Key Summary
The era where matching only U.S. import documents is sufficient for U.S. customs clearance may be coming to an end.
On September 2, 2026, U.S. Customs and Border Protection (CBP) published an Advance Notice of Proposed Rulemaking (ANPRM) in the Federal Register titled Heightened Import Disclosures for Supply Chain Visibility.
A core element under consideration by the CBP is the utilization of export-related documentation submitted by foreign exporters to their own customs authorities for goods imported into the U.S.
For Korean companies, this means it will become increasingly critical to ensure consistency between the entry data submitted by U.S. importers and the export declaration data, Commercial Invoice, Packing List, and origin documentation prepared in Korea.
Please note that this is currently at the ANPRM stage. No new filing obligations have been finalized or implemented at this time.
What did the CBP release on September 2?
The official title of the document is Heightened Import Disclosures for Supply Chain Visibility, Docket No. USCBP-2026-1058.
The CBP is soliciting industry feedback on how to modify existing regulations to gain greater clarity into the supply chains of goods entering the United States.
This review is a follow-up to U.S. Executive Order 14411, Strengthening Customs Enforcement, signed on June 3, 2026.
Most Significant Potential Change: Foreign Export Documentation
The CBP is exploring ways to utilize data submitted by foreign exporters to their respective customs or export authorities during the U.S. import clearance process.
Specific examples of documentation cited in the ANPRM include:
- Export Declarations submitted to foreign customs
- Commercial Invoice
- Packing List
- Certificate of Origin
- Export licenses or permits
- Transportation documents such as Bill of Lading and Air Waybill
The CBP has not yet decided whether these documents will be required for every import, whether they must be transmitted at the Entry or Entry Summary stage, or if they should be maintained and submitted upon request.
Why is this important for Korean exporters?
While U.S. importers prepare U.S. customs entry data, much of the underlying information is sourced from foreign suppliers.
Therefore, if this proposal evolves into an actual regulation, discrepancies between the data prepared by Korean exporters and the data declared by U.S. importers will be much easier to identify than they are today.
The following items, in particular, warrant pre-emptive review:
- Export declaration price vs. U.S. import declaration price
- HS Code vs. U.S. HTS classification
- Quantity and weight
- Manufacturer information
- Exporter and seller information
- Country of Origin
- Commercial Invoice details
- Export license requirements
Does a price discrepancy automatically mean a problem?
Not necessarily.
There may be transactions where the price declared in the country of export and the Customs Value for U.S. valuation purposes are calculated based on legally distinct concepts.
The CBP is also asking the industry in the ANPRM how to reconcile and explain such conceptual differences.
The key is not to force numbers to match, but to establish a structure where you can document and explain the legitimate reasons for any discrepancies.
CBP may also scrutinize manufacturer information more closely
Currently, the Manufacturer Identification Code (MID) is used in U.S. customs clearance.
However, the CBP believes the existing MID has limitations in accurately and consistently identifying the actual manufacturer or parties in the supply chain.
Consequently, they are considering ways to collect the actual company name, address, or other business identifiers for manufacturers, shippers, and exporters.
GBI also requires renewed attention
The CBP is also seeking feedback on using the Global Business Identifier (GBI) to more accurately identify supply chain parties.
Current relevant tests utilize identifiers such as D-U-N-S, GLN, LEI, and Altana ID.
As the system evolves, U.S. exporters should be prepared for the possibility of being required to manage identification information for their supply chain partners, including manufacturers, sellers, and shippers, in addition to their own.
Connection to Country of Origin and Transshipment Enforcement
A major objective of this ANPRM is the detection of illegal transshipment and origin fraud.
The CBP intends to use supply chain data to detect transactions that use third countries to conceal the true country of origin or circumvent U.S. trade regulations.
In particular, comparing foreign export declaration data with U.S. import declaration data can be used to detect discrepancies in price, quantity, tariff classification, and origin.
AI and supply chain tracking technology under review
The CBP is also reviewing methods to identify risks of illegal transshipment using supply chain tracking technology and AI.
