U.S. Customs and Border Protection (CBP) brought together government officials and members of the trade community in Dallas from September 8–10, 2026, for its annual Trade and Cargo Security Summit (TCSS). This year’s theme “Knowing Your Supply Chain to Remain Compliant and Mitigate Risk” was reflected throughout three days of discussions on enforcement, supply chain visibility, artificial intelligence, forced labor, transshipment, CTPAT, cybersecurity, and the future of customs compliance.
Here are some of the most important takeaways for importers.
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CBP Is Entering a New Era of Customs Enforcement
A major focus of the Summit was the Administration’s June 3, 2026 “Strengthening Customs Enforcement” Executive Order and the regulatory changes expected to follow.
The Executive Order calls for, among other things, heightened requirements for Importers of Record (IORs), expanded data and identification requirements, and increased vetting of IORs and other parties throughout the import process. CBP officials emphasized that implementation will be an agency-wide effort and that additional regulatory packages are expected.
The shift is already visible in the government’s broader enforcement posture. Discussions at the Summit emphasized customs fraud, shell companies, identity theft, false importer information, double invoicing, and other schemes CBP is encountering in the trade environment. CBP also stressed that its focus is not on ordinary clerical mistakes, but on identifying and escalating consequences for parties intentionally exploiting the system.
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Supply Chain Visibility Is Becoming a National Security Issue
Perhaps no theme came through more strongly than supply chain visibility.
Just days before the Summit, CBP published an Advance Notice of Proposed Rulemaking (ANPRM), “Heightened Import Disclosures for Supply Chain Visibility.” The ANPRM considers new requirements involving information about parties in the supply chain, foreign export documentation, global business and foreign tax identifiers, and technology that could be used to trace goods through increasingly complex supply chains. Comments are due December 1, 2026.
The significance extends beyond entry paperwork. CBP officials repeatedly connected supply chain visibility to economic and national security. Importers should increasingly expect questions not simply about what they imported and who sold it to them, but about where components and raw materials originated, who handled the goods, what processing occurred in intermediate countries, and whether the documentation supports the story being presented to CBP.
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Importers and Brokers Are Expected to Know Who They Are Doing Business With
Another recurring message was simple: know your business partners.
CBP described increasingly sophisticated fraud involving stolen identities, shell companies, fraudulent powers of attorney, nonexistent IORs, and parties acting as importers without the legitimate business’s knowledge. Customs brokers were specifically warned that they are expected to ask questions and understand both their customers and the cargo they are entering.
That does not shift the importer’s obligations to the broker. CBP leadership stressed that responsibility exists throughout the supply chain. Importers should not rely solely on a broker, freight forwarder, supplier, or other third party to validate their compliance.
For importers, now is a good time to review not only supplier due diligence but also who has access to company customs information, who maintains the ACE account, who is authorized to transact customs business on the company’s behalf, and whether company and banking information on file with CBP is accurate and current.
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AI Will Play a Bigger Role but CBP Still Wants a “Human in the Loop”
Artificial intelligence featured prominently throughout the Summit, both as an enforcement tool and as a compliance tool for the private sector.
CBP discussed using AI and advanced analytics to process enormous volumes of trade data and identify patterns that may be difficult to detect manually. For example, data can help identify sudden changes in shipment volumes, supplier relationships, production capacity, routing, and other anomalies that may indicate illegal transshipment or other compliance risks.
At the same time, one phrase repeatedly surfaced during the Summit: “human in the loop.” CBP and industry speakers emphasized the importance of human review, understanding the authority and data behind AI-generated answers, and ensuring that AI outputs can be validated.
For importers using AI for classification, supply-chain mapping, document review, or compliance analysis, appropriate human oversight remains critical.
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Forced Labor Enforcement Is Reaching Deeper Into the Supply Chain
Forced labor remains a significant CBP enforcement priority, and the discussions at the Summit reinforced the importance of multi-tier supply chain tracing.
The challenge for importers is increasingly one of visibility beyond direct suppliers. A product assembled in one country does not necessarily establish that all of its inputs are free from forced-labor concerns. The Summit discussions emphasized tracing components and raw materials farther upstream and understanding the entities involved throughout the production process.
Importers should evaluate whether they have the documentation and traceability necessary to substantiate the origin and movement of materials through multiple tiers of production.
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CTPAT Is Becoming Even More Important
The Customs Trade Partnership Against Terrorism (CTPAT) was another recurring theme.
CBP continues to view CTPAT as a way to distinguish trusted, lower-risk participants from unknown or higher-risk entities. The agency has historically used CTPAT as a public-private supply chain security partnership, allowing CBP to segment risk and focus resources on higher-risk shipments.
But the 2026 discussions suggest CTPAT could take on even greater importance as CBP implements the new Customs Enforcement Executive Order. Speakers specifically identified CTPAT membership as increasingly important and noted that CBP can focus more resources elsewhere when companies demonstrate that they are known and trustworthy.
Existing CTPAT members should not become complacent. CBP emphasized annual security-profile reviews, ongoing business-partner vetting, and ensuring that written responses accurately reflect what CBP would actually find during a validation.
What Should Importers Do Now?
The 2026 Summit made clear that importers should expect more data, more scrutiny, and greater expectations for visibility into their supply chains.
Businesses should use this period to assess whether their compliance programs are keeping pace. That includes reviewing tariff classification, customs valuation, country of origin, AD/CVD exposure, forced labor, intellectual property, PGA requirements, free trade agreement claims, and recordkeeping.
Importers should also pay close attention to CBP’s pending supply-chain visibility ANPRM. The agency is actively seeking input on the future of import disclosures and supply chain tracing, and the December 1, 2026 comment deadline provides the trade community with an opportunity to help shape requirements that could ultimately affect how companies collect and report supply-chain information.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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