Executive Summary On October 8, 2026, CBP published a notice of proposed rulemaking (NPRM), “Low-Value Shipments” (91 FR 64532; document 2026-20650; docket USCBP-2026-0298; RIN 1685-AA38), proposing to amend 19 CFR parts 113, 128, 141, 143, and 145. It concerns informal entries, the simplified entry process for goods valued at $2,500 or less, and would replace the current postal informal entry process with a new Entry Type 13 (informal mail entry). As proposed, the rule would require electronic Entry Type 11 filings upon or before the date of importation (instead of within 15 days after arrival); require the final deliver-to party where it differs from the ultimate consignee; require a consignee that is not the owner or purchaser to appoint a licensed customs broker as importer of record; require every Type 11 and Type 13 filer to hold a basic importation and entry bond; set a $1,000 minimum for liquidated damages on a bond default; add a shipper/sender data element and a mail tracking number on the carrier’s inward manifest for Type 13; treat unentered low-value mail as voluntarily abandoned after 15 days; and allow certain Chapter 99 goods valued from $250 to $2,500 to use informal entry. CBP designates the rule economically significant and estimates a present value of net costs of about $9.3 billion over 2026–2035 (3% discount rate), while stating that it expects security and enforcement benefits it did not quantify. Comments are due December 7, 2026. This is a proposal: it is not in force, and the notice sets no effective date. This analysis summarizes the proposed changes, CBP’s stated reasons and estimates, and considerations for the parties that handle low-value shipments, based on the text of the notice.
CBP’s Low-Value Shipments Proposal: What Would Change for Informal Entries and International Mail
(CBP低价值货物拟议规则：非正式报关和国际邮件将发生哪些变化)
1 · Background and CBP’s Stated Reasons
Informal Entry
Informal entry procedures are authorized by 19 U.S.C. 1498(a)(1)(A) for shipments valued at $2,500 or less, and are found mainly in 19 CFR part 143, subpart C (with mail procedures in part 145). The proposal keeps the $2,500 limit. Entry Type 11 is the general informal entry type, and the notice states that the requirements for Type 11 would also apply to the rarely used Type 12.
The De Minimis Context
According to the notice, the de minimis exemption has been suspended since at least August 29, 2025 (Executive Order 14324). Executive Order 14388 (February 20, 2026) continued the suspension and imposed a 10 percent ad valorem duty on postal shipments under Section 122. On June 24, 2026, CBP published two interim final rules making the suspension indefinite (91 FR 37789 for non-postal modes and 91 FR 37801 for postal), and the One Big Beautiful Bill Act terminated the exemption by statute effective July 1, 2027. CBP states that it expects low-value shipment volumes to remain high as goods formerly eligible for de minimis shift to informal entry procedures such as Type 11.
CBP’s Stated Concerns
| Concern | CBP’s explanation in the notice |
|---|---|
| Filing timing | Under 19 CFR 141.5, entry may be made within 15 calendar days after landing, which CBP says does not give it enough time for risk assessment and targeting before high-volume, low-value shipments arrive |
| Postal data | Under the current postal informal entry process, the monthly international mail duty (IMD) worksheet is due on the 7th day of the following month, most postal entries are released automatically before it is submitted, and it contains less data than CBP Forms 3461 and 7501; CBP says most worksheets are submitted by a broker who does not have to identify the importer or consignee |
| Compliance gap | CBP reports that, from September 2025 to May 2026, only about 67 percent of postal shipments were sent through an informal or formal entry process, and says the remainder were likely shipped without payment of duties |
| Seizure rates | CBP reports FY 2024 narcotics seizure rates per million shipments of 277.8 for postal de minimis shipments, 15.8 for Type 11 informal entries, and 2.6 for formal entries |
| Bonding | CBP states that, currently, bonding for informal entries is required only in certain situations |
CBP states that it developed Entry Type 13 for postal informal shipments and that an Entry Type 13 test (announced in 91 FR 38007) was set to begin on September 22, 2026, to allow it to evaluate ACE functionality while the rulemaking is pending.
⚠️ Critical Takeaway: The proposal does not change the $2,500 informal entry limit. It would change when informal entries are filed, who is on the entry, what data is supplied, and what bond stands behind it. CBP’s stated aims are targeting, revenue protection, and closing the gap between postal and non-postal entries.
