Member Feedback Requested by November 10 on NAFTZ’s Draft CBP Comments – October 17, 2026

Members of NAFTZ were emailed a notice to review NAFTZ’s draft response to CBP’s Advance Notice of Proposed Rulemaking on “Heightened Import Disclosures for Supply Chain Visibility.” The notice considers additional foreign export documentation, supply chain party identification, and tracing technology requirements that could affect U.S. FTZ operations.

A big thank-you to our Trade Relations and Rapid Response Team (TRRT) members who contributed their time and expertise to drafting these comments. Their work provides a strong foundation for explaining the practical implications for U.S. FTZs and highlighting the rigorous compliance standards and CBP oversight already built into the program.

Please send your comments and suggestions to Olivia at omcdonald@naftz.org by November 10. Examples from your operations—particularly potential costs, challenges obtaining supplier information, or duplication of existing reporting—would help strengthen the response.

We would especially welcome input from anyone who participated in CBP’s Global Business Identifier (GBI) pilot. Please share any insights from that experience that could inform our comments on identifying manufacturers, shippers, sellers, and other supply chain parties.

If your company is preparing its own comments on the ANPRM, you are welcome to incorporate points from NAFTZ’s draft. If you are also working with other associations on their responses, please consider sharing our discussion of foreign export documentation and the unique reporting and timing challenges for U.S. FTZ admissions and subsequent entries. Including these points in other associations’ comments will help reinforce the need for CBP to account for U.S. FTZ operations in any new requirements.

Your feedback will give us time to compile member input and polish NAFTZ’s comments ahead of CBP’s December 1 submission deadline.

Thank you for helping ensure our response reflects the experience and concerns of the U.S. FTZ community!