CBP's 64 Questions: Is Import Compliance About to Change?

Host: Lalo Solorzano & Andy ShilesGuest(s): Humberto CaballeroPublished: September 24, 2026Length: ~33 minutesPresented by: Global Training Center Summary CBP has put 64 questions before the trade community—but are they really just questions, or a preview of where U.S. import compliance is headed? In this episode, Lalo Solorzano and Andy Shiles sit down with licensed customs broker Humberto Caballero of XP Logistics & Trade to unpack what these questions could mean for importers, customs brokers, manufacturers, and trade compliance teams. Drawing on his experience with both U.S. and Mexican customs, Humberto boils the discussion down to three critical concepts: right to make entry, traceability, and accountability. The conversation explores why CBP may increasingly expect importers to understand what happens before goods reach the U.S. border—including foreign export documentation, transaction values, supplier information, manufacturer identification, sourcing, and payment records. The team also digs into the challenges surrounding Manufacturer Identification Numbers (MIDs), supplier due diligence, CTPAT, and the growing need for trade compliance professionals to have a seat at the table before sourcing and purchasing decisions are finalized. The message for importers is clear: start preparing now rather than waiting for new requirements to arrive. Main Topic / Discussion CBP's 64 questions point toward a potentially significant evolution in how importers document, verify, and demonstrate compliance. Humberto organizes the underlying issues into three areas: right to make entry, traceability, and accountability. Importers may need greater visibility into their foreign suppliers, export documentation, transaction history, sourcing, manufacturer information, and the parties receiving the economic benefit of a transaction. The discussion also highlights the increasing importance of aligning trade compliance with purchasing, sourcing, logistics, and foreign operations. Instead of bringing compliance professionals in after a problem occurs, companies should involve them before suppliers are approved and transactions begin. Particular attention is given to foreign documentation and Manufacturer Identification Numbers (MIDs). Inconsistent manufacturer information can create complications when companies, customs brokers, and government programs are trying to establish who actually manufactured or exported merchandise. The episode also examines how U.S. compliance expectations appear to be moving toward greater traceability and how those expectations compare with practices Humberto has experienced in Mexico. Key Takeaways • Humberto summarizes the themes behind CBP's 64 questions as right to make entry, traceability, and accountability. • Importers should understand not only what they are importing, but also who they are doing business with and how their suppliers source materials. • Foreign export documentation, purchase orders, invoices, payment records, transaction values, and manufacturer information could become increasingly important parts of demonstrating traceability. • Manufacturer Identification Numbers can become inconsistent when different parties construct an MID differently or use different addresses for the same company. • Supplier due diligence should involve trade compliance—not just sourcing and purchasing. • Companies should consider maintaining reliable supplier data such as foreign tax IDs, DUNS information, manufacturer details, and applicable MIDs in their internal systems. • CTPAT continues to evolve beyond its original security focus, making traceability and trade compliance increasingly important considerations for participating companies. • A strong trade compliance function can be a competitive advantage, particularly when compliance professionals are involved before transactions occur rather than being asked to fix problems afterward. Resources & Mentions • Global Training Center