2 · The Proposed Changes
Nine Core Changes
| # | Proposed Change | Detail (per the notice) |
|---|---|---|
| 1 | Electronic Type 11, filed upon or before importation | Informal entries of goods valued at $2,500 or less would have to be filed electronically as Entry Type 11 (the electronic equivalents of CBP Forms 3461 and 7501, or CBP Form 7501) upon or prior to the date of importation, rather than within 15 days after arrival (proposed 19 CFR 141.5(b) and 143.23) |
| 2 | Broker as importer of record for non-owner consignees | A consignee intending to enter goods valued at $2,500 or less that is not an owner or purchaser, such as a foreign postal operator, the U.S. Postal Service, a freight forwarder, or a carrier, would have to appoint a licensed customs broker who acts as the importer of record, unless the exception in 19 CFR 143.26(b) applies (proposed 143.26(a)) |
| 3 | New Entry Type 13 (informal mail entry) | A new electronic entry type for goods valued at $2,500 or less sent by mail that would be eligible for Entry Type 11 if shipped by other means, replacing the current process under 19 CFR 145.12(b); filed on the electronic equivalents of CBP Forms 3461 and 7501 rather than the IMD worksheet |
| 4 | Shipper/sender data for Type 13 | A required data element: the identity and address of the party causing the goods to be shipped, filed by the importer of record or broker |
| 5 | Mail tracking number on the manifest | The tracking number (the Universal Postal Union S-10 number assigned by the foreign postal operator) must be provided by the party filing the inward manifest for each mail article, under new 19 CFR 145.7, covering vessel, air, rail, truck, and express consignment manifests |
| 6 | Unentered mail deemed abandoned | Mail valued at $2,500 or less for which entry is not timely and properly filed would not be released and would be deemed voluntarily abandoned 15 days after the date of importation, with disposition by USPS under its requirements, which may include destruction or return to the sender (new 19 CFR 145.6) |
| 7 | Bond for all Type 11 and Type 13 filers | All Type 11 and Type 13 filers must obtain a basic importation and entry bond, a single transaction bond or a continuous bond with the conditions in 19 CFR 113.62, secured by an approved corporate surety or cash deposit (§ 113.40); shipments would not be released without it (proposed 143.29 and 145.15) |
| 8 | Liquidated damages minimum | On breach of a bond condition for Type 11 or Type 13 (other than listed conditions), liquidated damages would be the greater of the merchandise value or $1,000; for restricted or prohibited merchandise or alcoholic beverages, the greater of three times the value or $1,000 (proposed 113.62(n)(6)) |
| 9 | Chapter 99 goods and informal entry | The $250 limit on informal entry for goods under Subchapters III and IV of Chapter 99, HTSUS (such as goods subject to Section 232 duties) would be removed, so such goods valued up to $2,500 could be informally entered (proposed 141.82(d), 143.21, 143.23) |
Additional Provisions in the Notice
| Provision | Detail |
|---|---|
| Final deliver-to party (Type 11 and Type 13) | A new data element identifying the final deliver-to party and address, required only if distinct from the ultimate consignee on the entry summary |
| Formal entry discretion (proposed 143.22) | CBP could require formal entry for any merchandise or category of merchandise, any importer, or merchandise produced by a specific manufacturer or producer, and for any period, including on a blanket basis, not only case by case |
| IMD worksheet | The current informal postal entry process, including the monthly IMD worksheet, would be terminated if the rule is finalized |
| Bona fide gifts | CBP states there is no change to the procedures for entering bona fide gifts (new 19 CFR 128.24(f)); the requirements for shipments exempt from duty under 19 U.S.C. 1321(a)(2)(A)–(B) remain as in 19 CFR 143.26(b) |
| Time of entry for mail | Proposed 19 CFR 141.68(f) addresses the time of entry for informal mail entries |
⚠️ Critical Takeaway: Beyond the nine core changes, the notice adds a final deliver-to party data element and a broader CBP discretion to require formal entry, so the proposal reaches further than the headline list.
3 · CBP’s Analysis: Costs, Benefits, and Alternatives
The notice includes a regulatory impact analysis. The figures below are CBP’s estimates, stated by CBP to rest on assumptions and data limitations, and CBP requests comment on several of them.
