CBP wants to see further up your supply chain. Comments close 1 December 2026.
On 2 September 2026, U.S. Customs and Border Protection published an advance notice of proposed rulemaking, Heightened Import Disclosures for Supply Chain Visibility (91 FR 56408, docket USCBP-2026-1058). It is not a rule yet. It asks 64 questions about three things: the export documents your suppliers file abroad, who made, shipped and exported your goods, and the technology importers use to trace them.
- CBP ANPRM · THE DATES
- 3 Jun 2026E.O. 14411 signed
- 2 Sep 2026notice published
- 1 Dec 2026comments close
- Thena proposed rule, if CBP goes ahead
- 91 FR 56408advance notice
Where it stands.
Each line names the source it was checked against.
- Stage
- An advance notice of proposed rulemaking. Nothing is required yet. CBP says the comments may be used to draft a notice of proposed rulemaking. 91 FR 56408
- Comments
- Due on or before 1 December 2026, through regulations.gov under docket USCBP-2026-1058. Comments are posted publicly as submitted, personal information included. Cite the question numbers you answer. 91 FR 56408
- Why now
- Executive Order 14411, Strengthening Customs Enforcement (3 June 2026), told CBP to require the export documents foreign exporters file and more detail on the parties and production behind imported goods. E.O. 14411, 91 FR 35125
- What CBP is after
- Illegal transshipment and imports that get around U.S. law on forced labor, rules of origin, origin marking, intellectual property, revenue and product safety. Later questions add national security. 91 FR 56409
- Who would file
- Mainly the importer of record. CBP also asks whether customs brokers, foreign exporters and other parties in the chain should submit data directly, and whether small businesses and CTPAT members should get different timelines. ANPRM, Section III
- Rules it could change
- 19 CFR Parts 141, 142, 143 and 163: entry of merchandise, the entry process, special entry procedures and recordkeeping. 91 FR 56408
What CBP is asking, in four parts.
Export documents
Questions 1–23. Should importers file, or keep on record, the export declaration, commercial invoice, packing list, certificate of origin, export licence and transport documents their supplier filed abroad? For every import, at random, or for high-risk product and country categories?
Who made, shipped and exported it
Questions 24–45. Replace the manufacturer ID code with the full name and address of the manufacturer, shipper and exporter for each shipment. Declare online marketplaces and logistics platforms. Collect global business identifiers such as D-U-N-S, GLN, LEI and Altana ID.
Tracing technology
Questions 46–61. Which tools companies use to trace goods and verify where raw materials come from, whether importers should have to use them, identifiers and credentials for goods as they move, tracing requirements for CTPAT members, and a possible ban on covered logistics platforms such as LOGINK.
Costs
Questions 62–64. Costs and benefits, especially for small businesses and for critical goods such as medical products, and how to keep supply from being disrupted.
Records that answer questions like these.
CBP's questions are about shipments and the parties behind them. These guides cover the standards and records underneath.
EPCIS 2.0 explained
The GS1 standard for recording who did what to which goods, where and when.
Read the guide →GS1 Digital LinkGS1 Digital Link
One identifier on the product that opens its record.
Read the guide →Forced labourEU Forced Labour Regulation
The EU ban, and what apparel brands need to show.
Read the guide →EUDREUDR
The EU's plot-to-product rule, from 30 December 2026.
Read the guide →Supply chain mapWhere the supply chain breaks
Recalls, cargo theft and falsified medicines, mapped.
Read the guide →Every ruleGlobal compliance
The deadlines we track across the US, the EU and the UAE.
Read the guide →Where Aeroz fits, and where it doesn't.
Shipment questions, unit answers
The notice asks for data per shipment. Aeroz records each tagged unit: who handled it, where and when, as signed GS1 EPCIS events. Shipment answers can be drawn from unit records; unit answers can't be drawn from shipment records.
Identifiers that check out
CBP asks which technologies give goods identifiers and credentials as they move (Q53). Each Aeroz tag answers a tap with a new one-time code, beside the GS1 identifiers your partners already use.
Not a customs filing tool
Aeroz does not file entries or export documents with CBP. It keeps the custody record a filing can be checked against, alongside the customs broker and ERP you already use.
CBP supply chain visibility ANPRM, answered.
Is the CBP supply chain visibility rule final?
No. It is an advance notice of proposed rulemaking, published on 2 September 2026. Nothing is required yet. CBP says the comments may be used to draft a proposed rule.
When are comments due?
On or before 1 December 2026, through regulations.gov under docket USCBP-2026-1058. Comments are posted publicly as submitted, so leave out anything confidential.
Does the notice require RFID, blockchain or unit-level tracing?
No. It asks about shipment-level data and party identifiers, and asks open questions about tracing technology. It does not name RFID or blockchain; artificial intelligence is the only technology it names.
Who would have to comply?
Mainly importers of record. CBP also asks whether customs brokers, foreign exporters and other parties should submit data directly, and whether timelines should differ for small businesses, CTPAT members and high-volume filers.
What are the reference numbers?
Docket USCBP-2026-1058. The notice is 91 FR 56408, FR Doc. 2026-17926, RIN 1685-AA47, published by U.S. Customs and Border Protection on 2 September 2026.
Sources: Federal Register, 91 FR 56408 · Official PDF (govinfo) · Docket USCBP-2026-1058 · Executive Order 14411 · CBP announcement. Checked 26 October 2026. Not legal advice.
CBP's advance notice Heightened Import Disclosures for Supply Chain Visibility (91 FR 56408, 2 September 2026) asks 64 questions on foreign export documents, party identifiers and tracing technology. Comments close 1 December 2026 under docket USCBP-2026-1058.
- Stage
- advance notice
- Questions
- 64
- Docket
- USCBP-2026-1058
- Comments due
- 1 Dec 2026