New US Rules Could Force Importers to Reveal Their Entire Supply Chain

Knowing your direct supplier may soon not be enough. US Customs wants to see every party behind your products, from the factory floor to the port of export.

On 2 September 2026, U.S. Customs and Border Protection (CBP) published an Advance Notice of Proposed Rulemaking (ANPRM) titled "Heightened Import Disclosures for Supply Chain Visibility." It asks for public input on how CBP can get deeper visibility into the parties, documents and processes behind goods entering the United States.

The proposal is not a final rule yet, and comments are due by 1 December 2026. But its scope shows clearly where US customs enforcement is heading: toward a world where importers are expected to account for their whole supply chain, not just the last link.

What could importers be asked to disclose?

CBP is considering requiring importers to submit or keep additional documents and data tied to the foreign export of their goods, including:

• Export declarations
• Commercial invoices
• Packing lists
• Certificates of origin
• Export licences and permits
• Bills of lading and other transport documents
• Identities of manufacturers and producers
• Details of exporters, sellers and distributors
• Foreign tax and global business identifiers

CBP is also exploring technology to trace goods through the supply chain and verify where they really come from.

In practice, this would mean importers need to know, and be able to prove, who made their products, who sold them, who shipped them and what paperwork supports each step.

Why is CBP doing this?

CBP says the goal is to detect and stop illicit imports, especially goods illegally transshipped through third countries to avoid US duties and trade restrictions.

The move follows Executive Order 14411, "Strengthening Customs Enforcement," which directed the government to increase supply-chain transparency and step up enforcement of customs and trade laws.

With data from every stage of a transaction, CBP could cross-check documents and flag inconsistencies in origin, value, quantity or classification. Discrepancies that once went unnoticed could become red flags.

The real challenge: pulling it all together

For most importers, the hard part isn't getting one document. It's assembling accurate, consistent information from many sources.

A single product can pass through manufacturers, exporters, logistics providers and intermediaries across several countries, and each one produces its own records. For businesses with large product catalogues, tracking all of this by hand quickly becomes unmanageable.

If these requirements move forward, supply-chain data accuracy and traceability will become a core part of import compliance, not a nice-to-have.

What importers should do now

The rules aren't mandatory yet, but trade experts are already advising businesses to get ahead of them:

1. Map your supply chain. Identify manufacturers, producers, shippers, exporters, sellers, distributors and other intermediaries.
2. Test your suppliers. Check whether they can provide the export documents CBP may ask for.
3. Find the gaps. Compare your import data with supplier information, focusing on:
   • Product descriptions
   • Quantity
   • Value
   • Classification
   • Country of origin
   • Supplier identity
4. Have your say. The 1 December comment deadline is a chance to tell CBP about the practical burden these requirements could create.

How Gloco can help

Compliance increasingly depends on having accurate product and regulatory information ready when it's needed.

Gloco helps global sellers manage compliance with AI-assisted product analysis that flags potential tariff, licensing and IP considerations from product information. The platform also supports duty calculations, documentation, certificates and permits, so key compliance requirements sit in one place.

With ongoing monitoring and alerts, Gloco helps businesses keep up with changing regulations and emerging risks instead of relying on a one-time review.

The bottom line

The CBP proposal is still at the consultation stage, but the direction is clear. For global sellers, knowing where a product comes from, who was involved in making it and what documents back it up may soon matter as much as getting its tariff classification right.

The time to map your supply chain is before CBP asks for it.