As I write my final article as Chair of the National Association of Foreign-Trade Zones (NAFTZ), I'm once again reflecting on how much our trade environment has evolved over the past several years. New tariff structures, heightened enforcement priorities, supply chain resiliency concerns, forced labor compliance, national security considerations, and growing expectations around transparency have fundamentally reshaped the customs landscape.

That reality makes this an appropriate moment to focus less on farewells and more on what lies ahead.

Two recent developments deserve the attention of every importer, customs professional, and FTZ operator: Executive Order 14411, "Strengthening Customs Enforcement", issued on June 3, 2026, and CBP's Advance Notice of Proposed Rulemaking on Heightened Import Disclosures for Supply Chain Visibility, published on September 2, 2026. Together, these actions signal what may become the most significant expansion of customs compliance expectations since the principles of informed compliance and shared responsibility were established under the Customs Modernization Act.

At its core, the Executive Order is about accountability, transparency, and enforcement. The Administration's stated objective is to strengthen customs enforcement by addressing perceived vulnerabilities related to importer identification, supply chain visibility, undervaluation, transshipment, origin claims, and duty collection. Among other initiatives, the Order directs CBP to pursue enhanced importer-of-record requirements, additional ownership and financial disclosures, expanded supply chain visibility, collection of foreign export documentation, increased audits, stronger penalty standards, and new approaches to importer vetting and risk management.

While many of these initiatives will require rulemaking before they become effective, the policy direction is unmistakable: CBP expects importers to know more about their supply chains, retain more documentation, and demonstrate greater accountability than ever before.

Importantly, CBP is not simply announcing new requirements. Through the recently published ANPRM, the agency is actively seeking stakeholder feedback before drafting proposed regulations. The notice poses more than 60 questions on topics ranging from foreign export documentation and recordkeeping obligations to manufacturer identification, Global Business Identifiers (GBIs), supply chain tracing technologies, and the future role of CTPAT in customs enforcement.

For importers, three themes stand out.

First, supply chain visibility is rapidly becoming a strategic compliance requirement. Many companies know their direct suppliers well, but far fewer have visibility into upstream suppliers, production processes, logistics providers, and sourcing relationships. The ANPRM makes clear that CBP is considering ways to obtain greater transparency throughout the supply chain. Importers should evaluate where visibility gaps exist, what information is available today, and how quickly supporting documentation can be produced when requested.

Second, recordkeeping expectations may expand significantly. One of the most notable concepts under consideration is whether importers should obtain and retain documentation submitted by foreign exporters to their own customs authorities. Whether these materials ultimately become filing requirements or recordkeeping obligations, companies should begin assessing their document retention practices, supplier agreements, and internal controls now rather than waiting for final regulations to emerge.

Third, customs compliance is increasingly being viewed through the lens of national and economic security. As a result, compliance can no longer be viewed solely as a trade department responsibility. Procurement, sourcing, logistics, technology, legal, and executive leadership teams will all need to be aligned as expectations continue to evolve.

For the U.S. FTZ community, these developments should sound familiar.

Foreign-Trade Zones have long been built around the principles of accountability, visibility, control, and partnership with CBP. As regulators place greater emphasis on supply chain transparency and compliance assurance, U.S. FTZ operators and users are uniquely positioned to demonstrate the value of strong inventory controls, disciplined recordkeeping, and robust compliance programs. As CBP evaluates future approaches to importer accountability and supply chain visibility, U.S. FTZ stakeholders have an opportunity to highlight how zones already support many of these objectives.

Just as importantly, U.S. FTZ participants should engage in the rulemaking process. The ANPRM stage is where industry input can have the greatest impact, and CBP is specifically requesting feedback on implementation challenges, costs, technology capabilities, and operational realities. The NAFTZ will be preparing comments, and I encourage members to read both documents, evaluate their potential impact, and consider participating in the process. The future customs environment is being shaped today.

As I conclude my term as Chair, I want to express my sincere gratitude to the NAFTZ membership, Board, staff, committee leaders, and the many volunteers who dedicate their time and expertise to strengthening our community.

Serving this organization has been one of the greatest professional honors of my career.

The customs and trade environment will continue to evolve. New regulations will emerge. Enforcement priorities will shift. Uncertainty will remain part of the landscape. But one thing has always given me confidence about the future of our profession: this community.

The U.S. FTZ industry has consistently demonstrated resilience, collaboration, innovation, and an unwavering commitment to compliance. Those strengths will continue to serve us well in whatever comes next.

Thank you for your partnership, your friendship, your willingness to share knowledge, and your commitment to advancing the U.S. FTZ program. We may not always know what lies around the next corner, but I am confident that, together, this community will continue to adapt, lead, and succeed.

Thank you for allowing me the privilege of serving as your Chair. As we navigate the next chapter of customs and trade together, remember: we're all in this together.