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A question for the group — from the compliance corner, where new CBP rulemakings tend to raise both eyebrows and blood pressure:
CBP’s new Advance Notice of Proposed Rulemaking under Executive Order 14411 looks like the beginning of a major shift in how supply chain visibility, entity identification, and recordkeeping will work. Mandatory foreign export documents, Global Business Identifiers, AI‑driven traceability, expanded CTPAT criteria… basically: “Show us your supply chain, every layer, every entity, every document and do it before release.”
I’m curious how others are reading this, because if even half of these proposals move forward, it feels like we’re heading toward a very different operational reality. Where do you see these requirements fitting into your current workflows? And what changes do you think companies should start preparing already for now?
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Under EU export rules I am the other end of that request. The foreign export document CBP asks about is the declaration lodged on my side, and for controlled goods it names the authorisation and the value. Releasing it to a buyer is not prohibited: it is a commercial decision. So put it in the supply contract rather than the escalation email. I do not know the US side.
This is fine until the auditor lays your supplier's export declaration beside your entry summary. CBP says it is weighing those documents as a way to verify and reconcile entry information, and the notice asks what controls importers should run to catch differences in value, quantity or classification.
Worst case, the figures disagree and nobody on your side noticed first. Realistic case, the gaps are innocent but nobody wrote down why. The precaution: reconcile each copy against its entry as it arrives, and note the reason for every difference.
I checked this morning, and CBP has posted no extension to the comment date mentioned above.