CBP New Import Disclosure Rules 2026: What Importers Must Know

On September 2, 2026, U.S. Customs and Border Protection (CBP) published a proposed rulemaking that could require US importers to collect and keep far more information about their supply chains — including documents their Chinese suppliers file with Chinese Customs. Nothing is mandatory yet: CBP is asking for public comment until December 1, 2026. But the direction is clear, and importers who prepare early will have a much smoother ride. Here is what the proposal says, who it affects, and what you should do now.

What Did CBP Propose on September 2?

The announcement is formally called an Advance Notice of Proposed Rulemaking (ANPRM) — a “we’re thinking about new rules, tell us what you think” step that comes before any final regulation. The title: “Heightened Import Disclosures for Supply Chain Visibility.”

It implements Section 3 of Executive Order 14411, “Strengthening Customs Enforcement,” signed on June 3, 2026. CBP’s stated goal is to see further into the supply chains behind imported goods so it can detect and stop shipments that evade US customs and trade laws — such as goods illegally transshipped to disguise their origin, or invoices that understate what was actually paid.

The full notice is published in the Federal Register (91 FR 56408, docket USCBP-2026-1058), with public comment open until December 1, 2026. You can also read CBP’s official announcement here.

What Information May Importers Have to Collect?

CBP is weighing four broad categories of new requirements. None are final, but together they sketch what a much more transparent import process would look like:

• Foreign export documentation. The headline item: importers may need to obtain and keep the documents their overseas suppliers submit to their own governments — for Chinese goods, that includes the China export declaration, commercial invoices, packing lists, certificates of origin, export licenses, and bills of lading. CBP says comparing these against US entry data would help flag discrepancies such as dual invoicing (using two different invoice sets to hide a shipment’s true value).
• Key party identification. Collecting additional identifying details about the manufacturers, producers, shippers, exporters, and other parties behind each import — not just the name on the invoice.
• Better business identifiers. Improving how companies are identified across filings, so the same entity can’t easily reappear under a new name.
• Supply chain tracing technology. Possibly encouraging or requiring technology that tracks where goods actually came from, paired with expanded data-integrity expectations.

CBP is also signaling changes to CTPAT — the voluntary “trusted trader” program that rewards companies with strong supply chain security through faster processing. Potential updates include new cybersecurity and data-integrity criteria for members, and possibly restrictions on certain foreign-controlled logistics software platforms.

Why Is CBP Doing This Now?

Enforcement pressure has been building all year. Executive Order 14411 already pushed CBP to verify the accuracy of importer information on file, and the ANPRM is the next step: if CBP can compare what a Chinese exporter declared to Chinese Customs with what the US importer declared to CBP, mismatches become obvious — undervaluation, misstated origin, and transshipment schemes all get much harder to hide.

For legitimate importers, that is actually good news. Businesses that play by the rules are the ones undercut by competitors who understate values or launder origins through third countries. Tighter visibility raises the floor for everyone.

Does This Affect DDP Shipments from China?

Yes — and arguably DDP importers benefit most. Under DDP shipping (Delivered Duty Paid), the seller or their forwarder handles US customs clearance and pays the duties, while you receive the goods door-to-door. The import paperwork still exists; it is just handled on your behalf.

If the proposal becomes a final rule, the document chain behind a DDP shipment — China export declaration through US entry — becomes fully visible to CBP. That strongly favors DDP providers who clear customs with clean, accurately declared shipments, and puts pressure on gray-area “under-declared, all-inclusive” offers. When you evaluate a DDP quote, the question to ask is simple: will my goods be declared accurately, at full value, under my supply chain’s real paperwork? If the answer is yes, you are well positioned for whatever CBP finalizes. Our overview of professional customs clearance services explains how a compliant entry is built.

The Other Deadline: IOR Verification Starts September 18

While the disclosure rules are still just a proposal, one related enforcement action is very real and very close. In a General Notice published August 19, 2026, CBP said it will begin acting against importers whose Importer of Record (IOR) information on file is inaccurate — and starting September 18, 2026, it can immediately void the IOR number of companies that fail to keep it complete and correct.

