Formal Entry for Every Package: What the End of “Type 86” Means for Small Sellers Going Big
Introduction
For years, a small but hugely crucial loophole controlled the economics of cross-border e-commerce. Under Section 321 of the Tariff Act of 1930, any shipment with a value of $800 or less per person per day could be imported into the United States duty-free, with little documentation, and without the services of a qualified customs broker. Sellers—especially those selling large items such as furniture, fitness equipment, appliances, and other products shipped directly from China—built entire fulfilment strategies around this criterion.
That time is officially past. Executive Order signed by President Trump on July 30, 2025, titled “Suspending Duty-Free De Minimis Treatment for All Countries,” effective at 12:01 a.m. Aug. 29, 2025 at 7 p.m. ET Additionally, the U.S. Customs and Border Protection (CBP) announced that all Entry Type 86 filings via electronic data interchange would be rejected and all Section 321 manifest files would be deleted from the Truck Manifest Trade Portal. One regulatory move cut off the informal entry channel that had handled the vast bulk of U.S.-bound e-commerce shipments.
For sellers of big and heavyweight goods, the category that logistics specialists call “super large items” or 超大件 in Chinese trade lingo, this move is more than an inconvenience. It changes the economic model, the compliance load and the strategic calculus of exporting large products from China to Europe and the US dramatically. In this essay, we’ll explain what happened, why it matters and what operationally serious sellers should do about it.
A Brief History of Type 86 and De Minimis
The de minimis exemption originated from 1930, but only took the form in which it is economically relevant today when the Trade Facilitation and Trade Enforcement Act of 2015 upped the de minimis level from $200 to $800. That surge, along with the boom in direct-from-China platforms, set the stage for a record-setting amount of duty-free exports. CBP data indicated that by 2023, about 79% of de minimis entries entered the U.S. through either the Entry Type 86 Test or the Section 321 Data Pilot, both voluntary pilot programs introduced in 2019 to provide more data insight into low-value exports.
In effect, an Entry Type 86 was a codified, broker-facilitated de minimis entry. It was more demanding than a basic carrier manifest statement but much less burdensome than a complete formal entry, requiring the production of a 10-digit Harmonised Tariff Schedule (HTS) code and Partner Government Agency (PGA) compliance data. Type 86 opened the door for goods that were previously unable to benefit from de minimis classification because to PGA restrictions. Licensed customs brokers filed entries using the Automated Commercial Environment (ACE), the entry was processed timely, and commodities moved.
The approach was elegant in efficiency but it also produced vast enforcement gaps. The influx of low-value packages concealed fentanyl precursors, products created with forced labour, counterfeit goods, and devalued shipments. CBP itself admitted that the volume made targeted examination practically impossible. The pressure from local manufacturers, labour organisations and national security proponents progressively built, and by 2024 the writing was on the wall.
The Timeline of Policy Change
The background matters here. To appreciate where the market is today, it’s vital to note that the de minimis unravelling unfolded in stages.
| Date | Event | Impact |
| May 2, 2025 | De minimis exemption eliminated for China/Hong Kong goods | All China-origin parcels required formal entry regardless of value |
| July 30, 2025 | Executive Order suspending de minimis globally signed | Extended duty requirements to all countries worldwide |
| August 29, 2025 | Global suspension takes effect | CBP rejects all Type 86 EDI filings; Section 321 manifests removed |
| Ongoing 2025-2026 | Enhanced Entry Process proposed | CBP developing streamlined formal entry for low-value goods, built on Type 86 data elements |
What you see in this timeline is a planned, staged escalation. The trade community had some warning about the loss of de minimis protections, first for China-origin items, by far the largest part of cross-border e-commerce traffic. The global extension in August 2025 was the ultimate act, blocking the route completely for vendors anywhere in the globe who had continued to rely on simple access.
Crucially, CBP’s longer-term strategy includes a “Enhanced Entry Process” that builds upon the data infrastructure established through the Type 86 Test. So it’s not necessarily that the agency is against expedited entry, it’s that they want better data, they want greater compliance and they want to see actual duty collected on items that were previously getting by.
