CBP Proposes Sweeping Import Disclosure and AI Supply Chain Tracing Rules Under EO 14411
In a major consolidation of executive authority over international trade, U.S. Customs and Border Protection (CBP) published a landmark Advance Notice of Proposed Rulemaking (ANPRM) on September 2, 2026, titled "Heightened Import Disclosures for Supply Chain Visibility" (91 Fed. Reg. 17926). The proposed regulations, which implement Section 3 of President Trump's June 3, 2026 Executive Order 14411 ("Strengthening Customs Enforcement"), represent an unprecedented expansion of federal oversight into global supply chains.
The ANPRM outlines several sweeping changes designed to detect customs fraud, forced labor, and illegal transshipments. Most notably, CBP is proposing to require importers of record to obtain and submit actual foreign export documentation—such as foreign export declarations, packing lists, and export licenses—that foreign exporters filed with their own domestic customs administrations prior to shipping goods to the United States. Trade experts warn that this requirement could deal a devastating blow to overseas suppliers, particularly China's export sectors, by exposing discrepancies in transshipment and valuation.
Additionally, CBP is evaluating a transition away from the legacy Manufacturer Identification (MID) code system. The agency proposes replacing or supplementing MIDs with a Global Business Identifier (GBI), which aggregates private-sector entity identifiers such as DUNS numbers, Legal Entity Identifiers (LEIs), and Altana IDs. The proposed rule also contemplates expanding the Customs Trade Partnership Against Terrorism (CTPAT) program to enforce strict cybersecurity and data integrity criteria, potentially prohibiting the use of foreign-controlled logistics platforms like China's LOGINK. To enforce these rules, CBP plans to integrate advanced, AI-driven supply chain tracing solutions to detect illegal transshipments before goods reach the U.S. border.
"On September 2, 2026, CBP issued an advance notice of proposed rulemaking ('ANPRM') titled, 'Heightened Import Disclosures for Supply Chain Visibility.'... The proposals target three areas: 1. enhanced identification of parties involved in importation; 2. integration of technical tracing solutions; and 3. collection of foreign export documentation." — Crowell & Moring LLP, International Trade Law Advisory, September 2, 2026
"Section 3 of E.O. 14411 directly mandates CBP to establish heightened import disclosure requirements, including: (a) disclosure of foreign tax identifiers, global business identifiers, and detailed supply chain and production method information; and (b) submission of documentation that foreign exporters were required to file with their own customs administrations prior to export to the United States." — Crowell & Moring LLP, International Trade Law Advisory, September 2, 2026