On September 2 local time, U.S. Customs and Border Protection (CBP) issued an Advance Notice of Proposed Rulemaking (ANPRM) titled Heightened Import Disclosures for Supply Chain Visibility, opening public consultation on expanding import supply chain information disclosure requirements.

The proposal covers a wide range of issues, including supply chain participant identification, foreign export documentation, cargo tracking technologies and import data submission timelines. If finalized, the rules would reshape data and documentation workflows for ocean carriers, NVOCCs, freight forwarders, customs brokers and importers.

“Border security is national security. Knowing what is coming into this country is vital to our national security,” said CBP Commissioner Rodney S. Scott. “By strengthening visibility into the supply chains behind goods entering the United States, CBP can better identify high-risk shipments, stop illicit trade, and ensure that American businesses are not undercut by those who evade our customs laws.”

This ANPRM supports the implementation of Executive Order 14411, Strengthening Customs Enforcement, which directs the Department of Homeland Security to strengthen customs enforcement, increase international supply chain transparency and prevent bad actors from exploiting outdated processes.

Important note: This is not a final, enforceable regulation. The ANPRM is issued solely to collect industry feedback, which may be used to develop a formal Notice of Proposed Rulemaking (NPRM) at a later stage.

CBP has stated that current import filings already provide certain cargo, importer and transaction data, but gaps in supply chain visibility remain. To address this, the ANPRM poses 64 targeted questions to industry stakeholders, exploring four major regulatory directions.

CBP is considering upgrading current business entity identification requirements. Future rules may require clearer identification of all parties across the import supply chain, including raw material suppliers, overseas manufacturers, shippers, exporters, sellers and other intermediaries.

The agency is also evaluating the use of standardized global business identifiers to more accurately map entities across supply chains. If formalized, existing limited business identification data may no longer satisfy future filing requirements.

Another high-profile proposal would require import stakeholders to collect, retain and potentially submit to CBP certain documents generated at the foreign export stage.

Documents under discussion include:

• Export declarations
• Commercial invoices
• Packing lists
• Certificates of origin
• Export licenses or permits
• Transport documents

Traditionally, these documents are generated and used within the export country’s trade and customs processes. If the new requirements take effect, the scope of information required for US import clearance would extend further upstream to the overseas export side.

For cross-border logistics chains, this means importers, forwarders and NVOCCs would need to build more robust data and document exchange mechanisms with overseas suppliers, manufacturers and exporters.

This is the proposal with the most direct impact on ocean shipping operations.

According to Seatrade Maritime reporting, if CBP enforces stricter import data requirements, container carriers and NVOCCs may need to receive and process relevant information earlier before cargo loading, which would in turn shift data preparation and document cut-off times at overseas load ports.

CBP has not yet announced new official cut-off timelines. However, the question of whether import data should be submitted earlier — to give CBP more review time before cargo arrives in the US — is explicitly included in the consultation.

If formalized, existing document collection, verification and cut-off schedules for carriers and NVOCCs would likely require operational adjustment.

A primary goal of expanded disclosure is to improve detection of high-risk cargo and illegal transshipment, including false declarations and third-country routing used to evade US trade controls.

From an operational perspective, Seatrade Maritime notes that under stricter future rules, shipments with incomplete supply chain information may face stricter automated screening, increased risk of cargo holds, targeted inspections and terminal detention at US ports.

Clarification: This is forward-looking industry analysis based on the proposed direction. CBP has not stated that incomplete data will automatically trigger inspections at this stage. The process remains in public consultation.

Beyond traditional trade documents and entity data, CBP is also exploring digital supply chain tracking technologies. Proposals include end-to-end tracing of goods and raw materials from origin to final destination, supported by data interoperability and digital credentials.

The agency is also seeking input on the potential use of artificial intelligence in supply chain tracing, origin verification and illegal transshipment detection.

In addition, CBP is discussing whether to strengthen requirements for participants in the Customs-Trade Partnership Against Terrorism (CTPAT) program around supply chain traceability, cybersecurity and data integrity.

Procedurally, the rulemaking remains in its early stages. The September 2 ANPRM does not impose new mandatory filing obligations. Instead, it seeks industry input on current data management practices, technical capabilities, implementation costs and potential impacts.

The public comment period closes December 1, 2026.

After reviewing feedback, CBP may proceed to draft a formal Notice of Proposed Rulemaking (NPRM), at which point specific requirements, scope and implementation timelines would be further clarified.

Overall, the direction of US import regulation is clear: moving toward earlier data capture, finer supply chain entity identification, broader access to overseas export documentation and strengthened end-to-end cargo traceability.

For carriers, NVOCCs, forwarders and importers, the scope of data involved in US import business is likely to become broader than current practices. Further updates will depend on CBP’s follow-up rulemaking process.

As a professional freight forwarder with deep expertise in US trade lanes and customs compliance, Huazong Logistics helps shippers and partners prepare for evolving US import regulations:

1. Regulatory Update Monitoring – Our compliance team tracks CBP rulemaking developments in real time, delivering timely alerts on ANPRM, NPRM and final rule releases so you can adjust operations proactively.
2. Document & Data Readiness – We assist clients in organizing full sets of export and import documentation, verifying data consistency across invoices, packing lists, declarations and shipping files to minimize inspection and delay risks.
3. Cut-off Timeline Management – With close partnerships with major carriers, we help you navigate shifting cut-off schedules, ensuring complete and accurate data submission well before vessel loading deadlines.
4. End-to-End Supply Chain Visibility – Full tracking from origin warehouse to US final delivery, with transparent documentation and status updates to support CBP supply chain disclosure requirements.

For businesses shipping to the US, partnering with Huazong Logistics ensures proactive compliance preparation and reliable logistics support amid evolving customs regulations.