What “Super Large Items” Actually Face Now
Formal entry is an additional cost for normal small packages – broker fees, bond requirements, HTS classification, duty payments. The repercussions are more profound for dealers of big, heavyweight goods, as many were not employing de minimis in the first place. But the regulatory move affects all segments of cross-border freight, even the specialised niche of shipments up to 8 metric tonnes in weight with individual dimensions beyond 4 meters.
Cost Structure Has Changed for Everyone
Even merchants who delivered via ocean freight under official entry have been enjoying the advantages of a logistics ecosystem geared to high-volume, lightweight parcel flows. The market, where de minimis handled the lion’s share of entry volume, showed itself in port processing times, broker fee structures and carrier pricing. As that traffic now enters into formal entry, processing queues lengthen, broker resources become more limited, and administrative costs climb. Industry estimates are that paperwork processing times might go up by 30 to 50 percent under the new regime, while per-parcel broking and handling fees from carriers and customs brokers have climbed by $10 to $20 for many shipments.
This sharpens the competitive focus on big goods where logistical costs per shipping are already high. Sellers of products including massage chairs, treadmills, dining table sets, refrigerators and industrial lighting, who were already working on narrow international margins, will now have to model customs compliance as a fixed overhead with more accuracy.
The Tariff Math for China-Origin Oversized Goods
| Product Category | Applicable Tariff Rate | Entry Requirement | Key Consideration |
| Furniture (sofas, beds, tables) | Up to 25% (Section 301) | Formal Entry (Type 01 or Type 11) | High classification sensitivity; AD/CV exposure |
| Home Appliances (washers, fridges) | 15-25% (Section 301) | Formal Entry | PGA requirements (CPSC) for electrical safety |
| Fitness Equipment (treadmills, bikes) | 7.5-25% (Section 301) | Formal Entry | Weight-based freight premium; classification varies |
| Electric Vehicles / E-Bikes | Up to 100%+ (IEEPA + Section 301) | Formal Entry | Battery-related PGA requirements (DOT, EPA) |
| Industrial/Commercial Equipment | Varies widely | Formal Entry | Potential AD/CV exposure for metal components |
The aforesaid tariff rates are not new. Section 301 tariffs on Chinese goods have existed since the first Trump administration. The new thing is that there’s no way to avoid them for low-value goods. Theoretically, under the former regime, a seller may design shipments to fall within de minimis. The existing system does not allow structure. The entry is formal, the HTS code is verified and the duty is collected.
What Changes for European Market Sellers
European e-commerce merchants and Chinese exporters selling to EU markets are facing a similar, but different, regulatory trend. The U.S. measures have garnered more immediate headlines, but the European Union has been headed in the same way. The EU’s customs reform proposal, which has been under discussion since 2023 and is being phased in, tackles the same de minimis abuse that led to U.S. policy action. The proposed amendments in the EU would remove the exemption from customs duties for imports worth less than EUR 150 and would require formal customs declarations for all commercial products regardless of their value.
Topway Shipping’s European presence is especially significant for sellers of exceptionally big items targeting European buyers. The company provides a DDP (Delivered Duty Paid) door to door service to 25 EU member states and also provides in-house customs clearance through its own approved clearance operations. The liability to comply is not the seller’s, it’s the logistics provider’s, and he does it within a specified cost structure.”
Below is a channel comparison showing how vendors targeting Europe should be considering route selection in the current market.
| Channel | Transit Time | Price Sensitivity | Customs Handling | Best For |
| European Air Freight | 12-15 days | High (premium) | Full formal entry | High-value seasonal goods |
| European Ocean Freight (FCL/LCL) | 45-50 days | Low (economy) | Full formal entry; DDP available | Bulky, heavy items; cost-sensitive |
| China-Europe Rail (China-Europe Express) | 30-45 days | Medium | Full formal entry | Mid-range urgency; e-commerce cargo |
| Overseas Warehouse + Last Mile | Variable | Medium-low | Pre-cleared stock | B2C fulfillment; appointment delivery |
How Topway Shipping Navigates the New Compliance Landscape
Topway Shipping was founded in Shenzhen in 2010, and has developed its business identity around the very type of freight most directly affected by the new customs environment: big, heavyweight items transiting from China to Europe and North America. Founders of the company have over 15 years of industry expertise with a speciality in cross-border logistics and customs clearance, and have experienced every phase of the U.S.-China trade policy cycle.
