CBP Seeks Input on New Supply Chain Traceability Requirements

Sep. 1, 2026
By: Austin J. Eighan

U.S. Customs and Border Protection (CBP) is requesting public comment on potential regulatory amendments that significantly expand documentation, recordkeeping, and disclosure requirements for imported merchandise. Following the White House’s recent report on alleged transshipment schemes, the announcement highlights proposals responsive to Executive Order 14411 (see our prior discussion on the EO here), which directs CBP to increase supply chain visibility, strengthen trade law enforcement, and “remedy systemic inefficiencies.”

The notice sets out approximately 64 questions covering the agency’s proposals in these areas:

• Foreign Export Documentation: CBP is considering whether foreign export documentation may assist CBP “in verifying and reconciling entry and entry summary information, and in detecting discrepancies that could indicate violations.” While CBP is asking for comment on which transmission and retention requirements should apply, the scope of documents could include export declarations, commercial invoices, packing lists, certificates of origin, export licenses, and transportation documents that foreign parties provide to customs authorities. CBP also asks whether importers should apply a standard of reasonable care when assessing the accuracy of these records.
• Expanded Party Identification: CBP is evaluating replacing or supplementing the current Manufacturer Identification Code (MID) entry data element by expanding the agency’s existing test of Global Business Identifiers (GBIs) to provide more detailed information identifying manufacturers, shippers, exporters, sellers, and other supply-chain participants.
• Supply-chain Tracing: CBP is exploring whether it should require importers to leverage technology, including artificial intelligence, to trace supply chains and verify production and origin information.
• Enhanced CTPAT Requirements: CBP is reviewing whether it should add supply-chain tracing technology, cybersecurity, and data-integrity requirements to the Minimum Security Criteria for participants in the Customs Trade Partnership Against Terrorism (CTPAT) program and offer additional benefits to those that meet enhanced standards.

In their submissions, CBP asks commenters to describe current supply chain tracing tools and visibility technologies, explain how they use those tools in practice, and provide data that supports their position on the impact of the proposed regulatory changes. The agency also seeks comment on potential implementation strategies, including the use of voluntary testing programs or phased rollouts by commodity, entry type, country, or transportation mode.

CBP encourages interested parties to submit comments within 90 days of the notice’s publication in the Federal Register (approx. December 1) via docket number USCBP-2026-1058. If your company would like to assess the potential impact of these proposals or would like assistance submitting comments to CBP, please reach out to one of our attorneys at Barnes, Richardson & Colburn.