Пошаговое соблюдение требований: почему окончание льготного периода меняет всё
For most of the last decade, low-value e-commerce shipments moved into the United States on a kind of administrative autopilot. A carrier filed a manifest, CBP glanced at the aggregate data, and packages under the $800 de minimis threshold rolled through without anyone touching a Harmonized Tariff Schedule book. That system is gone. Since the August 2025 suspension of Section 321 treatment, and especially since CBP folded that suspension into standing regulation on June 24, 2026, every commercial shipment entering the United States now needs an individual entry, a duty calculation, and a party willing to stand behind the paperwork. The grace period that let brokers, carriers, and postal operators ease into the new world is closing on a fixed schedule, and the shippers who treated it as optional guidance rather than a hard deadline are the ones now scrambling.
This piece is written for freight forwarders, customs brokers, and cross-border e-commerce sellers who need to understand not just that the rules changed, but exactly what changes operationally when every parcel becomes its own entry. We will walk through the regulatory timeline, compare the entry types now in play, look at what entry-by-entry filing actually costs in time and money, and outline what a sensible compliance posture looks like heading into the fourth quarter of 2026.
From Manifest Clearance to Individual Entry
The old de minimis process relied on what CBP calls release from manifest: a carrier could list a shipment on a bill of lading or manifest, and as long as the declared value stayed under $800 per person per day, the goods could be released without a formal entry. It was fast, it was cheap, and it was built for a world where cross-border parcel volume was a fraction of what it is today. CBP itself has acknowledged that the original justification for the exemption — limited agency capacity to process high volumes of low-value entries — no longer holds now that automation handles targeting, verification, and duty collection at scale.
The practical result is that a shipment which once needed only a line on a manifest now needs a full data set: an accurate 10-digit HTSUS classification, a declared value, a country of origin, an importer of record, and in many cases a bond. Multiply that by the millions of parcels that used to move through Section 321 channels every week, and the scale of the operational shift becomes obvious. The table below lays out the sequence of regulatory milestones that brought the industry to this point.
| Время | Что произошло |
| Август 29, 2025 | Executive Order suspends the $800 de minimis exemption for all countries; most low-value shipments must file informal or formal entry. |
| 20 февраля, 2026 | Executive Order 14389 ends certain IEEPA ad valorem duty actions but leaves the de minimis suspension itself in place. |
| 28 февраля, 2026 | International postal carriers lose the option of a flat per-item duty; only the ad valorem method is permitted going forward. |
| Июнь 24, 2026 | CBP publishes interim final rules that codify the suspension into 19 CFR 10.151 and 19 CFR 145.31, moving it from executive-order policy into standing regulation. |
| Июль 24, 2026 | The new postal informal entry process takes effect; the public comment period on the rulemaking closes the same day. |
| 22 октября, 2026 | Full compliance deadline for postal shipments that carry PGA data requirements or fall under HTSUS Chapter 98/99 — the effective end of any remaining grace period. |
What stands out in that timeline is how the story shifted from executive action to durable law. An executive order can be reversed by the next administration with the stroke of a pen; a rule codified in the Code of Federal Regulations, and reinforced by statute through the One Big Beautiful Bill Act’s 2027 termination date, is a different animal entirely. Freight forwarders who were hoping the suspension might quietly lapse now have their answer — it will not.
Type 86, Type 11, Type 01: Choosing the Right Entry
Entry-by-entry compliance does not mean every shipment follows the same path. CBP still recognizes several entry types, and the one that applies to a given parcel depends on its value, its commodity classification, and whether it triggers requirements from a partner government agency such as the FDA or CPSC. Type 86 has not disappeared entirely, but with de minimis suspended it is largely unavailable for the shipments that used to rely on it. Most low-value e-commerce parcels are now funneled into either Type 11 informal entry or Type 01 formal entry, while a new Type 13 pilot process handles certain international mail.