Headline Estimates
| Item | CBP’s Estimate |
|---|---|
| Designation | Economically significant regulatory action; reviewed by OMB |
| Present value of net cost, 2026–2035 | About $9.3 billion (3% discount rate) or $7.7 billion (7%) |
| Annualized net impact | About −$1.09 billion per year |
| First-year private sector cost | More than $1 billion (primarily importers and senders: time burdens, broker fees for postal entries, and the new Type 11 bond) |
| Revenue transfer | Higher duty collection on postal shipments, estimated at about $58.6 million per year at full compliance (a transfer, not counted in net costs) |
| Quantified benefits | None; CBP expects improved targeting, interdiction of illicit goods, and trade compliance, but did not quantify them |
Selected Underlying Data Points Stated by CBP
| Topic | Data in the notice |
|---|---|
| Type 11 filing timing | In a random sample of 392,473 Type 11 entries (September to November 2025), only 0.4% were filed before the day of arrival, 26.6% on the day of arrival, and 25.0% the day after |
| Paper filing | 73,534 of 52,450,418 Type 11 entries (0.14%) were filed manually from September 2025 to May 2026 |
| Bondless Type 11 entries | About 2.3 million Type 11 entries (about 3.3% of projected 2026 entries) were entered without a bond between August 2025 and July 2026; CBP estimates the added premiums at about $9.3 million over that period |
| Volumes | From September 2025 to May 2026, CBP counts about 24.4 million postal entries (of which about 16.4 million, or 67%, went through an informal or formal entry process, per CBP) and about 52.5 million Type 11 entries |
| Broker fee assumption | CBP assumes brokers would charge about $30 more per Type 13 entry than for the monthly IMD worksheet |
| USPS costs | USPS estimates initial programming costs of $12 to $20 million; CBP does not quantify USPS storage and return costs |
Unquantified Costs CBP Identifies
CBP states that it cannot quantify, and that some could be significant: the cost of the earlier filing deadline (for example, filers that currently read package labels after arrival may need to obtain data before departure, possibly with overseas staff), brokers’ system changes, USPS storage and return costs for abandoned mail, and deadweight loss from reduced imports. CBP also notes the possibility of shipment delays if shippers hold goods until entry data is ready.
Small Entities
In its initial regulatory flexibility analysis, CBP states that it cannot certify that the rule would not have a significant economic impact on a substantial number of small entities, citing small importers that would need single transaction bonds, filers of the postal IMD worksheet, and non-postal informal entry filers affected by the earlier deadline.
Alternatives CBP Describes
| Alternative | CBP’s Description |
|---|---|
| Less strict | Keep the 15-day filing deadline while adopting the other changes: less costly for filers, but CBP would not have entry data at arrival for screening |
| Stricter | Require entry 24 hours before arrival or before the shipment leaves the country of origin: more time for CBP analysis, but greater cost and uncertainty for filers |
⚠️ Critical Takeaway: CBP’s analysis projects large costs and unquantified benefits, and the notice asks for comment on several of its assumptions, particularly the earlier filing deadline, shipping times, electronic submission, and the cost of returning undeliverable mail.
4 · Who Would Be Affected
| Party | Proposed Changes Most Relevant |
|---|---|
| Importers and e-commerce sellers shipping low-value goods | Electronic filing before or on importation (1); final deliver-to party; bond (7, 8); Chapter 99 goods (9) |
| Carriers | Mail tracking number on the inward manifest (5) |
| Foreign postal operators, the U.S. Postal Service, freight forwarders | Appointing a licensed customs broker as importer of record when the consignee is not the owner or purchaser (2); abandonment of unentered mail (6) |
| Licensed customs brokers | Acting as importer of record for non-owner consignees (2); bond and filing requirements for Type 11 and Type 13 filings (1, 3, 7) |
| Senders of mail to the United States | Shipper/sender identity and address (4) |
5 · Process and Timeline
| Item | Status |
|---|---|
| Published | October 8, 2026 (91 FR 64532; document 2026-20650) |
| Comments | Due December 7, 2026, through the Federal eRulemaking Portal under docket USCBP-2026-0298 |
| Effective date | None set in the notice; CBP’s cost analysis assumes the rule would take effect in 2027, and a final rule would state its own effective and compliance dates |
| Legal status | Proposed rule, not in force; nothing in it applies to entries until a final rule takes effect |
| Severability | CBP states it generally intends the provisions to be severable and expects to say more in the final rule |
6 · Considerations for the Parties Involved
The following considerations are informational and not prescriptive; they apply only if a final rule adopts the proposal in similar form.
