CBP Tees Up To Expand Info Requirements For Importers
By Ashley Amidon, CAE
Executive Director
International Wood Products Association
Last month the U.S. Customs and Border Protection (CBP) issued a new notice titled “Heightened Import Disclosures for Supply Chain Visibility” requesting information from stakeholders regarding substantial changes the agency is considering for importer documentation and supply chain traceability. In particular, the agency is looking to integrate technical solutions to trace supply chains and collect foreign export documentation that overseas exporters are required to submit to their customs authorities prior to exportation. While IWPA does not reflexively oppose information sharing with CBP and other federal agencies, we do want to ensure that any information required by the government satisfies clear economic and national security requirements and does not unnecessarily burden members of the trade community.
IWPA has already notified members about this change, and we will be soliciting feedback from association members about how this could affect their businesses, as well as considerations that CBP should have in mind when imposing new information sharing requirements. While the preliminary notice does not outline specific proposals, the policies implied by the questions in the document could dramatically increase the amount of work importers would be required to do in order to comply with U.S. import regulations.
This information gathering is part of CBP’s general rollout of President Trump’s Strengthening Customs Enforcement executive order, which also includes the agency’s proposal to target invalid Importers of Record. The agency plans to use comments submitted to this docket to inform their rollout of additional policies mandated by the executive order.
The questions in the notice generally revolve around requiring foreign export documentation, enhanced information collection about the parties involved in creating and shipping a product, national security risk designations, supply chain tracking applications, the CTPAT program, and the economic impact of these policies. Individual questions are more illustrative of specific policies, and I strongly encourage companies to read through the individual questions that can be reviewed online via FederalRegister.gov.
Companies should think about how to respond to some of the policies contemplated by this notice, especially those of you with complex or multi-layered supply chains. IWPA plans to submit comments on this notice and will be working with several of our committees to formulate our response.
As with any call for comments, IWPA is keen to be a constructive partner; one who offers solutions instead of just saying no. That being said, we also believe in representing the needs of our members, and as an industry, we have to be careful of unnecessary or duplicative regulations. Only time will tell how this regulatory process will play out, but we encourage anyone impacted to read the notice and comment by the December 1 deadline.
