Executive Summary
U.S. Customs and Border Protection has issued two interim final rules revising how low-value shipments are handled across every mode of entry, extending the indefinite suspension of the Section 321 de minimis exemption to shipments moving through the international postal network as well as all other entry modes. Beyond simply eliminating duty-free treatment, CBP has established a new interim process specifically for informal mail entries valued at $2,500 or less, complete with specific documentation requirements, bonding obligations, and eligibility restrictions for who may act as filer. Two requirements in particular deserve immediate attention: filers must submit an Excel spreadsheet by email containing the data elements CBP requires, rather than transmitting through ACE as with standard entries, and only owners, purchasers, or licensed customs brokers hold the right to make entry under this process—freight forwarders and other unlicensed intermediaries do not qualify. Separately, CBP plans to launch a voluntary test of a new electronic informal entry type for qualifying international mail shipments later this year. This analysis examines what these changes mean in practical terms for customs brokers and importers handling low-value shipments, with particular focus on the operational requirements filers must now satisfy.

CBP’s Low-Value Import Overhaul: Understanding the New Entry Requirements for Brokers and Importers

(CBP低价值进口新规解读：报关行与进口商需要了解的要求)

1 · The Regulatory Context: Why These Changes Are Happening Now

Extending an Existing Suspension

An executive order issued earlier this year continued the suspension of the Section 321 de minimis exemption—the longstanding provision allowing duty-free treatment for imports of articles valued at $800 or less, imported by one person on one day. This suspension was first implemented in 2025, and the current executive order extends it further.

A Notable Legal Detail: while the executive order provides the policy backdrop, CBP has cited its own independent statutory authority under 19 U.S.C. § 1321 to amend the exemption through formal rulemaking. This matters because it means CBP’s rules rest on a distinct legal foundation from the executive order itself, giving the agency direct regulatory authority to shape how the suspension actually operates in practice—rather than simply implementing executive branch policy through informal guidance.

Two Separate Rules Covering Every Entry Mode

CBP has issued two interim final rules working in tandem to close what might otherwise have been gaps in coverage:

The first rule addresses shipments entering via the international postal network specifically, with an effective date of July 24. Notably, compliance with some provisions of this rule is not required until October 22, giving affected parties a several-month runway to adjust operations before full enforcement begins.

The second rule addresses low-value shipments entering through any other mode—covering express carriers, freight forwarders, and other non-postal channels—and took effect earlier, on June 24.

Why Two Rules Matter: CBP’s stated goal is to “ensure that all low-value shipments are subject to consistent enforcement across every mode of entry.” Historically, postal shipments and express/commercial shipments have often been treated somewhat differently in practice, even under the same nominal legal framework, given the very different operational realities of how mail versus commercial freight moves through the system. By issuing separate but coordinated rules, CBP appears to be closing any potential arbitrage opportunity where shippers might favor one mode over another specifically to exploit inconsistent enforcement.

The Comment Period: public comments on both rules are due by July 24, meaning affected parties still have a formal opportunity to raise operational concerns or request clarifications before the rules are potentially finalized in different form.

2 · The New Interim Process for Low-Value Mail Entries

A Specific Pathway for Shipments Valued at $2,500 or Less

Beyond simply ending de minimis duty-free treatment, the mail-specific rule establishes an entirely new interim process for informal mail entries valued at $2,500 or less—including shipments that would previously have qualified for de minimis treatment under the old $800 threshold. This is a critical detail: CBP is not simply forcing all low-value mail shipments into the standard formal entry process. Instead, it has created an intermediate, informal entry pathway specifically calibrated for this segment of trade, presumably in recognition of the sheer volume of mail shipments that previously moved through de minimis channels and would otherwise overwhelm formal entry processing capacity.

The Documentation Mechanism: A Mandatory Excel Spreadsheet Submission

⚠️ Filers must understand this requirement before attempting to use the interim process. Data cannot be transmitted through ACE or the Automated Broker Interface as with standard entries. Instead, CBP requires filers to email a properly formatted Excel spreadsheet containing the specified data elements for each qualifying shipment. Entries submitted without this spreadsheet, or with an incomplete or improperly formatted one, will not be processed under this pathway.

The specific mechanics of this interim process are worth understanding in detail, since they differ meaningfully from standard electronic entry filing. Under this process, filers must email CBP an Excel spreadsheet containing information specified in the rule, rather than transmitting data through the Automated Broker Interface or ACE in the manner used for standard formal or informal entries.

Why This Matters Operationally: this spreadsheet-based approach represents a distinctly manual, interim solution rather than a fully automated one. For customs brokers and importers accustomed to electronic data transmission through ACE, this represents a notable departure from standard practice—and likely reflects the reality that CBP needed to stand up some workable mechanism quickly, before a more automated solution could be built and tested. Brokers and filers handling volume in this category should anticipate the administrative burden of preparing and submitting properly formatted spreadsheets for each qualifying shipment or batch of shipments, at least during this interim period.

