CBP's 64 Questions for Importers
- Annkaren Wambui
- 2 days ago
- 8 min read
Updated: 21 hours ago
🔓 CBP is considering new supply-chain disclosure requirements. Its 64 questions reveal three issues importers should start examining now.
Summary: U.S. Customs and Border Protection has published an Advance Notice of Proposed Rulemaking seeking industry feedback on potential new requirements for supply-chain visibility. The notice asks 64 questions covering foreign export documentation, supply-chain traceability, identification of parties involved in imported goods, manufacturer identification and Global Business Identifiers. Although no new rule has been adopted, the questions reveal three central themes: the conditions attached to making an entry, the ability to trace where goods and supply-chain information come from, and accountability when import data cannot be supported. Importers have until 1 December 2026 to submit comments before CBP moves to the next stage of the rulemaking process. |
CBP Is Asking 64 Questions About Your Supply Chain
U.S. Customs and Border Protection has opened an important conversation about what importers may eventually need to disclose in order to demonstrate greater visibility into the supply chains behind goods entering the United States.
The notice is called Heightened Import Disclosures for Supply Chain Visibility.
It contains 64 questions.
At first glance, those questions appear to cover many separate subjects:
Foreign export documentation.
Manufacturers and other parties involved in the supply chain.
Manufacturer Identification Codes.
Global Business Identifiers.
Supply-chain tracing technology.
CTPAT.
National-security risks.
Recordkeeping.
Entry and entry-summary information.
But when the questions are stripped back, three larger ideas appear.
Entry. Traceability. Accountability.
And those three ideas may matter more to importers than any individual question.
First: Entry Is Not Simply a Data Submission
The first question running through the CBP notice is fundamentally about the conditions under which goods should be allowed to enter the United States.
CBP is exploring whether additional information, documentation and supply-chain visibility should become part of the process surrounding entry and entry summary.
One major area of focus is foreign export documentation.
CBP is asking whether importers should be required to submit or retain documents that foreign exporters provide to their own customs authorities. These may include export declarations, commercial invoices, packing lists, certificates of origin, export licences or permits and transport documentation. CBP is also seeking feedback on whether such information should be submitted as part of entry, retained as a recordkeeping requirement or handled differently.
This raises a practical question for importers: Can your organisation obtain the information needed to support what is being declared to CBP?
For many supply chains, the answer may not be straightforward.
The importer may purchase goods from a distributor.
The distributor may purchase from a trading company.
The trading company may work with multiple factories.
The entity filing export documentation may not even be the manufacturer.
The CBP questions therefore go beyond simply asking what information an importer currently has.
They ask what information an importer could realistically obtain if deeper supply-chain disclosure became a condition of importation.
Second: Traceability Means Showing Where Information Came From
The second major theme is traceability. Knowing where goods came from is one thing.
Being able to demonstrate that information is another. CBP is asking questions about how importers could obtain, retain and provide foreign export information and how the agency could establish whether documentation is authentic and has not been modified. The notice also explores potential technical solutions that could improve supply-chain tracing.
This is where the distinction between: information provided by a supplier
and information that can be independently supported
may become increasingly important.
A supplier declaration may identify a manufacturer.
An invoice may describe a product.
A certificate may state an origin.
But the underlying compliance question is increasingly becoming: What evidence supports that information?
CBP is also examining the possible role of supply-chain tracing technology and business identifiers in improving visibility into the parties involved in imported goods.
For importers, this could mean looking beyond individual customs documents and examining how information moves across the supply chain.
Manufacturer Identification: How Much Does the Importer Know?
Another significant area of the consultation concerns the identification of parties involved in imported goods. CBP is examining whether existing approaches to identifying manufacturers and other supply-chain parties remain sufficient. This is important because many modern supply chains involve more entities than the traditional buyer-seller relationship suggests.
Goods may pass through:
Manufacturers.
Producers.
Sellers.
Shippers.
Distributors.
Consolidators.
Trading companies.
Logistics providers.
Online marketplaces.
The consultation explores how these parties could potentially be identified and what identifiers may be appropriate for improving supply-chain visibility.
The practical challenge is not simply collecting another name.
It is establishing whether the importer can identify the correct entity consistently and accurately.
Global Business Identifiers Could Become More Important
CBP is also seeking feedback on Global Business Identifiers (GBIs).
The notice refers to identifiers used to identify business entities and asks questions about their suitability for supply-chain visibility, how businesses use them and whether they could be required for particular supply-chain parties.
For businesses, this raises another important operational question: How easily can we identify every relevant entity in our supply chain using a reliable identifier?
That question may be particularly challenging where supply chains involve smaller manufacturers, intermediaries or businesses in markets where internationally recognised identifiers are not widely used.
CTPAT: Could Supply-Chain Information Become More Relevant to Participation?
The consultation also raises questions about CTPAT and supply-chain traceability.
