Your Grade Spec Has a Docket Number Now
A customs rulemaking published this morning asks whether importers should hand over the export declaration their foreign supplier filed at home, and whether composition and grade belong on the entry itself. Commerce has opened 17 circumvention inquiries this year, the most since at least 2010, and the document CBP is asking about would settle most of what those inquiries are trying to prove.
Executive Order 14411 gave the Secretary of Homeland Security 90 days to establish a requirement that importers produce whatever paperwork their foreign supplier filed with its own customs authority before the goods ever left.
The order was signed June 3. Day 90 was yesterday.
At 8:45am yesterday CBP filed an advance notice of proposed rulemaking, and it published this morning at 91 FR 56408.
The notice establishes nothing. It asks 64 numbered questions, and the answer window closes December 1.
"Who has to prove where a molecule came from, and with which piece of paper?"
Commerce has spent the year answering that one the slow way, at a rate with no precedent in the record since 2010: 17 circumvention inquiry initiations published so far in 2026, against a previous full-year high of ten (chart below). Three of the seventeen are the alkyl phosphate ester orders this desk was reading yesterday.
Here is what the docket would change for you.
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