Who May Act as Filer: A Critical Eligibility Gate

⚠️ Not every party handling low-value shipments can use this pathway. CBP has explicitly limited eligibility to parties holding the right to make entry—owners or purchasers of the goods, or designated and licensed customs brokers acting on their behalf. Organizations that do not meet this definition cannot file under the interim process, regardless of shipment value or volume.

This interim process is not open to just anyone. CBP has explicitly limited eligibility to parties with the right to make entry—specifically defined as owners or purchasers of the goods, or designated and licensed customs brokers acting on their behalf.

The Practical Implication: this eligibility restriction mirrors the general legal framework governing who may make customs entry under normal circumstances, meaning CBP has not relaxed the underlying party-eligibility requirements simply because the shipment value is low. Freight forwarders, consolidators, or other intermediaries who are not licensed customs brokers and are not themselves the owner or purchaser of the goods would not qualify to file under this interim process. This is an important distinction for any logistics providers currently handling low-value shipment consolidation who may need to reassess their operational role under the new framework.

The Bonding Requirement

Filers using this interim process must maintain a basic importation and entry bond sufficient to secure the entries being filed. This is a meaningful operational requirement: it means that even for shipments falling below the relatively modest $2,500 threshold, the filer cannot simply file entries without financial backing. The bond requirement serves CBP’s broader risk-management function, ensuring that duties, taxes, and potential penalties associated with these entries remain collectible even in cases of filer default or noncompliance.

What This Means for Smaller Operators: parties handling low-value mail shipments who do not already maintain an appropriate customs bond will need to secure one before they can participate in this interim filing process. This represents a new compliance cost and administrative step for entities that may previously have relied on de minimis treatment specifically because it eliminated the need for formal bonding on these shipments.

Categories of Shipments Excluded from This Interim Process

Not every low-value shipment qualifies for this streamlined interim pathway. CBP has carved out several categories that must instead go through the full formal entry process regardless of value:

• Shipments subject to quotas
• Shipments subject to antidumping or countervailing duties
• Shipments subject to duties imposed under HTSUS Chapters 98 and 99
• Shipments subject to import and entry-related Partner Government Agency requirements
• Shipments for which duty-free treatment is claimed under HTSUS Chapter 98 or under a free trade agreement

Why These Exclusions Exist: each of these categories involves either heightened revenue risk (AD/CVD duties can exceed several hundred percent of declared value), regulatory complexity requiring PGA coordination that the simplified spreadsheet process cannot accommodate, or preferential treatment claims that require more substantive documentation to verify eligibility. Brokers and importers should carefully screen shipments against these exclusion categories before assuming the interim informal process is available, since incorrectly routing an excluded shipment through the informal pathway would itself constitute a compliance failure.

3 · Looking Ahead: The Electronic Entry Type 13 Test Program

A More Automated Alternative on the Horizon

Recognizing that the spreadsheet-based interim process represents a manual stopgap rather than a long-term solution, CBP has announced its intention to begin, on September 22, a test of a new electronic informal entry type 13 specifically for international mail shipments valued at $2,500 or less.

What This Test Will Provide: according to CBP, this test will offer an alternative to the Excel-based interim process described above, allowing genuine informal entry processing within ACE for qualified international mail shipments. This represents a meaningful step toward automation, moving low-value mail entries into the same electronic infrastructure used for other customs transactions rather than requiring manual email submissions.

Expanded Coverage for PGA-Regulated and Specially-Dutied Shipments

Notably, this test program will also temporarily create an informal entry pathway for low-value international mail shipments that are subject to PGA data requirements, or subject to duties other than those found in HTSUS Chapters 1-97. This is a meaningful expansion relative to the interim spreadsheet process, which does not accommodate PGA-regulated shipments at all. If this test program functions as intended, it could provide a viable informal entry route for a broader range of low-value mail shipments than currently possible under the interim process—though the specific scope and limitations of PGA coverage under the test will need to be monitored closely as details emerge.

What Remains Excluded Even Under the Test: shipments subject to AD/CVD duties or quotas will remain ineligible for this test program and must still be entered under formal entry procedures. This consistency with the interim process’s exclusions suggests CBP views AD/CVD and quota-related revenue risk as warranting formal entry treatment regardless of which informal mechanism is otherwise available for other low-value shipments.

A Voluntary Test of Indefinite Duration

Two structural features of this test program are worth noting for planning purposes. First, participation is voluntary—filers are not required to use the new electronic entry type and may continue relying on the interim spreadsheet process (or formal entry, where applicable) if they choose not to participate in the test. Second, the test will run for an indefinite period, meaning there is no announced end date after which the test necessarily concludes or converts to a permanent program.

The Longer-Term Direction

CBP has stated that it plans to eventually replace the interim spreadsheet-based process with a fully automated process. The Entry Type 13 test appears to represent exactly this evolution in progress. CBP has explained that the purpose of the voluntary test is to allow the agency to evaluate the capabilities of the new entry type and determine whether it effectively addresses the risks and complexities present in the international mail environment—particularly given the substantial volume of mail that was formerly eligible for de minimis treatment and now requires some form of active customs processing.

