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ARTICLE · 04 SEPTEMBER 2026

CBP Explores Sweeping New Disclosure Requirements: Importers May Face Expanded Reporting, Traceability, And Foreign Export Documentation Obligations

Kelley Drye & Warren LLP
Kelley Drye & Warren LLP
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Kelley Drye & Warren LLP

Kelley Drye & Warren LLP

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U.S. Customs and Border Protection has published an Advance Notice of Proposed Rulemaking seeking industry input on dramatically expanded import disclosure requirements that could fundamentally reshape customs compliance. The proposed changes would require importers to provide foreign export documentation, enhanced supply chain participant identification, and technology-enabled traceability information.

United StatesGovernment, Public Sector
Carrie L. Owens
Carrie L. Owens
Jennifer E. McCadney
Jennifer E. McCadney
Maggie Crosswy
Maggie Crosswy
Hans R. Maxime
Hans R. Maxime

On September 2, 2026, U.S. Customs and Border Protection (“CBP”) published an Advance Notice of Proposed Rulemaking (ANPRM), titled “Heightened Import Disclosures for Supply Chain Visibility.” The notice is a strong signal of how CBP is contemplating implementing portions of President Trump’s June 2026 Executive Order on Strengthening Customs Enforcement. Our Client Advisory on June 8 lays out the new plan to combat illicit trade set forth in the EO. 

Importantly, CBP is seeking industry input through 64 detailed questions that will inform a subsequent Notice of Proposed Rulemaking. Comments are due by December 1. In a communication sent this morning, CBP explained it is seeking to balance enforcement priorities with commercial realities, suggesting it seeks to examine what is feasible without disrupting legitimate trade and unnecessarily burdening businesses. 

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