On September 2, 2026, U.S. Customs and Border Protection published Federal Register document 2026-17926, Heightened Import Disclosures for Supply Chain Visibility, at 91 FR 56408.[1] The action line is an advance notice of proposed rulemaking. Comments are due December 1, 2026, on docket USCBP-2026-1058.[1] FederalRegister.gov is the unofficial XML copy. Anyone who needs legal notice should use the official edition on govinfo.[1]
CBP is asking whether the U.S. import packet should have to carry documentation the foreign exporter already filed with a foreign customs authority, a party identifier that does not collide across firms, and a tracing tool that can be checked before goods arrive or are released.[1] The notice opens a comment file. It does not adopt those requirements.
The longstanding manufacturer or shipper identification code sits at the center of that ask. Importers provide a MID at entry summary. CBP constructs it from the manufacturer or shipper name and address on the commercial invoice under Customs Directive 3550-055, dated November 24, 1986.[4] CBP now says that code provides limited identifying information, does not always name the party of enforcement interest, is not always available early enough, and is not always unique. Name, address, and country of origin can change over time. And the same MID can attach to multiple entities.[1]
Executive Order 14411, Strengthening Customs Enforcement, signed June 3, 2026, and published June 10, 2026, at 91 FR 35125, told Homeland Security to take steps on both identifiers and the foreign file.[2] Section 3(a) instructs the Secretary to take steps to require disclosure of certain foreign tax and global business identifiers, plus detailed information about the supply chain and production methods of goods imported into the United States.[1] Section 3(b) directs the Secretary to take steps to mandate submission of any documentation or information the foreign exporter was required to submit to the foreign customs administration prior to exporting to the United States.[1]
The notice lists the kinds of files that might fill that second instruction: export declarations showing declared value, classification, and quantity; commercial invoices showing the transaction value declared abroad; packing lists; certificates of origin submitted to the foreign authority; export licenses or permits; and transport documents such as a bill of lading or air waybill that were part of the foreign export manifest.[1] CBP is considering whether those records would help it verify and reconcile U.S. entry and entry-summary information, and whether they would help detect discrepancies that could indicate violations such as dual-invoicing.[1]
Illegal transshipment is the other named enforcement object. CBP describes it here as routing goods through a third country to obscure or misrepresent true country of origin.[1] "To combat such evasion," the notice says, "CBP has intensified its enforcement efforts, including evaluating artificial intelligence (AI)-driven solutions for pinpointing illegal transshipment risk."[1] It wants to use private-sector traceability tools to make decisions before goods arrive at, or are released from, the U.S. border.[1] Question 48 asks what role AI plays in driving those technologies.[1] Question 53 asks what technologies exist to assign unique entity identifiers and tamper-proof credentials documenting the movement of goods.[1] Those remain docket questions. No production system is named.
Question 61 asks what costs would follow if CTPAT minimum security criteria restricted or prohibited covered logistics platforms, with LOGINK named as an example of a foreign-controlled system identified as a national-security risk.[1] That sentence is a cost question in a comment file.
Last week's bulk-power order asked who made the relay in the cabinet and whether it can stay.[3] This notice asks whether the U.S. entry should have to carry the file the exporter already gave another customs service.
Susan S. Thomas, Executive Assistant Commissioner, Office of Trade, signed the document for publication after Commissioner Rodney S. Scott approved it.[1] CBP classifies the ANPRM as a significant regulatory action under Executive Order 12866.[1] This is orientation, not legal, customs, trade-compliance, or national-security advice. Anyone with filing duties needs the official text and qualified counsel.
Verification bottleneck
The scarce check is whether a U.S. entry can be reconciled against the foreign export declaration before a colliding manufacturer code is treated as identity.
- Private tracing scores and AI transshipment flags can move faster than CBP can say what those tools measured and how a score would map onto ACE.
- Importers, brokers, and CBP would have to compare the U.S. entry, the foreign export file, and a party identifier that does not collapse two firms into one code.
- Watch the December 1 comment file and any later proposed rule that actually names required fields.
Opportunities
Where value may appear is a dual-declaration worksheet. For one shipment it would line up U.S. entry fields against the foreign export declaration (value, classification, quantity, origin), the MID, any global business identifier if one exists, and who could produce the foreign file. Legal conclusions stay with a licensed broker or counsel.
A lighter companion is a CTPAT tracing inventory for one partner: which visibility tools are in use, whether CBP could see them, and whether any logistics platform in the chain is a covered foreign-controlled system. Idea fodder only. Not legal, customs, trade, or investment advice.
Sources
[1] U.S. Customs and Border Protection, Heightened Import Disclosures for Supply Chain Visibility, FR Doc. 2026-17926, 91 FR 56408 (Sept. 2, 2026). Official PDF: https://www.govinfo.gov/content/pkg/FR-2026-09-02/pdf/2026-17926.pdf
[2] Executive Order 14411, Strengthening Customs Enforcement, 91 FR 35125 (June 10, 2026)
[3] Hypernovelty Institute, The Cabinet Is Still In Service, August 29, 2026
[4] U.S. Customs Service, Customs Directive No. 3550-055, November 24, 1986