identities behind them, once you had them?