CBP Considers Broader Supply-Chain Disclosure Requirements

Posted By: Jess Marvin Government Affairs, NFFS,
The Foundry Brief
Trade & Supply Chain

CBP Considers Broader Supply-Chain Disclosure Requirements

U.S. Customs and Border Protection is considering new requirements that could significantly expand the information importers must collect about foreign suppliers, production methods and the movement of goods through international supply chains.

September 2026  |  Exclusively for NFFS Members

U.S. Customs and Border Protection (CBP) is considering a significant expansion of the information that importers must provide about foreign suppliers, production methods and the movement of goods through international supply chains. An advance notice of proposed rulemaking published September 2, 2026, requests public comments by December 1.

At a Glance

What You Need to Know

More Documentation

CBP is considering whether importers should provide foreign customs records such as export declarations, commercial invoices, packing lists and certificates of origin.

Greater Supply-Chain Visibility

Importers could be required to identify more of the foreign manufacturers, sellers, processors and other parties involved in producing and moving imported goods.

Date to Watch

Public comments on the advance notice are due December 1, 2026.

Import Documentation

CBP Could Require More Foreign Customs Records

Among the options under consideration, CBP could require importers to obtain and submit documents filed with foreign customs authorities.

Records Under Consideration

Importers could be asked to collect:

• Foreign export declarations
• Commercial invoices
• Packing lists
• Certificates of origin
• Other documentation submitted to foreign customs authorities

CBP is evaluating whether these records should be submitted with each entry, retained by importers for later inspection or requested on a randomized basis.

Supply-Chain Parties

More Upstream Parties Could Need to Be Identified

CBP is also considering requirements that would identify more of the foreign parties involved in producing, selling and transporting imported goods.

Potential information could include:
• Foreign tax identification numbers
• Global business identifiers
• Intermediate sellers and manufacturers
• More detailed production-method information
• Raw-material sources
• Additional parties involved in the movement of goods

The agency is separately requesting input on the use of artificial intelligence, traceability platforms and other technologies to verify origin and detect illegal transshipment.

The Bigger Issue
Supply-Chain Traceability
The notice reflects CBP’s growing focus on understanding not only who directly sells goods to a U.S. importer, but also where products and materials originated and which parties handled them further upstream.
Compliance Challenge

The Information May Extend Beyond Direct Suppliers

The proposal could substantially expand the information that must be collected from overseas suppliers.

Obtaining reliable documentation beyond a direct supplier can be difficult, particularly when importers are asked to identify raw-material origins, smelters, intermediate processors or other facilities several tiers upstream.

These questions are part of a broader focus on supply-chain traceability, which CBP views as an important tool for verifying origin, identifying illegal transshipment and enforcing U.S. customs and trade laws.

NFFS Perspective

What This Could Mean for Foundries

Foundries that directly import raw materials, equipment, components or other goods may want to pay close attention to how far upstream future documentation requirements could extend.

Know what your suppliers can document
Importers may want to understand now which records foreign suppliers maintain and how readily those records can be provided.
Look beyond the direct supplier
Potential requirements involving raw-material sources, manufacturers and intermediate processors could make visibility into deeper supply-chain tiers increasingly important.
Review traceability systems
Companies may want to evaluate how supplier records, purchasing systems and existing traceability tools could support more detailed customs documentation.
Watch for operational burden
If CBP advances these concepts through a formal proposed rule, the timing, frequency and depth of required submissions will help determine the practical compliance burden for importers.
Looking Ahead

No New Requirements Yet

The September notice is an advance notice of proposed rulemaking and does not impose new disclosure requirements at this stage.

CBP will use the comments it receives to evaluate potential regulatory approaches. The process could eventually lead to a formal proposed rule affecting importers, customs brokers, foreign manufacturers, logistics providers and other participants in international supply chains.

Timeline

Key Dates

September 2, 2026
CBP publishes its advance notice of proposed rulemaking on heightened import disclosures for supply-chain visibility.
December 1, 2026
Public comments on the advance notice are due.

Review CBP’s advance notice on heightened import disclosures for supply-chain visibility.

Review the CBP Notice
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