| Area | Commonly Raised Consideration |
|---|---|
| Timing of data | Whether the data for an informal entry (value, description, classification, consignee, shipper, final deliver-to party) is available before the goods arrive, since filing would move to on or before importation |
| Bonding | Whether a continuous bond or single transaction bonds suit the filer’s volume; CBP’s own data suggest the choice differs sharply between high-volume and infrequent importers |
| Who is the importer of record | For shipments handled by postal operators, forwarders, or carriers, how the consignee, owner or purchaser, and broker relationships would be structured, and whether the exception in 19 CFR 143.26(b) applies |
| Mail and manifests | How tracking numbers and sender data would be captured and transmitted by carriers, postal partners, and filers |
| Unentered mail | The consequences of the 15-day abandonment provision for senders and consignees, including destruction or return |
| Chapter 99 goods | How the proposed change for goods over $250 would interact with additional tariffs and with the choice between informal and formal entry, and CBP’s proposed discretion to require formal entry |
| Other rules in motion | How the proposal interacts with the de minimis suspension and with CBP’s interim final rule on importers of record (91 FR 69977), which also covers informal entries requiring CBP Form 3461 or 7501 |
| Comments | Whether to submit comments, and on which provisions or assumptions, by December 7, 2026 |
⚠️ Critical Takeaway: Several of the proposed changes affect the same shipments in different ways: timing, bonding, who files, and what tariffs apply. Looking at them together may clarify the operational picture.
7 · Conclusion: A Proposal at the Comment Stage
CBP’s Low-Value Shipments proposal would move informal entries to an earlier, electronic, bonded process, replace the postal informal entry process with a dedicated mail entry type, and clarify who is the importer of record for non-owner consignees. It would also remove the $250 limit for certain Chapter 99 goods and add a final deliver-to party data element. CBP projects substantial costs and expects unquantified enforcement benefits. It is a proposal: CBP will review comments received by December 7, 2026 before deciding whether and how to finalize it.
Key Takeaways
| Factor | Detail |
|---|---|
| Proposal | “Low-Value Shipments,” NPRM, 91 FR 64532 (Oct. 8, 2026); document 2026-20650; docket USCBP-2026-0298; RIN 1685-AA38 |
| Regulations Affected | 19 CFR parts 113, 128, 141, 143, and 145 |
| Comments Due | December 7, 2026 |
| Status | Proposed rule; not in force; no effective date set |
| Informal Entry Limit | Unchanged at $2,500 |
| Type 11 | Electronic, filed upon or before importation; final deliver-to party if distinct from the ultimate consignee |
| Type 13 (new) | Informal mail entry replacing the current postal process and IMD worksheet; electronic; shipper/sender identity and address required |
| Manifest | Mail tracking number provided by the inward manifest filer |
| Unentered Mail | Not released; deemed voluntarily abandoned after 15 days; USPS disposition (may include destruction or return) |
| Bond | Basic importation and entry bond (single transaction or continuous; corporate surety or cash deposit) for all Type 11 and Type 13 filers |
| Liquidated Damages | Greater of value or $1,000 (greater of three times value or $1,000 for restricted/prohibited goods and alcohol) |
| Broker as IOR | Required for non-owner consignees (e.g., postal operators, USPS, forwarders, carriers), subject to 143.26(b) |
| Chapter 99 | Goods over $250 up to $2,500 would be allowed to use informal entry; CBP could require formal entry on a blanket basis |
| CBP’s Net Cost Estimate | About $9.3 billion present value, 2026–2035 (3%); benefits not quantified |
The Bottom Line
The proposal addresses informal entries from several angles at once, and its effect would depend on the final text. Importers, carriers, postal partners, and brokers that handle low-value shipments can compare their current processes against the proposed changes and decide whether to comment. Organizations that would like an outside perspective may find it worthwhile to work with a trade compliance partner familiar with CBP’s informal entry and bonding requirements.
The message is clear: CBP has proposed electronic, bonded, earlier-filed informal entries and a new mail entry type, projects substantial costs, and has set December 7, 2026 as the deadline for comments.
This analysis reflects CBP’s notice of proposed rulemaking, “Low-Value Shipments,” 91 FR 64532 (October 8, 2026), document 2026-20650, docket USCBP-2026-0298 (comments through the Federal eRulemaking Portal, regulations.gov), CBP’s interim final rules on the de minimis exemption (June 24, 2026), and CBP’s interim final rule Heightened Requirements for Foreign Importers of Record (91 FR 69977). Cost, benefit, and volume figures are CBP’s own estimates as stated in the notice. The proposal is not in force; its provisions are summarized and subject to the text of the notice and any final rule. Organizations should consult with customs counsel and trade compliance professionals for guidance tailored to their specific circumstances.
