U.S. Customs proposes new rules requiring importers to submit Chinese export declarations to enhance supply chain transparency and enforcement.
On September 2, 2026, U.S. Customs and Border Protection (CBP) issued an Advance Notice of Proposed Rulemaking (ANPRM) titled 'Import Disclosures for Enhanced Supply Chain Visibility.' This proposal aims to strengthen supply chain transparency, improve customs enforcement, and implement Executive Order 14411, 'Strengthening Customs Enforcement,' signed on June 3, 2026. The order directs the Department of Homeland Security to enhance enforcement, increase transparency, and close gaps in existing processes.
CBP is considering a requirement for U.S. importers to obtain, retain, and submit export documents from foreign exporters. This includes Chinese export declarations, commercial invoices, packing lists, certificates of origin, export licenses, and shipping records. By cross-referencing these with U.S. import declarations, CBP aims to identify issues such as illicit transshipment, undervaluation, false origin declarations, and anti-dumping circumvention. Discrepancies could trigger inspections, detentions, fines, or rejection of shipments.
If implemented, Chinese export data - including pricing, quantities, and classifications - would be directly compared to U.S. filings. The proposal is still under discussion, with CBP determining whether the requirement will apply to all imported goods or only specific high-risk categories. It's also unclear if submission will be mandatory for entry or serve as a recordkeeping obligation.
Although still in the public comment phase (closing December 1, 2026), the proposal signals a potential shift in trade practices. U.S. importers may begin requesting official Chinese export declarations to ensure compliance. Discrepancies between Chinese and U.S. filings could label shipments as high-risk, exposing them to inspections or detentions.
Legitimate exporters may experience indirect but significant impacts. As CBP improves its Manufacturer Identification Code (MID) and promotes the Global Business Identifier (GBI) initiative, exporters could face additional requirements to disclose upstream information, such as manufacturer details and factory addresses. While non-compliant exporters engaging in undervaluation or transshipment may face increased costs and risks, compliant businesses could benefit from fairer competition as unfair practices are curtailed.
CBP emphasizes that these measures aim to enhance risk targeting, intercept counterfeit or hazardous goods, and protect compliant enterprises while fostering a more transparent, competitive supply chain.