CBP is seeking information about how CTPAT participants use traceability solutions and how supply-chain information could potentially support customs enforcement and security objectives.
This does not mean that CBP has already changed CTPAT requirements.
That distinction is important. The questions are part of an ANPRM, not a final rule.
However, they indicate that CBP is actively considering how existing trusted-trader and supply-chain programmes could interact with future visibility requirements.
Third: Accountability Will Matter When the Data Is Wrong
The third theme running through the 64 questions is accountability.
When information is incomplete, inconsistent or inaccurate, who can explain it?
Consider a discrepancy between:
A foreign export declaration.
A commercial invoice.
An entry summary.
A supplier declaration.
A manufacturer's information.
CBP is asking how importers could reconcile differences between foreign export information and information declared to CBP.
That is ultimately an accountability question.
The issue is no longer only whether a document exists.
It is whether someone within the importing organisation understands:
What the information means.
Where it came from.
Whether it is consistent.
Why differences exist.
What evidence supports the final customs declaration.
For customs and trade compliance teams, this could increase the importance of internal ownership.
Procurement may have supplier information.
Logistics may have transport information.
Customs may have entry data.
Finance may have transaction records.
Sustainability or risk teams may have supply-chain mapping.
But when a discrepancy appears, someone must be able to connect those pieces.
This Is Not a New Rule Yet
This is perhaps the most important point for businesses reading the notice.
CBP has not yet introduced a new final rule requiring these disclosures. The current document is an Advance Notice of Proposed Rulemaking. An ANPRM is an early stage of the regulatory process in which an agency seeks information and feedback before developing proposed regulatory requirements.
CBP is asking the trade community questions about feasibility, costs, available data, implementation challenges and potential approaches to improving supply-chain visibility.
That means businesses should not treat every question in the notice as a future obligation.
But they also should not ignore them.
The questions provide a useful indication of the areas CBP is considering.
And this is the stage at which businesses can explain what works, what does not and what the operational consequences of potential requirements could be.
Why the Comment Period Matters
CBP has invited written comments and has stated that the most useful feedback will address the specific questions contained in the notice.
Comments must be received by 1 December 2026.
This is particularly important for businesses with complex supply chains.
For example:
How long does it take to obtain foreign export documentation?
Is that documentation available to the importer?
Can the importer verify that it is the same document submitted to the foreign customs authority?
What happens when the foreign exporter is not the manufacturer?
Can smaller suppliers obtain Global Business Identifiers?
What costs would new disclosure or recordkeeping requirements create?
Could requirements delay entry?
Which tracing technologies are genuinely practical?
These are not theoretical questions.
They are the questions CBP is currently asking the trade community.
What Should Importers Do Now?
There is no new final compliance requirement to implement today.
But importers can use the consultation as a supply-chain stress test.
Consider asking:
1. Do we know every significant party involved in our supply chain?
Not only the supplier named on the purchase order.
But also relevant manufacturers, producers, exporters and intermediaries.
2. Can we obtain foreign export documentation?
Determine what documents exist and whether your suppliers can provide them when requested.
3. Can we verify where information came from?
Consider how supplier information is supported and whether underlying documentation can be obtained.
4. Can we explain discrepancies?
Identify how differences between supplier, export and import information would be investigated and resolved.
5. Who owns the data internally?
Clarify responsibilities between procurement, customs, logistics, finance and compliance.
6. Should your organisation comment?
If the potential requirements could create significant costs or operational challenges, the current consultation provides an opportunity to explain those concerns to CBP.
The Bigger Message Behind the 64 Questions
The individual questions are different.
Foreign export documents.
Manufacturer identification.
Global Business Identifiers.
Supply-chain technology.
CTPAT.
Recordkeeping.
But the larger direction is consistent.
CBP is exploring how to obtain greater visibility into the supply chains behind imported goods.
For importers, that creates three practical questions:
Entry
What information might you eventually need to provide or maintain to support the entry of your goods?
Traceability
Can you show where your goods and supply-chain information came from?
Accountability
When information is wrong, incomplete or inconsistent, can your organisation explain why?
CBP has not yet written the final answers.
That is exactly why the current consultation matters.
The trade community has until 1 December 2026 to respond.
Source
The CBP Advance Notice of Proposed Rulemaking, Heightened Import Disclosures for Supply Chain Visibility, can be reviewed through the Federal Register. Read the CBP notice
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Related Topics
#CBP #USCustoms #ImportCompliance #SupplyChain #SupplyChainVisibility #CustomsCompliance #InternationalTrade #TradeCompliance #Importers #SupplyChainTraceability #Customs #GlobalTrade #CTPAT #CustomsManager
Author
Ann Karen | Head of Growth
Updated: September 2026
Disclaimer
This article is provided for general informational purposes only and does not constitute legal, customs or tax advice. Businesses should seek professional advice based on their individual trading arrangements and compliance obligations.
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