The Practical Signal for Filers: brokers and importers currently building compliance processes around the interim spreadsheet method should treat that approach as a genuinely temporary solution rather than a long-term operational foundation. Organizations investing in low-value mail entry capabilities may benefit from monitoring the Entry Type 13 test closely and considering early participation once it launches, both to gain operational familiarity ahead of an eventual mandatory transition and to provide CBP with practical feedback while the test program’s parameters remain flexible.

4 · Practical Considerations for Customs Brokers and Importers

Reassessing Eligibility to File

Given that only owners, purchasers, or licensed customs brokers may file under the interim informal mail process, any organization handling low-value shipment volume should confirm its own eligibility status under this framework. Freight forwarders and other intermediaries lacking broker licensure or ownership/purchaser status in the underlying transaction should evaluate whether they need to restructure relationships—potentially routing filing responsibility through a licensed broker partner—to maintain the ability to process these shipments.

Building Spreadsheet Submission Capacity

Since the interim process depends on email submission of properly formatted Excel spreadsheets rather than automated ACE transmission, organizations should ensure they have clear internal processes for compiling the required data fields accurately and consistently, minimizing errors that could delay processing or trigger compliance issues. This is not an optional refinement—without a working spreadsheet submission process in place, a filer cannot use the interim pathway at all. That said, given this is explicitly framed as an interim, manual mechanism, organizations should avoid over-investing in permanent infrastructure built specifically around the spreadsheet format, since it is likely to be superseded by the Entry Type 13 process or its eventual automated successor.

Confirming Bond Adequacy

Organizations that previously relied heavily on de minimis treatment, and therefore may not have maintained bonds sized for this volume of low-value entries, should assess whether their existing basic importation and entry bond is sufficient to secure their anticipated entry volume under the new interim process. Given that bond adequacy is a stated prerequisite for participation, insufficient bonding could create operational bottlenecks precisely when shipment volume through this channel is highest.

Screening for Exclusion Categories

Before routing any shipment through the interim informal process, filers should systematically screen for the exclusion categories—quota-subject goods, AD/CVD-subject goods, HTSUS Chapter 98/99 duties, PGA-regulated goods, and FTA or Chapter 98 duty-free claims. Given the complexity of AD/CVD scope determinations in particular, organizations may benefit from building a screening checklist or automated flag system to catch these exclusions before attempting to file through the simplified pathway.

Monitoring the Comment Period and Test Program Timeline

With comments on both interim final rules due by July 24, organizations with significant low-value shipment volume may wish to consider submitting comments identifying operational challenges they anticipate under the new framework, since interim final rules can still be modified in response to substantive public comment. Separately, organizations should track CBP announcements regarding the September 22 Entry Type 13 test launch closely, given the potential operational advantages of transitioning to a more automated process once it becomes available.

5 · Conclusion: Navigating a Transitional Period in Low-Value Import Processing

A Deliberately Layered Approach

CBP’s handling of low-value import entries reflects a deliberately layered, transitional regulatory approach rather than a single definitive solution. The suspension of de minimis treatment across all entry modes establishes the baseline policy shift, the interim spreadsheet-based process provides an immediate—if manual—operational pathway for the large volume of shipments previously eligible for duty-free treatment, and the upcoming Entry Type 13 test signals CBP’s intended direction toward a more automated, ACE-integrated long-term solution.

What This Means for the Trade Community

For customs brokers and importers, this layered approach means genuine near-term operational adjustment is required—confirming filing eligibility, securing adequate bonding, and building capacity for manual spreadsheet submission—while also requiring attention to what comes next, since the interim process is explicitly not intended as a permanent fixture. Organizations that treat the current framework as fully settled risk being caught flat-footed when the Entry Type 13 test, or its eventual successor, begins reshaping how low-value mail entries are actually processed.

Staying Prepared

Given the pace and layered nature of these changes, customs brokers and importers handling meaningful volumes of low-value shipments—whether through the international postal network or other modes—are well served by maintaining close, ongoing attention to CBP announcements in this area, rather than treating the current interim rules as a fixed endpoint. The stated goal of consistent enforcement across every entry mode suggests CBP intends continued refinement of these procedures as it gathers operational experience and test program data over the coming months. Above all, organizations should treat filer eligibility and the Excel spreadsheet submission requirement as gating conditions rather than administrative afterthoughts: without confirming the right to make entry and establishing a reliable spreadsheet submission process, participation in the interim pathway simply is not possible.

This analysis reflects CBP’s interim final rules on low-value import entry procedures as issued in 2026. Specific compliance deadlines, eligibility criteria, and program details are subject to the official rule text and any subsequent CBP guidance or rule modifications following the public comment period. Organizations managing low-value import entries should consult with customs brokers and trade compliance professionals for guidance tailored to their specific operations and circumstances.