Trade & Customs Oct 10, 2026 · 8 min read

CBP proposes to rebuild low-value and postal entry

CBP wants low-value entries filed by the day goods land. US Customs proposed on 8 October that informal entries, meaning shipments worth $2,500 or less, be filed electronically on or before arrival day instead of within 15 days. The rule covers about 70.1 million commercial and 32.7 million postal shipments a year, according to the Federal Register notice. Mail gets its own entry type. Both types need a bond. Our view: customs work for cheap parcels now has to happen at origin. CBP prices a brokered mail entry at $39.72, and 79% of mail parcels are worth $30 or less. We expect a final rule before de minimis legally ends on 1 July 2027.

CBP proposes arrival-day filing and a new mail entry for every shipment under $2,500
On 8 October 2026, US Customs and Border Protection (CBP) published a proposed rule that would change how the US clears low-value goods. Informal entries, meaning shipments worth $2,500 or less, would have to be filed electronically on or before the day the goods arrive. Today, filers have up to 15 days after landing. The rule would reach about 70.1 million commercial informal shipments and 32.7 million postal shipments a year, according to CBP’s estimate in the Federal Register notice. Comments are due by 7 December 2026 under docket USCBP-2026-0298.

What CBP actually proposed

The rule has four main parts, according to the Federal Register notice.
First, Type 11 entries change. Type 11 is the standard informal entry used by express carriers and brokers for low-value goods. Under the proposal, it must be filed electronically, by the date of importation, and it must name a “final deliver-to party” with an address when that party differs from the consignee.
Second, mail gets its own electronic entry. The notice says CBP wants “to establish a new electronic informal entry type for merchandise entering through the mail environment”. This is Type 13, the Informal Mail Entry. It requires the identity and address of the shipper or sender. Carriers would have to report the Universal Postal Union S-10 tracking number, the standard international postal barcode, on the inward manifest. That is the cargo list carriers send CBP before arrival. The number must match the one on the Type 13 filing. Mail not properly entered within 15 days of importation would be treated as voluntarily abandoned.
Third, bonds. Type 11 and Type 13 filers would need a basic importation and entry bond, either for a single shipment or continuous. A bond is a surety’s guarantee that duties and penalties get paid. CBP proposes a minimum of $1,000 in liquidated damages, the set penalty claimed against the bond, for each breach of a listed bond condition, or the value of the goods if higher.
Fourth, who can file. A consignee that is not the owner or purchaser of the goods would have to appoint a licensed customs broker to act as importer of record. CBP would also get wider power to require formal entry on a blanket basis, for example by importer, manufacturer or product category.
There is one loosening. Goods classified under Chapter 99, Subchapters III and IV of the tariff schedule are capped at $250 for informal entry today. Chapter 99 is where the extra tariffs sit, including Section 232 duties, the national-security tariffs on goods such as steel. The proposal removes that $250 cap, so those goods could be entered informally up to $2,500.

Our view: the clock is the real change

We think the headline item is not the new entry type or the bonds. It is the deadline. Moving filing from “within 15 days after landing” to “by arrival” changes where the work gets done. The data now has to be complete before the goods land. For most cross-border e-commerce, that means at origin, often in China, and often by people who are not brokers today.
CBP’s own numbers show how much this touches. In a sample of Type 11 entries cited in the notice, 26.6% were filed on the day of arrival and 25.0% the day after. That second group, a quarter of the total, would miss the new deadline by a single day. CBP says it cannot put a number on the cost of the earlier deadline, but concedes those costs “could be significant”. It notes some filers may need staff overseas. It also says the effect on transit times could go either way. Goods could sit in origin warehouses longer while data is gathered, or be released faster because CBP already has what it needs. Seatrade Maritime News reported that CBP is asking for comment on exactly this point.
Our second view: this rule ends postal as a cheap back door. CBP estimates the full cost of a brokered Type 13 entry at $39.72, according to the notice. That is a $30 broker fee, based on an academic estimate of express brokerage fees, plus about $9.72 of time spent on two CBP forms. Meanwhile, mail parcels worth $30 or less made up 79% of postal shipments by volume but only 16% by value between September 2025 and May 2026. For most mail parcels, clearing the goods would cost more than the goods themselves. CBP assumes every Type 13 importer or sender will hire a broker. The notice says the party that hires the broker pays the fees, though the other party may end up carrying some of that cost.