Why it matters: a valid IOR number is required to import into the United States at all. An inaccurate profile can also block your ability to receive refunds on CBP bills, including tariff refunds. CBP has signaled it will apply strict interpretations, with potential enforcement under the False Claims Act. Log into your CBP systems (or ask your broker to) and confirm your IOR details — legal name, address, contact information, and business type — are current before September 18.

What Happens Next? The Timeline

• Now – December 1, 2026: Public comment period on the ANPRM. Trade groups, importers, and foreign governments weigh in.
• Late 2026 – 2027 (expected): CBP reviews comments, then may issue a Notice of Proposed Rulemaking (NPRM) with actual regulatory text — which would open a second comment round.
• Later: A final rule with effective dates. Realistically, importers will get notice before any documentation requirement is enforced.
• September 18, 2026: Not part of this rulemaking, but the date IOR verification actions begin. Treat it as a hard deadline.

In other words: the disclosure rules themselves will take time, but the compliance direction is already set by the Executive Order. Smart importers use the gap to get ready. If you are new to the process itself, our guide to US customs clearance for imports from China covers what a standard entry involves today.

What Importers Should Do Now: A 5-Step Checklist

1. Verify your IOR information before September 18, 2026. This is the only item with a near-term hard deadline. Confirm every field CBP has on file is accurate and complete.
2. Audit your document chain. Ask: for a typical China shipment, can you (or your forwarder) already produce the export declaration, matching invoices, packing list, and certificate of origin? If yes, you are close to compliance. If no, start closing the gap.
3. Talk to your suppliers and forwarder. Find out whether your Chinese suppliers can share the documents they file with Chinese Customs — and whether your DDP forwarder keeps them on file for each shipment.
4. Consider commenting. Rules shaped by real importer feedback tend to be more workable. Submit comments at regulations.gov by December 1, or contribute through your industry association.
5. Watch CTPAT. If supply chain transparency becomes a bigger factor in clearance speed, membership in trusted trader programs may become a competitive advantage rather than a nice-to-have.

Frequently Asked Questions

Is the new CBP disclosure rule already in effect?

No. As of September 2026 it is an Advance Notice of Proposed Rulemaking — a request for input. No new importer documentation requirements are enforceable until CBP completes rulemaking and a final rule takes effect. The IOR accuracy check, however, is already underway, with enforcement actions starting September 18, 2026.

Do I need to submit anything to CBP right now?

Only if you choose to file a comment on the proposal (due December 1, 2026) — that is optional. Separately, every importer should verify their IOR information on file is accurate, because CBP begins voiding inaccurate IOR numbers on September 18, 2026.

What is an Importer of Record (IOR)?

The IOR is the entity legally responsible for an import — the party whose name and number are on the customs entry, who answers to CBP for the declared value, classification, and origin, and who owes any duties. In a DDP arrangement, the forwarder typically arranges clearance, but the entry is still filed under a properly registered IOR with accurate information.

Will these rules affect small businesses and Amazon FBA sellers?

Probably yes, eventually — CBP has not proposed a small-importer exemption. The practical effect depends on your setup: if you use a DDP forwarder who handles documentation professionally, most of the added work lands on their side. If you self-clear or buy FOB, expect to collect more supplier documents yourself.

What documents might importers have to keep under the proposal?

The notice specifically contemplates foreign export documentation — for China-origin goods, the China Customs export declaration, commercial invoices, packing lists, certificates of origin, export licenses, and bills of lading — plus identifying information about the manufacturers and other parties in the chain. All of it is under consideration, not yet required.

Disclaimer: This article is general information, not legal advice. The September 2, 2026 ANPRM is a proposal and may change significantly before any final rule. For guidance on your specific shipments, consult a licensed customs broker or trade counsel — and verify the latest requirements directly on CBP.gov.