Topway Shipping also offers shipping to 25 European countries on a DDP basis thereby becoming the importer of record and including the customs clearance process within its service delivery. For sellers who have used de minimis in the past to simplify their compliance picture, this model provides a like-for-like replacement: one logistics partner to pick up from the Chinese factory, consolidate at the Shenzhen warehouse, move by ocean or rail, clear customs at destination and schedule last mile to the end customer’s door.
The company’s super large item capabilities is specifically suited to the product categories most affected by the regulatory change. Topway Shipping’s network can accept shipments with items weighing up to 8 metric tonnes and measuring up to 8 meters in any one dimension. The 2.57 metre height limit for in-home delivery is matched to conventional residential access in European markets.
On the tech side, Topway Shipping has a patented smart logistics platform – the 欧象 (OuXiang) system – that provides sellers with full shipping visibility from order to client signing. In a world where the customs clearance process creates procedural procedures, real-time tracking is no longer a value-added feature but a compliance and customer experience issue. Delays caused by clearance holds are much easier to justify if the seller can tell the buyer exactly where the shipment is and why it is being held.
The scale numbers from the company’s latest disclosures speak of real operational depth – 3 million-plus kilometres of delivery mileage, 200,000-plus parcels dispatched, 5,000 square meters of standardised warehousing, 2,000-plus monthly order volume shipments, 1,000-plus transacting customers and 80-plus partner relationships across its logistics network. These aren’t vanity numbers, but rather the infrastructure required to absorb regulatory complexity at scale.
Practical Implications for Sellers: What You Should Do Now
The demise of Type 86 and Section 321 de minimis is not a one-off blip. CBP made it plain in its announcement that it will not accept any Type 86 EDI files from now on, and the political agreement for the change includes both major parties in the U.S. Sellers need to think of this as a permanent structural change and change their operations accordingly.
Classify Your Products Immediately
If you haven’t already issued precise 10-digit HTS numbers to every product in your catalogue, do it now. Under the new regime, fines for misclassification can exceed duties avoided, and CBP is actively looking at entries that were previously filed under simplified methods. Oversized goods are generally classified under difficult HTS chapters on furniture (Chapter 94), machinery (Chapter 84), automobiles (Chapter 87) and electrical appliances (Chapter 85). Classification mistakes are frequent and costly.
Recalculate Your Landed Cost
Your 2024 landed cost model is no longer valid. The correct calculation now includes any and all applicable Section 301 duties based on your HTS code, any antidumping or countervailing duties specific to your product category, customs broker fees (typically $50-$150 per formal entry), ISF (Importer Security Filing) fees, any port handling charges associated with formal entry processing and last mile delivery costs for oversized items that require appointment scheduling.
For several product categories, landing costs will climb by between 15 and 25 percent from pre-2025 levels. That’s the statistic that should guide price decisions, not hopes of a policy reversal.
Evaluate Overseas Warehousing as a Buffer
One pragmatic approach to increased customs complexity is to shift inventory to overseas warehouses ahead of peak demand seasons. Sellers can mitigate the compliance overhead and remove the per-shipment broking cost on B2C orders by pre-clearing products in bulk when customs lineups are shorter. Topway Shipping’s international warehouse services in Europe include inbound processing, relabelling, repacking and B2C shipment, which makes them an ideal staging point for sellers looking to untether their supply chain from the compliance timetable.
Partner With a Logistics Provider That Owns Its Customs Capability
In the old de minimis era, logistics and customs were largely independent issues. From now on they are one. A logistics service that utilises third-party brokers for customs clearance will create delays, communication gaps and accountability gaps that a provider with in-house clearing competence will not. The fact that clearance and delivery are integrated is a real operational advantage, especially for sellers of exceptionally big items, where a single shipping delay might lead to a missed installation appointment, a customer service escalation, and a poor review.
