Nonpostal de minimis suspension enters regulations
CBP codified the indefinite suspension for nonpostal merchandise valued at $800 or less, requiring formal or informal entry procedures. Budget for duty and clearance when shipping apparel directly by express carrier.
Our read
Ordinary apparel parcels sent direct by express each need a formal or informal entry, with brokerage fees on top of duty; on one-item parcels that fixed cost weighs heavily. Our view: it is worth costing bulk shipments to a US warehouse instead, remembering that the bulk import still has to be entered and pay duty.
Key dates
- Published; Takes effect
- Comment deadline for this interim final rule
- We checked the official text
Who is affected
- Sellers importing ordinary commercial goods valued at $800 or less by express, air or ocean need an appropriate formal or informal entry.
- Sellers replenishing a US warehouse should assess the bulk import as one shipment; subsequent domestic deliveries are not separate duty-free imports.
- International mail falls under a separate concurrent rule. This rule does not remove the distinct exemptions for qualifying bona fide gifts and accompanying personal or household articles.
Run the numbers
| Component | Calculation | Amount |
|---|---|---|
| General duty | $20 × 16.5% | $3.30 |
| Additional duties | 7.5% China Section 301 + 12.5% new Section 301 = 20% | $4.00 |
| Total duty | $20 × 36.5% | $7.30 |
What to do
- Ask the carrier which entry type it files in CBP’s Automated Commercial Environment (ACE), who is responsible and how charges are assessed.
- Provide the actual product description, material, origin and customs value; the former $800 threshold is not a zero-duty rate.
- When comparing direct shipment with bulk replenishment, include import duty on the bulk shipment, storage and US domestic delivery.
What the official text says
This indefinite suspension means that all entries of merchandise valued at $800 or less arriving through all modes other than the international postal network must utilize formal or informal entry procedures.
This rulemaking does not affect the availability of the exemptions for bona fide gifts under 19 U.S.C. 1321(a)(2)(A) or personal or household articles accompanying travelers under 19 U.S.C. 1321(a)(2)(B).