U.S. Customs seeks broader supply chain data from importers

U.S. Customs and Border Protection is seeking public input on a proposal that would require importers and foreign suppliers to disclose much more information about how goods shipped to the United States are made, a move that could widen federal oversight of global supply chains and increase compliance demands for companies that bring products into the country.

The comment period runs through Dec. 1 for an advance notice of proposed rulemaking titled “Heightened Import Disclosures for Supply Chain Visibility,” according to the Wine and Spirits Shippers Association, which briefed its members on the measure in a logistics and trade update released Friday. The proposal is still at an early stage, but the trade group said CBP is signaling that it wants deeper production data from overseas suppliers as part of a broader enforcement push.

According to the association, the rule under consideration would require foreign producers to provide more detailed information on how products exported to the United States are produced. In describing the scope of the idea, the group said CBP has given an example involving cake imports, where the agency would want to know where each ingredient was purchased, where it originated, and how much it cost. That example suggests the rule could extend well beyond basic customs declarations and into the underlying sourcing and cost structure of imported goods.

The proposed disclosure regime comes as CBP officials are emphasizing a tougher view of import compliance. WSSA said its managing director, Alison Leavitt, attended several conferences and met with CBP officials over the past two weeks, where the administration’s customs enforcement agenda was a central topic. The group said Shane Campbell, CBP’s deputy executive director of cargo and conveyance security, told industry participants that the agency has implemented more than 60 executive orders since January 2025 and is focused on U.S. economic security, including efforts to crack down on duty evasion and other violations.

WSSA said Campbell described the message under Executive Order 14411 in blunt terms, saying that “importing is a privilege and not a right,” and that importers must be rigorous in providing accurate data. The association also said CBP officials reported that more than 5 million inactive, dormant, or problematic importer of record records have been removed since the order took effect, and that more than 100,000 have been updated. Companies that import into the United States use importer of record information in their customs filings, including on Form 5106.

For the beverage business, the possible rule could carry significant operational consequences even though it is not aimed only at alcohol. Importers of wine, beer, and spirits often rely on long supply chains that run through growers, cooperatives, distilleries, bottlers, warehouses, and freight intermediaries in multiple countries. If CBP moves ahead with a broader disclosure requirement, those companies could face added administrative work to document ingredients, bulk inputs, contract production arrangements, packaging materials, and the identity of upstream suppliers before products reach U.S. ports. Smaller wineries, breweries, and distilleries that sell into the U.S. through import partners could feel that burden most sharply if they do not already keep records in a format that matches customs demands.

The measure could also raise commercial sensitivities. WSSA urged companies to submit comments explaining how the proposal would affect their businesses or their relationships with producers overseas, a sign that importers may be concerned about asking suppliers to share detailed sourcing or cost information. In industries such as wine and spirits, where production methods and supplier networks can be closely held, some exporters may resist turning over data that they view as proprietary, even if U.S. importers need it for customs compliance.

The proposal is emerging during a period of broader strain for importers. In the same Friday update, WSSA warned members about severe weather disruptions at Rotterdam and Antwerp, continued terminal problems in Le Havre, low water on the Rhine, and customs clearance delays in Ireland tied to labor actions. The group also said truck capacity from parts of Europe remains tight, with some inland bookings running 3 to 5 weeks out. Those logistics problems are separate from the CBP initiative, but together they point to a supply chain environment in which importers may be dealing with more paperwork, more delays, and higher compliance costs at the same time.

The customs proposal also fits into a wider pattern of trade pressure affecting beverage importers and exporters. WSSA said the trade dispute with Canada remains unresolved and that U.S. alcohol products still face import restrictions there, including a 50% duty on bulk wine and a continuing exemption for bulk spirits. The association also noted an open public comment period at the Federal Maritime Commission on a proposal involving sanctions tied to Spanish-flag ships and possible action on products from Spain. Those issues are separate from CBP’s supply chain disclosure proposal, but they add to the regulatory load facing companies that depend on cross-border beverage trade.

Because the current CBP action is an advance notice of proposed rulemaking, the agency has not yet issued a final rule or a full list of mandatory new data elements. That means the proposal could still change after industry comments are reviewed. But the message from customs officials, as relayed by WSSA, is that the government is moving away from a system centered mainly on trade facilitation and toward one with more scrutiny of how imported goods are sourced, priced, and produced.

WSSA said it plans to hold a webinar on what it called the shift from trade facilitation to trade enforcement. For importers, the immediate deadline is Dec. 1, when the public comment period on the disclosure proposal closes. Between now and then, companies that depend on overseas suppliers will be weighing how much more visibility CBP may seek into their supply chains and how difficult that information will be to gather.