The Competitive Landscape Has Actually Leveled
It is worth stepping back from the operational complexity to notice something counterintuitive: for established sellers of excellent large items, the end of de minimis may not be all bad news. For years, several cross-border platforms exploited the de minimis loophole to ship straight to U.S. and European consumers with rates that included zero duty cost. This artificially squeezed margins for sellers operating under the full import system.
The April 2025 Consumer Edge research revealed a sharp deceleration in growth for the top direct-from-China platforms and a shift in consumer spending share toward established U.S. and European merchants. The tariff wall is real, and all China-sourced goods — including ultra-low-cost players who based their strategies on regulatory arbitrage — are impacted. Those that have invested in product quality, post-sale support and reliable fulfilment are now on a more level playing field.
This is a time for Chinese manufacturers and exporters of serious, high-quality large items – the furniture makers, appliance brands and fitness equipment companies that have real engineering and design invested in their products – to reassert value propositions that have been obscured by price-dumping strategies. Compliance expenses are significant, but they are common to all market players. Today, the differentiators are operational excellence, service quality, and logistics reliability.
Conclusion
The termination of Entry Type 86 and the global freeze of Section 321 de minimis is a true turning point for cross-border e-commerce, and especially for sellers of big and heavyweight items travelling between China and Western markets. The informal entry channel that used to handle the bulk of U.S. inbound goods is gone, and the compliance rules that apply to a shipment of treadmills are now structurally identical to those that apply to a container of semiconductors.
This is no excuse to pull out of overseas markets. That’s a cause to get serious about logistics infrastructure. Sellers who have structured their supply chains around partners with real customs competence, owned clearing capabilities and specialist experience with super big item delivery will absorb the new expenses a lot more efficiently than those who still approach logistics as a commodity procurement exercise.
That is exactly the operating environment for which Topway Shipping’s model was created – a DDP door-to-door service across 25 EU countries, in-house customs clearance, dedicated handling of extremely big items (up to 8 tonnes and 8 meters) and its own tracking platform. The challenge for vendors is not whether to follow formal entrance procedures. The answer to the question is: The challenge is, who do you trust to oversee that compliance when your goods are crossing the Pacific or the Eurasian continent.
FAQs
Q: What exactly is Entry Type 86, and why does its end matter?
A: Entry Type 86 was a U.S. Customs and Border Protection informal entry type that permitted items worth under $800 to clear customs electronically using the Automated Commercial Environment (ACE) without paying duties. This involved a 10-digit HTS number and a registered customs broker, more rigorous than a basic carrier manifest but significantly less difficult than a formal import entry. Its removal implies that all shipments – regardless of value – now have to be subject to formal entry, pay appropriate tariffs and meet all paperwork requirements.
Q: Does this affect shipments to Europe, or only the United States?
A: The executive order of August 2025 applies only to the United States. But the European Union has been following parallel customs reform along similar lines, including the removal of the EUR 150 low-value import exemption for commercial items. Sellers seeking European markets should assume that informal entry privileges are tightening worldwide and manage their logistics appropriately.
Q: What are the typical costs sellers can expect under formal entry for oversized items?
A: Beyond any applicable import duties (which can range from 7.5% to well over 25%, depending on the product category, for China-origin goods) sellers should budget for customs broker costs (about $50 to $150 per entry), ISF filing fees, and any port handling expenses particular to the destination. Last-mile fees can include big products that require appointment delivery. When working with a DDP logistics provider like Topway Shipping, these fees are combined into one quote, making it easier to plan.
Q: Can I still ship oversized goods from China to Europe competitively under the new rules?
A: Yeah. The new customs rules add expense and administrative complexity, but they are the same for all market participants. Now sellers who have invested in product quality and customer service are on a more level playing field than when ultra-low-cost competitors were taking advantage of de minimis loopholes. It is essential to have the correct logistics partner with in-house customs clearance and expertise in delivering large items to keep landed costs predictable and delivery performance good.
Q: How does Topway Shipping handle customs clearance for super large items?
A: For DDP shipments to 25 EU countries, Topway Shipping does customs clearance in-house. The company’s team handles HTS classification, duty calculation, documentation preparation, and communication with customs authorities at the destination port or border. That means the seller does not need to pay for a separate customs broker – it’s included as part of the end-to-end logistics solution.