Why CBP says it needs this

CBP’s case rests on enforcement. In FY2024, it seized narcotics in postal de minimis shipments at a rate of 277.8 seizures per million shipments, according to the notice. For formally entered shipments the rate was 2.6 per million. CBP also says it receives “much less information” to target postal informal shipments than Type 11 shipments. The notice ties electronic filing directly to targeting, seizures and catching illicit drugs such as fentanyl. Seatrade reported CBP’s position that the changes are needed to protect revenue and identify trade-law violators as well.
The price tag is large. CBP puts the net cost of the rule over 2026 to 2035 at about $9.30 billion at a 3% discount rate, or $7.72 billion at 7%. Its analysis assumes the rule takes effect in 2027. Seatrade reported CBP’s estimate that the tracking-number requirement alone will cost carriers $18.7 million in 2027. The US Postal Service expects $12 million to $20 million in initial programming. It says that work will take 4 to 6 months at the low end and up to 8 months at the high end.

How we got here

This is the third big move on low-value entry in under two years, and each has gone further than the last.
In January 2025, CBP proposed narrowing de minimis rather than ending it, according to a BDO summary. That proposal would have barred goods under Section 301, 201 and 232 tariffs from duty-free de minimis entry and asked for more data, such as seller and buyer details. Comments closed on 17 March 2025.
Policy then overtook the rulemaking. The One Big Beautiful Bill Act, signed 4 July 2025, ended the exemption in law from 1 July 2027. Executive Order 14324, signed 30 July 2025, went faster and suspended duty-free de minimis treatment for all countries from 29 August 2025. Executive Order 14388 in February 2026 kept the suspension going and put a 10% duty on postal shipments. On 24 June 2026, CBP issued two interim final rules that wrote the suspension into its regulations, all according to the new notice.
A temporary postal process followed. From 24 July 2026, mail worth $2,500 or less went through an email-and-spreadsheet entry process with monthly payment, according to Forvis Mazars. Under it, only owners, purchasers or licensed brokers may file, according to law firm Troutman Pepper Locke. Foreign postal operators, which could file under the earlier stopgap, lost that role. A voluntary Type 13 test began on 22 September 2026. From 22 October, goods subject to extra Chapter 99 duties, trade-agreement claims or other agencies’ rules drop out of that simplified process.
The lesson from last time is that this area moves faster than the formal calendar suggests. The January 2025 proposal was overtaken by executive action within months. This time the statute sets a hard date, and CBP has already built and tested most of the machinery.

What it means for forwarders, shippers and lanes

For forwarders and brokers, the main shift is that data must arrive before the goods do. Product descriptions, tariff codes, values, sender details and the final delivery address have to come from sellers before departure, not be chased after arrival. That favours brokers with origin-side operations or tight system links to marketplaces and consolidators.
Forwarders and carriers acting as consignee should check their position. If you are the consignee of record but not the owner or purchaser, you would have to appoint a licensed broker as importer of record. Seatrade noted this explicitly for ocean carriers, which have handled consolidated mail using wider bill of lading data.
Bonds become standard for low-value flows. With a $1,000 minimum penalty per breach, a high-volume parcel filer could build up large claims quickly. Sureties will price that in.
For shippers, the blanket formal-entry power is the risk to watch. If CBP can push a whole importer, manufacturer or product category into formal entry, a marketplace seller with a poor record could lose access to informal entry across its whole catalogue.
There is upside for some industrial shippers. Low-value spare parts and samples under Chapter 99 tariffs, now capped at $250 for informal entry, could go informal up to $2,500.
On lanes, the hit lands hardest on China-to-US e-commerce, especially small parcels sent by mail. CBP’s data already shows the trend. Postal de minimis entries fell at an annual rate of 11.63% from FY2021 to FY2024 while Type 11 entries grew 3.14% a year, according to the notice. We expect this rule to push more volume out of the mail and into express and consolidated Type 11 flows, where brokers and data already exist.

Our call

We expect CBP to publish a final rule by June 2027, timed for the 1 July 2027 legal end of de minimis. We think the arrival-day filing deadline survives in the final text, possibly with a short phase-in, because CBP’s enforcement case depends on having data before release. And we expect postal informal volume in the first full year under the rule to come in well below CBP’s estimate of 32.7 million shipments, as low-value mail moves to Type 11 or stops altogether.

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