The ANPRM requests feedback on technologies for tracking the origin of raw materials, verifying the accuracy of supply chain data, tamper-proof credentials, and the potential for integration with existing trade data systems such as ACE.
Not yet an implemented regulation
This distinction is critical.
The ANPRM is not a finalized rule; it is an initial stage where the CBP is gathering market and industry feedback before designing future regulations.
Based on this feedback, the CBP may draft a Notice of Proposed Rulemaking (NPRM) in the future.
Therefore, it should not be interpreted that new document submission obligations have been imposed on Korean exporters at this time.
What should be prepared now?
While there is no need to build a new system yet, it is worth checking how consistently your data is currently managed if you are a U.S. exporter.
- Compare prices and quantities between Korean export declarations and Commercial Invoices.
- Manage the mapping between Korean HS Codes and U.S. HTS codes.
- Distinguish transactions where the manufacturer and seller are different.
- Maintain records of actual manufacturing facility addresses.
- Retain documentation supporting origin determinations.
- Identify the supply chain for raw materials or major components.
- Retain export license and certification documentation.
- Compare data provided to U.S. importers with Korean declaration data.
Trading companies, in particular, need to verify
If the manufacturer does not sell directly to the U.S. and the transaction involves a trading company, distributor, or consolidator, the supply chain parties are divided into multiple stages.
In this ANPRM, the CBP is reviewing how to identify not only the manufacturer but also the shipper, exporter, seller, and, in some cases, the ultimate consignee.
Therefore, if the exporter is an intermediary trading company, it is advisable to ensure that the actual manufacturer information is linked within your internal system.
Practical Checklist
- Compare Korean export declaration data with U.S. Import Entry data.
- Verify consistency of quantities across Invoice, Packing List, and Export Declaration.
- Retain supporting documentation for any price discrepancies.
- Review HS/HTS mapping.
- Clearly define the roles of manufacturer, seller, exporter, and shipper.
- Manage actual manufacturing facility information.
- Maintain supporting documentation for Country of Origin.
- Retain export licenses and permits.
- Confirm data transmission procedures with U.S. customers or Customs Brokers.
- Monitor for future NPRM announcements.
Conclusion
The core of this CBP ANPRM lies in the shift from viewing information only at the time of import to connecting the entire supply chain to verify where goods were made, who made them, who exported them, and what was declared to foreign customs authorities.
As this is not yet a finalized regulation, there is no need to assume new obligations have been implemented.
However, U.S. exporters can prepare for future regulatory changes by simply cross-referencing their Korean export declaration data with their U.S. import declaration data now.
FAQ
Must I now submit my Korean export declaration to the U.S. CBP?
No. We are currently at the ANPRM stage, and the CBP is soliciting feedback on how to design the submission or retention requirements for foreign export documents.
What documents are under review?
The CBP has cited Export Declarations, Commercial Invoices, Packing Lists, Certificates of Origin, export licenses, and transportation documents as examples.
Is it a problem if the Korean HS Code and U.S. HTS code differ?
Detailed classifications may differ due to variations in tariff systems by country. The important factor is that you can explain the discrepancy and that you have declared appropriately according to each country's classification rules.
Is the CBP planning to expand manufacturer information requirements?
Yes. While reviewing the limitations of the existing MID, they are considering more specific identification information for manufacturers, shippers, and exporters, or the potential use of GBI.
When will this be implemented?
There is currently no finalized implementation date. This document is an ANPRM, and further feedback collection and rulemaking procedures may follow.
Official References
- U.S. Federal Register — Heightened Import Disclosures for Supply Chain Visibility
- U.S. Customs and Border Protection — Trade
※ This content is for general trade and customs information purposes only and does not constitute legal or tax advice. This matter is at the ANPRM stage as of September 4, 2026, and the content and implementation timing of final regulations may change. Please verify the latest requirements for actual U.S. import clearance through the CBP, your Customs Broker, or a professional advisory firm.