CBP Heightened Import Disclosures: How Asia Importers Can Build a Supplier File Now
CBP wants comment by December 1 on new supply chain disclosures. Here is what the proposal asks, what it could mean for Asia sourcing, and how to prepare.
In this piece 9 sections
CBP's heightened import disclosures are a proposal, not a rule yet. U.S. Customs and Border Protection asked for public comment on September 2, 2026, and comments close December 1, 2026. The agency may later require more detail about suppliers, production and foreign export papers. Importers sourcing from Asia can prepare a supplier file now.
This guide is for small and mid-sized importers who buy from factories and trading companies in China, Vietnam and elsewhere in Asia. It explains what CBP is asking, what the proposal could mean for your supplier paperwork, and how to build a file that holds up. Eastern Plays covers sourcing, shipping and customs for Western businesses in Asia, and this is the kind of change that lands on the sourcing desk first.
What CBP actually proposed
CBP issued an advance notice of proposed rulemaking (ANPRM) titled "Heightened Import Disclosures for Supply Chain Visibility." Its announcement of the rulemaking says the goal is a clearer view of the supply chains behind imported goods, so the agency can catch illegal imports. It supports Executive Order 14411, "Strengthening Customs Enforcement."
An ANPRM is the first step. CBP is asking questions, not setting rules. The agency says it may use the comments to write a future notice of proposed rulemaking.
That distinction matters. Nothing in the notice changes what you must file today. But the questions show where CBP is heading, and importers who prepare early will spend less later.
What is CBP asking importers about?
CBP is asking importers about key parties in the import process, business identifiers, foreign export documents, supply chain tracing technology and enhancements to the Customs Trade Partnership Against Terrorism (CTPAT) program. The notice contains 64 questions on current practices, costs and benefits. Comments go through regulations.gov under docket USCBP-2026-1058.
KPMG's summary of the notice gives more detail on the ideas on the table. Its review of the CBP import disclosure notice lists these questions:
- Whether importers should submit or keep foreign export documents, such as export declarations, commercial invoices, certificates of origin and packing lists.
- Whether the Manufacturer Identification Code (MID) system should change, and whether to use Global Business Identifiers and foreign tax identifiers.
- Whether online marketplaces or final delivery recipients should be identified to CBP.
- Whether filing deadlines should move earlier, so CBP can review data before goods are released.
- Whether imports that pose national security concerns should face extra documentation as a condition of entry.
KPMG also notes what remains unclear. The notice does not say which import categories would be covered or when any rule would start. Treat every item above as a possibility, not a requirement.
Why this lands hardest on Asia sourcing
The stated target is illegal transshipment, which means routing goods through a third country to hide their true origin. Asia sourcing sits at the center of that concern. Many buyers use trading companies, and one factory may sell through several of them.
A report from the trade press, based on a briefing by the Wine and Spirits Shippers Association, gives a flavor of what CBP may want. In its example, CBP would want to know where each input was bought, where it originated and what it cost. The Vinetur report on CBP's supply chain data request stresses that this is the association's reading, not a CBP data list.
For a small importer, the practical question is simple. If CBP asked tomorrow, could you name the factory that made your goods, and could you show where its main inputs came from? Many cannot. A trading company often keeps that detail to itself.
How to build a supplier file before any rule arrives
A supplier file is one folder per factory with the papers that prove who made your goods and where. It is useful whether or not CBP ever finalizes a rule. It also helps with other checks you may already face, such as forced labor screening. See our guide to the UFLPA Entity List and how to check your China suppliers.
Build the file in this order:
- Record the legal name, address and business registration number of the factory that makes your goods, not only the trading company that invoices you.
- Save the exporter's tax or business identifiers, as shown on its own documents.
- Keep each shipment's commercial invoice, packing list and, where issued, certificate of origin.
- Ask for a short bill of materials that names the main inputs and their country of origin.
- Note any contract manufacturing or subcontracting step, with the subcontractor's name.
- Store everything with the purchase order number, so one search finds it all.
Our editors at Eastern Plays recommend asking for the factory's name in writing before the first deposit. If a supplier refuses, that is useful information. The old rule still applies: nothing gets paid until someone independent has verified it.
The table below shows what each document proves and who normally holds it. Use it as a checklist when you talk to a supplier.
| Document | What it shows | Who usually holds it |
|---|---|---|
| Commercial invoice | Seller, price and goods sold | Supplier and you |
| Packing list | Quantities, weights and cartons | Supplier and forwarder |
| Certificate of origin | Country where goods were made | Supplier or chamber of commerce |
| Export declaration | What the exporter told its own customs office | Supplier or its broker |
| Bill of materials | Main inputs and where they came from | Factory |
Most of these already exist. The hard part is getting a copy, filed under the right order, before you need it. A supplier who ships on time but cannot produce an export declaration is a risk worth flagging early.
What should you ask a trading company?
A trading company may be a perfectly good partner, but you need its factory details. Ask which factory makes each product, whether the factory ever changes, and whether it will share export documents for your orders. Put the answers in your purchase agreement.
Some suppliers will worry about losing you to the factory. Explain that your customs file needs the detail. You are not asking for their margin. You are asking for who made the goods and where.
It also pays to compare what the factory says with what the paperwork shows. A factory name that differs from the exporter on the invoice is not a crime, but it is a question worth answering before a customs officer asks it. Our article on the US-China tariff cut list shows why origin detail already drives your duty bill.
Should you file a comment with CBP?
Yes, if the idea of new document duties worries you. Comments from small importers are rare, and CBP asked for information on compliance costs. A short, factual comment about how long it takes you to collect supplier documents is useful.
Keep it concrete. Say how many suppliers you use, what documents you already hold, and which of CBP's ideas would be hardest. Submit through regulations.gov under docket USCBP-2026-1058 by December 1, 2026. A customs broker or trade association can also file on your behalf.
You do not need a lawyer to comment. You do need to be accurate. Do not guess at costs you have not measured.
If you would rather not file alone, ask your customs broker or your industry group whether it is preparing a joint comment. Groups often collect examples from several members, which gives CBP a fuller picture of what the paperwork costs a small buyer.
How does this connect to your other deadlines?
This proposal arrives alongside other changes that raise the paperwork load. Duty relief and exclusions have end dates too, and our guide to Section 301 exclusions that expire in November 2026 covers what to do before those lapse. A tidy supplier file helps with both, because origin and classification drive the duty you pay.
Budget time as well as money. Collecting documents from a factory takes weeks, not days, especially around holidays. Start with your top three suppliers by spend.
What we do not know yet
CBP has not published a final rule or a full list of required data fields. The Federal Register notice is only a request for views. Some of what is described here comes from law-firm and trade-press summaries of that notice, so check the primary documents before relying on any detail.
This is general information, not legal advice. For your own entries, talk to a licensed customs broker or trade attorney. Eastern Plays editors checked the facts in this article against CBP's own release on October 26, 2026.
Conclusion
CBP's heightened import disclosures are still a proposal, but the direction is clear. The agency wants to know who made your goods, where the inputs came from and which papers prove it. A supplier file answers all three.
Your next step is small. Pick your top supplier this week, write down the factory behind the invoice, and ask for its export documents on the next order.
