Foreign Exporter Documentation: CBP's Proposal Is Now Public

This page originally covered Section 3(b) of Executive Order 14411, which gave DHS until September 1, 2026 to act on requiring foreign export documentation. That deadline has now been met: CBP's Advance Notice of Proposed Rulemaking (ANPRM), "Heightened Import Disclosures for Supply Chain Visibility," was officially published in the Federal Register on September 2, 2026 (91 FR 56408; Docket No. USCBP-2026-1058; RIN 1685-AA47). Here's what it actually says, and what it doesn't say yet.

What the ANPRM actually covers

Strip away the legal phrasing and the idea is simple: right now, what you declare to CBP at the U.S. border and what your supplier declared to their own country's customs authority before the goods ever left, live in two separate systems that nobody automatically reconciles. The ANPRM is CBP thinking through how to close that gap, and it's organized around three proposals, not just one.

A. Foreign export documentation. This is the piece this page originally covered. CBP names six specific types of documents it's considering requiring or asking importers to retain and reconcile against their U.S. entry:

• Export declarations filed with the foreign customs authority (value, classification, quantity)
• Commercial invoices showing the transaction value declared abroad
• Packing lists (contents, weight, packaging)
• Certificates of origin submitted to the foreign customs authority
• Export licenses or permits, for controlled, restricted, or dual-use goods
• Transport documents (bills of lading, air waybills) tied to the foreign export manifest

B. Identifying the parties behind a shipment. CBP is also reconsidering the Manufacturer/Shipper ID (MID) system, which it says is often outdated, inconsistent, or unavailable early enough to be useful. Alternatives on the table include Global Business Identifiers (GBIs, like D-U-N-S, GLN, or LEI numbers) and even product-level identifiers like a manufacturer's own model or style number. One practical risk worth flagging to smaller or newer overseas suppliers: not every foreign manufacturer already has one of these identifiers, and if a future rule requires one, that gap alone could delay or complicate imports from them until it's resolved.

C. Technology and CTPAT. The ANPRM also asks about AI-driven supply chain tracing tools, and separately, whether CTPAT's security criteria should expand to cover cybersecurity, data integrity, and a possible restriction on "covered logistics platforms," foreign-controlled systems like LOGINK that CBP is treating as a potential security risk. If you're CTPAT-validated or considering it, that last piece is worth watching alongside what's already required of validated brokers.

The ANPRM doesn't name the pedimento specifically, it applies to whatever documentation any foreign exporter submits to their own country's customs administration, but for Mexico-origin freight it's the clearest available example. CBP's own questions ask exactly this: how should an importer reconcile a difference in value, quantity, or classification between the two documents, and what should happen when one is found? Worth knowing: CBP isn't necessarily proposing to treat every import the same way. It's specifically asking whether certain categories of merchandise or countries of origin should be designated as posing a heightened national security risk, with tougher documentation rules applying only to those. And even a clean reconciliation isn't always simple, valuation rules, tariff classifications, and origin determinations can genuinely differ between countries, so a mismatch isn't automatically evidence of a problem.

Two more things worth knowing about

The export documentation piece isn't the only thing in this ANPRM with real operational weight. Two others are worth having on your radar:

• Earlier entry filing. CBP is asking whether entries should be required sooner, giving the agency more time to review supply chain documentation before goods arrive. If this goes anywhere, it could reshape how brokers, carriers, and foreign suppliers coordinate the timing of paperwork, not just what paperwork is required.
• CTPAT benefits, not just requirements. The restriction side of this (cybersecurity criteria, "covered logistics platforms" like LOGINK) is covered on our CTPAT Validation page. But CBP is also asking whether companies that voluntarily provide enhanced supply-chain visibility should receive additional CTPAT benefits in return. If you're already CTPAT-validated, the comment period is a real opportunity to make the case for what those benefits should look like, not just react to new requirements.

Why the mismatch matters

Two documents describing the same shipment, filed with two different governments, created by two different parties, rarely disagree by accident when someone benefits from the difference. A value, quantity, or description that shifts between what left Mexico and what arrived in the U.S. is exactly the kind of discrepancy CBP is now asking, in writing, how to catch.

What importers can do now

• Start an internal audit comparing your declared U.S. entry data against what your exporter actually declared on export, starting with value, quantity, and description.
• If you're sourcing from Mexico, ask your supplier or customs broker on that side for a copy of the pedimento for a recent shipment and compare it directly.
• If you find a discrepancy, resolve it now and fix whatever process produced it, before there's a published rule requiring you to.
• If you source from elsewhere, ask the same question about whatever export documentation your supplier files with their own customs authority.
• If any of the six document types above would be hard for you to obtain or retain, that's exactly the kind of real-world friction CBP says it wants to hear about. Comments on Docket No. USCBP-2026-1058 are open through December 1, 2026 at regulations.gov.
• Have a question CBP itself could answer? The notice lists two direct contacts: Brandon Lord (Executive Director, Trade Programs) and Salvatore Ingrassia (Acting Executive Director, Cargo and Conveyance Security), reachable at (202) 325-4369 or supplychainvisibility@cbp.dhs.gov.