| Тип входа | Типичное использование | Bond Needed? | Обязанности по обращению |
| Тип 86 (устаревший) | Section 321 low-value e-commerce parcels | Нет | Duty-free (now largely unavailable) |
| Введите 11 | Informal entry, generally under $2,500 | Часто нет | Duties and fees apply |
| Введите 01 | Formal consumption entry, higher value or regulated goods | Да | Duties, taxes, and MPF/HMF apply |
| Type 13 (pilot) | New electronic informal entry for international mail | Да | Duties apply; ad valorem method only |
The distinction matters because it determines the compliance burden a forwarder or seller takes on. A formal entry demands a bond, a licensed broker’s involvement, and exposure to CBP’s full audit and penalty apparatus if the classification is wrong. An informal entry is lighter, but it is not exempt from duty, and CBP’s automated systems now flag inconsistent or repetitive filings from the same importer far more readily than the old manifest process ever did. Getting the entry type wrong, even innocently, can mean a shipment sits in a bonded warehouse while a broker refiles the paperwork — a delay that a direct-to-consumer brand selling on tight delivery windows simply cannot absorb.
What the Postal Channel Looks Like Now
International mail was carved out of the original Section 321 collapse because postal networks were not equipped to file individual electronic entries overnight. CBP allowed carriers a transitional flat per-item duty option while it built out a proper collection mechanism. That flexibility ended on February 28, 2026, after which every postal carrier and CBP-certified qualified party had to switch to the ad valorem method — duty calculated as a percentage of declared value, tied to the country of origin, item by item.
The new postal informal entry process, created by the interim final rule published June 24, 2026, took effect July 24, 2026, with full compliance required by October 22, 2026 for shipments carrying PGA data requirements or Chapter 98/99 duty claims. CBP is also running a voluntary electronic pilot, Entry Type 13, aimed at mail shipments valued at $2,500 or less and classifiable in HTSUS chapters 1 through 97. The disruption this caused upstream was significant — at least 88 national postal operators paused US-bound parcel acceptance at some point during the transition, and Japan Post suspended shipments to the United States for eight months before resuming with a pre-payment system in place. For any business that still routes low-value goods through postal channels rather than express or ocean freight, this is the piece of the rulebook that deserves the closest attention right now.
The Real Cost of Filing Every Parcel Individually
It is worth being blunt about what entry-by-entry compliance costs, because the gap between the old system and the new one is not just procedural. Under manifest release, a forwarder’s cost per parcel was close to zero beyond the freight itself. Under formal or informal entry, each shipment now carries brokerage fees, Merchandise Processing Fees where applicable, potential Harbor Maintenance Fees for ocean cargo, and the duty itself, which for many product categories runs well above what sellers had budgeted for under de minimis pricing.
Bonding is the other line item that catches sellers off guard. A single transaction bond covers one formal entry and is generally sized to the value of the goods plus duties, taxes, and fees, with higher amounts for regulated commodities. A continuous bond, by contrast, covers all of an importer’s entries at every US port for a full year and is typically set at the greater of a $50,000 minimum or ten percent of duties, taxes, and fees paid over the trailing twelve months. For a seller who used to ship thousands of low-value parcels a month through Section 321, the arithmetic on a continuous bond changes fast once every one of those parcels needs individual entry.
Misclassification risk rises in step with volume. A single wrong HTSUS digit on one manifest-cleared shipment used to be a rounding error; the same mistake repeated across ten thousand individually filed entries is now a pattern CBP’s automated review can catch, and it is the kind of pattern that leads to penalties, not just a duty adjustment.
Building an Operating Model That Survives the Transition
The forwarders and sellers weathering this shift well share a few habits. They classify products at the SKU level well before goods leave the origin warehouse, rather than leaving HTSUS assignment to whoever is filing the entry at the last minute. They consolidate shipments where it makes commercial sense, because a well-structured FCL or LCL ocean shipment cleared through a single formal entry is often more predictable, and ultimately cheaper per unit, than thousands of individually filed parcels moving by air or post. And they work with partners who already hold continuous bonds and established broker relationships, rather than trying to stand up bonding and customs infrastructure from scratch under deadline pressure.
