ARTICLE
22 October 2026

Lynn L. Bergeson, “New U.S. Customs And Border Protection Rule Could Upend Chemical Import Compliance,” Chemical Processing, September 21, 2026.

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Bergeson & Campbell

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Bergeson & Campbell, P.C. is a Washington D.C. law firm focusing on chemical product approval and regulation, product defense, and associated business issues. The Acta Group, B&C's scientific and regulatory consulting affiliate provides strategic, comprehensive support for global chemical registration, regulation, and sustained compliance. Together, we help companies that make and use chemicals commercialize their products, maintain compliance, and gain competitive advantage as they market their products globally.
U.S. Customs and Border Protection is considering significant regulatory amendments that would require importers to provide enhanced supply chain visibility, implement technical tracing solutions, and submit foreign export documentation. These proposed changes could fundamentally alter import procedures and compliance requirements for businesses bringing goods into the United States, with public comments due by December 1, 2026.
United States International Law

On Sept. 2, 2026, U.S. Customs and Border Protection (CBP) published a consequential advance notice of proposed rulemaking (ANPRM) stating that it “is considering amending its regulations to give CBP greater visibility into the supply chains of goods imported into the United States.” (See 91 Fed. Reg. 56408.) CBP seeks comments on new requirements that it claims will enhance visibility into the parties involved in the importation of goods, integrate innovative technical solutions for the tracing of supply chains of those goods and collect foreign export documentation that foreign exporters are required to submit to the foreign customs authority prior to the exportation of those goods to the United States. New requirements could also significantly impact and complicate the import of products, including chemicals. Comments are due Dec. 1, 2026.

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