On September 1, 2026, U.S. Customs and Border Protection (CBP) issued an advance notice of proposed rulemaking (ANPRM), requesting input from the importing community on a series of significant changes it is considering to implement Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026. The notice was filed on September 1 and published in the Federal Register on September 2, 2026, opening a 90-day comment window.
This matters to home furnishings retailers. Our industry is import-intensive, and the changes CBP is contemplating would reach deep into how retailers and their suppliers document, file, and account for imported goods. Because these rules are still being shaped, now is the time to provide feedback — before they take effect.
What CBP Is Considering (In Plain English)
- Handing over the paperwork that your supplier filed in their country.
When goods leave a country, the exporter has to file paperwork with that country’s customs office — showing what’s being shipped, its value, and how much there is. Think of it as the “receipt” from the seller’s side.
Right now, when those goods arrive in the U.S., you only file paperwork with U.S. Customs. CBP is strongly considering also requiring importers to hand over the paperwork the exporter filed with their government, for example, the export declaration that a Chinese exporter must file with Chinese Customs. The types of documents could include export declarations, commercial invoices, packing lists, certificates of origin, export licenses, and shipping documents like bills of lading.
Why does CBP want it? To compare the two sets of paperwork side by side. If the value, product code, or quantity doesn’t match — that’s a red flag. This is how Customs would catch things like “dual-invoicing” (two different price documents, one real, one lowered to pay less in duties) or illegal transshipment (routing goods through a third country to disguise where they were really made). Today, none of this documentation is required, so this would be a major change.
- Keeping the paperwork becomes your job, not just your broker’s.
Today, most importers lean on their customs broker to keep copies of shipment documents, which is part of the broker’s legal duty. Under the framework CBP is considering, everyone involved in bringing goods into the country, not just brokers, could be legally required to keep customs records. In practical terms: you’d need complete files on every shipment you import, not just whatever your broker happens to hold onto.
- Showing CBP where your products and their materials actually come from.
CBP wants a much clearer picture of your supply chain, going all the way back to the factories that supply the raw materials and components (think foam, fabric, wood, hardware) that go into the finished product.
To do that, CBP may replace the old “Manufacturer ID” code — a shorthand code that isn’t always reliable (it’s built from the manufacturer’s name and address, and it can change over time or accidentally match multiple companies). In its place: fuller, more accurate identification. Like the company’s actual legal name and address, or standard “global business ID” numbers such as D-U-N-S, GLN, LEI, and Altana ID.
What this means for you: expect to ask your overseas suppliers more questions — and get real answers — about who makes your goods and where the materials in them originate.
- A bigger, stricter CTPAT program — with more perks.
CTPAT is Customs’ voluntary “trusted partner” program: companies that demonstrate their supply chains are secure receive benefits such as smoother, faster cargo processing. CBP wants more companies to join and is considering new requirements for members, like using supply chain tracking technology, meeting cybersecurity and data-integrity standards, and possibly avoiding certain foreign-controlled shipping software platforms that Customs considers security risks. In exchange, it’s looking at new benefits for partners.
How to Comment
- Where: Federal eRulemaking Portal, docket number USCBP-2026-1058
- When: Comments are due 90 days after Federal Register publication — on or about December 1, 2026 (confirm the exact date on the docket once published).
- Questions: supplychainvisibility@cbp.dhs.gov or (202) 325-4369
CBP specifically invites feedback on costs and benefits for small businesses, and on whether new requirements should be phased in by entry type, commodity, country, or transportation mode, and whether different implementation timelines should apply to small entities. That is an important opening for small and mid-size retailers to describe real-world impacts: staffing, systems upgrades, supplier data availability, and compliance costs. Comments that cite specific question numbers, include data, and explain effects on your business carry the most weight.
What You Can Do Now
- Review the notice with your customs broker or compliance team and identify where your documentation gaps are — particularly foreign export documentation and upstream supplier data.
- Submit comments during the open period. Even concise comments with concrete examples and cost estimates help CBP understand the practical burden on retailers.
- Evaluate CTPAT certification for your company.
- Share your input with HFA so we can carry the retailer perspective forward in our advocacy on this rulemaking.
- Seek legal guidance. Due to the complexity of these proposed changes, importers may need to consult a law firm experienced in U.S. Customs regulations.
This is an ANPRM — the first step in the rulemaking process. Comments received will inform a subsequent Notice of Proposed Rulemaking, so this comment window is the industry’s best opportunity to shape the rules before they are proposed.
HFA will continue to monitor this docket and keep members updated as the process moves forward.