There is also a sequencing question that trips up a surprising number of sellers: origin documentation. An entry can only move as fast as the data behind it, and if the commercial invoice, packing list, and country-of-origin declaration are inconsistent with what shows up at the port, the entry stalls regardless of how good the broker is. Fixing that discipline at the factory or warehouse level, well before goods are booked onto a vessel or flight, is the single highest-leverage change most sellers can make this quarter.
How Topway Shipping Supports Entry-by-Entry Compliance
This is precisely the environment Topway Shipping was built for. Since 2010, Topway Shipping, headquartered in Shenzhen, China, has been a professional provider of cross-border e-commerce logistics solutions, and the company’s founding team brings more than 15 years of experience in international logistics and customs clearance, with a strong focus on China–U.S. transportation — the exact trade lane most affected by the de minimis suspension.
Rather than leaving sellers to piece together classification, bonding, and clearance on their own, Topway Shipping’s services span the entire logistics chain: first-leg transportation out of China, overseas складирование that lets sellers consolidate before customs entry, formal customs clearance handled by an experienced team rather than an unfamiliar last-minute broker, and last-mile delivery once goods are released. For sellers rethinking how much volume should move by air versus ocean now that per-parcel duty and filing costs have risen, Topway Shipping also offers flexible full-container-load and less-than-container-load ocean freight services from China to major ports worldwide, giving forwarders and brands a practical way to shift volume toward entry structures that are more predictable under the new rules.
For a business trying to keep landed costs stable while CBP’s compliance requirements keep tightening, that kind of single-chain visibility, from the first mile in China through customs clearance to the customer’s door, is what turns entry-by-entry filing from a daily fire drill into a manageable, budgeted part of the supply chain.
Заключение
The grace period built into the de minimis suspension was never meant to be permanent, and the schedule CBP has now locked into regulation makes that unmistakable. October 22, 2026 is not a soft target; it is the date by which postal shipments carrying PGA requirements or Chapter 98/99 duties must fully comply with the new entry process, and it sits alongside a broader shift that has already reshaped how every low-value shipment enters the country. Forwarders and sellers who spent the transition period building real entry-by-entry processes — accurate classification, adequate bonding, disciplined origin documentation, and dependable clearance partners — are moving into the next phase of trade with confidence. Those who treated the grace period as a reason to wait are finding that the window to adjust smoothly has already closed. Partnering with an experienced logistics provider like Topway Shipping is one of the more direct ways to close that gap quickly, without having to build customs and bonding infrastructure from the ground up under deadline pressure.
Часто задаваемые вопросы (FAQ)
Q: Is the de minimis exemption completely gone, or could it come back?
A: It is suspended indefinitely and, as of June 24, 2026, codified into CBP regulations rather than resting on executive order alone. The One Big Beautiful Bill Act also sets a statutory end date of July 1, 2027, so the direction of travel is toward permanent removal, not restoration.
Q: What is the actual deadline shippers need to hit?
A: October 22, 2026 is the compliance deadline for postal shipments subject to PGA data requirements or HTSUS Chapter 98/99 duties under the new postal informal entry process, which itself took effect July 24, 2026.
Q: Do all low-value shipments now need a customs bond?
A: Not always. Many informal Type 11 entries under roughly $2,500 can proceed without one, but formal Type 01 entries, regulated goods, quota merchandise, and in-bond movements generally require a single transaction or continuous bond.
Q: Is ocean freight a better option than air or postal for low-value goods now?
A: For many sellers, yes. Consolidating volume into FCL or LCL ocean shipments cleared through fewer, well-prepared formal entries is often more predictable and cost-effective per unit than filing large numbers of individual small-parcel entries by air or mail.
В: Чем компания Topway Shipping может помочь в этом переходе?
A: Topway Shipping manages first-leg transportation, overseas warehousing, customs clearance, and last-mile delivery as one connected chain, and also arranges FCL and LCL ocean freight from China to major global ports, so sellers do not have to assemble bonding, classification, and clearance capability on their own.
