CBP Enforcement Is Tightening. Here Is What We Are Hearing from the Market.

US importers are seeing a clear shift in customs enforcement. Across conversations with large retailers, we are hearing the same concern: CBP requests are becoming more documentation-heavy, especially around country of origin, transshipment risk, and free trade agreement claims.

This is not the result of one new rule or one isolated enforcement action. Since the tariff announcements in early 2025, US trade policy has continued to move toward tighter customs enforcement, more scrutiny of origin claims, and higher expectations for importer documentation. The “Strengthening Customs Enforcement” Executive Order is the latest signal in that broader direction.

Across industries, importers are being asked to support country-of-origin claims, validate supplier declarations, and show how materials moved through multiple tiers of the supply chain. In some cases, those requests are not limited to current shipments. CBP is also asking for records tied to goods imported in 2022 and 2023, long after the products were received, sold, and moved out of the normal production cycle.

The Documentation Gap Importers are Facing

As one trade compliance leader at a large US retailer put it: “Nobody has been collecting this level of detail. Everyone is caught flat-footed.”

The challenge is not just the volume of documentation. It is that many of these records were never collected in a structured way at the time of production. Manufacturing BOMs, supplier declarations, material origin records, invoices, and chain-of-custody documents often sit across different teams, systems, and supplier tiers. When CBP requests that information, importers may have only a short window to respond, and any gaps can quickly become financial exposure.

That pressure is showing up most clearly in two areas: country-of-origin validation and free trade agreement qualification. On origin, CBP is scrutinizing potential transshipment, where goods are routed through a third country and declared as originating there, even when meaningful production value may trace back elsewhere. On FTA claims, including CAFTA-DR, importers may need to support eligibility with material-level documentation, costed production records, and manufacturer declarations.

The Shift Leading Importers are Making

Leading importers are starting to treat traceability documentation as something that should be collected during production, not reconstructed after an enforcement request arrives.

“We want to collect at the time of shipment, so if there’s ever an investigation, it’s already there.”

That is the strategic shift: proactive collection as a production workflow, not reactive assembly under a deadline. The goal is to connect documentation to the PO, supplier, material, and shipment from the start, so teams have a usable record before risk becomes urgent.

A Risk-Based Approach to Traceability

Inspectorio’s traceability approach is built around a risk-based framework. The goal is not to apply the same level of documentation to every PO, but to help teams prioritize deeper traceability where supplier, product, market, or regulatory risk is highest.

Supply Chain Mapping helps teams understand who is in the supplier network across tiers, with structured supplier profiles, risk indicators, certificates, and supporting documentation connected from the start.

Material & Component Traceability captures what went into the product, where key materials originated, and how material-level data connects back to styles, POs, certificates, and supplier declarations.

Chain of Custody adds deeper transaction-level documentation for high-risk POs, including purchase orders, invoices, transport records, and shipping documents across supplier tiers.

Together, these layers create a reusable traceability record: who is in the supply chain, what materials went into the product, where those materials came from, and how goods moved from production to shipment. That record can support CBP inquiries, but it also strengthens readiness for broader regulatory, sourcing, ESG, and supply chain risk scenarios.

CBP is one signal of a broader shift: importers need connected supply chain data that is built into everyday production workflows, so they can respond faster when risk, regulation, or enforcement pressure increases.

See how Inspectorio’s traceability model works at inspectorio.com.