Importer Product Data and CBP Compliance: What Reasonable Care Really Requires

Importers often assume they can outsource compliance to their customs broker. In some ways that may be true, but under 19 U.S.C. § 1484, the responsibility for reasonable care sits with the importer of record. As customs enforcement expands, a gap grows between the information a customs broker submits and what an importer can actually support. For many importers, that gap comes from product data sitting in outdated spreadsheets that were never designed to demonstrate compliance with U.S. Customs and Border Protection (CBP) requirements.

This article explains why importers must own the compliance process, what that looks like when the company has no in-house trade expertise, and how technology such as the Tru Identity platform can help.

Why CBP's New Disclosure Requirements Raise the Bar for Importer Product Data

Customs enforcement has increased, and CBP is paying closer attention to imported goods. Importers now have two obligations: comply with the regulations, and show that compliance through documentation. Most importers struggle with the second. The September 2, 2026 ANPRM (Docket No. USCBP-2026-1058) signals where CBP is headed.

Under Executive Order 14411, CBP has signaled that it intends to expand what importers must disclose. The proposal could require importers to submit foreign export documentation, provide more information about the participants in their supply chain beyond today's manufacturer identification codes, and use global business identifiers such as D-U-N-S numbers and Legal Entity Identifiers on the entry summary.

Ultimately, CBP wants to know more about who made your product, where it came from, and whether the data on your entry summary can withstand scrutiny. Importers who can't show documented records of classification, value, and origin face real exposure.

Where Import Compliance Breaks Down: Supply Chain Documentation and Centralized Product Data

For importers, the most common failure point is the lack of centralized, up-to-date product information to base compliance decisions on. According to Hugo Pakula, CEO of Tru Identity, "people do not have master data. They're using a spreadsheet, and the spreadsheet's managed by many people and it's not kept up to date in one place."

Tru Identity sees this breakdown happen in two places.

Introducing new products: When an importer adds hundreds of new products to its catalog, the time needed to classify each one under the Harmonized Tariff Schedule (HTS) and confirm its country of origin becomes overwhelming. Capturing every dutiable addition adds more manual work, and importers also need to check customs value against the declared value on each transaction.

Keeping data current: Trade agreements and tariffs change often and with little notice, and each change can shift the compliance requirements for your product category. Periodic reviews of entry data and product information keep classifications, valuation inputs, and origin rules current. If your product data lives in a spreadsheet, responding to those changes is slow, and the delays create gaps that lead to penalties.

Accurate product data is also a competitive advantage. "Everybody's dealing with this complexity, including your competitors," Pakula said. "If you get this right, chances are that you'd be more agile in this environment." Centralized data streamlines the process and makes customs audits easier to manage.

What It Means for Importers to Own Customs Compliance Without In-House Trade Expertise

Even if an importer lacks in-house trade compliance expertise, it still needs to manage and control the compliance process itself rather than leaving every part of it to its customs broker.

Tru Identity helps by breaking product compliance down into four basic questions for each import:

• What is the product?
• What is it made of?
• Who is involved in manufacturing it?
• What is its intended use?

As long as an importer can answer these four questions, Tru Identity can handle the compliance work. Each imported product passes through the same verification process that CBP uses, and the platform flags products that need attention. The result is an audit trail that demonstrates reasonable care.

How Tru Identity Gives Importers the Same Compliance Technology CBP Uses

Tru Identity's importer product is the first compliance platform in U.S. Customs history to give importers access to the same compliance verification technology used by CBP. CBP selected Tru Identity for its Commercial Solutions Opening Pilot (CSOP), a direct government partnership that allows Tru Identity's compliance platform to be used in both public and private sector applications when creating customs entries.

Tru Identity's importer and broker products use the same compliance engine. The broker product shows detailed technical information such as Chapter 99 codes, antidumping data, and PGA requirements down to the individual line item. The importer product delivers the same compliance verification in a plain-English interface built around product knowledge.

Tru Identity also creates a timestamped audit trail of every applicable rule, including the version of each rule in effect when the entry was created and filed. That audit trail gives importers the proof of reasonable care that CBP expects, and because it builds automatically throughout the entry process, importers don't have to spend extra resources documenting their own evidence.

Tru Identity also integrates with importers' existing systems, which matters more for importers than for brokers. If your product data lives in an ERP, a procurement system, a shared drive, and a collection of spreadsheets, Tru Identity brings it together into one verified source of truth. Contact us today to get started.

Frequently Asked Questions

Q1. Does CBP require importers to submit foreign export documentation?

CBP is considering requiring foreign export documentation for imports through an ANPRM published on September 2, 2026 under Executive Order 14411. Comments are due December 1, 2026. No final rule has been issued, but the direction suggests importers should prepare for more supply chain documentation requirements.

Q2. What are Global Business Identifiers, and how could they replace Manufacturer Identification Codes?

Global Business Identifiers (GBIs) are private-sector identifiers such as D-U-N-S numbers, Global Location Numbers, and Legal Entity Identifiers. CBP has been testing GBIs through a voluntary pilot and is now assessing whether to require them on the entry summary in place of the existing Manufacturer Identification Code system, which CBP finds inadequate for enforcement.

Q3. How do importers demonstrate reasonable care to CBP?

Importers demonstrate reasonable care by keeping documented records of how they classified every product, how they determined value, and where those products originated. The duty of reasonable care falls on the importer of record under 19 U.S.C. § 1484. CBP reviews whether your entry data is accurate and complete, and whether your internal controls can support it.

Q4. Can importers use the same compliance technology as CBP?

Through the Commercial Solutions Opening Pilot, Tru Identity's importer product gives importers access to the same compliance verification technology CBP uses internally. The importer version uses plain English and requires no trade expertise. If you can answer four questions about your product, Tru Identity handles the compliance verification and builds the audit trail that demonstrates reasonable care.

Q5. What happens if importer product data isn't centralized?

Decentralized product data leads to classification errors, missed tariff changes, and inconsistent entry filings. When CBP audits an importer whose data lives across multiple spreadsheets, reconstructing the rationale behind a classification from months earlier becomes difficult and expensive. Documentation gaps can trigger penalties, and misclassification can compound into duty shortfalls.