Trade & Customs Oct 15, 2026 · 7 min read

CBP wants low-value entries filed before the goods land

CBP wants low-value entries filed before arrival. Almost nobody does that today. US Customs and Border Protection (CBP) has proposed that informal entries (goods worth $2,500 or less) be filed on or before the day goods arrive, not within 15 days after. In CBP’s own sample of 392,473 entries, only 0.4% were filed before the day of arrival. In our view, this is the biggest workflow change for express and e-commerce brokers since de minimis was suspended in August 2025. Data capture has to move to origin. Our call: comments due 7 December will be dominated by requests for a phase-in, and nothing takes effect before mid-2027.

CBP’s low-value rule moves customs work to origin, and its own data shows how far filers have to travel
US Customs and Border Protection (CBP) wants low-value entries filed before the goods arrive. Its own sample shows only 0.4% are filed that early today.
The proposed rule was published in the Federal Register on 8 October 2026 (91 FR 64532, docket USCBP-2026-0298). It would make informal entries due “upon or prior to the date of importation”. An informal entry is the simpler customs filing used for goods worth $2,500 or less. Most are filed electronically as “entry type 11”. Today the deadline is 15 calendar days after the goods land. Supply Chain Dive covered the proposal on 14 October. Comments are due on 7 December 2026.
Our view is simple. This rule takes the low-value customs job out of the US arrival hub and puts it at origin. For express operators, e-commerce consolidators and the brokers who file for them, that is a change in how the work is done, not a paperwork tweak.

What CBP’s own numbers show

CBP took a random sample of 392,473 type 11 entries filed from September to November 2025. It measured the gap between arrival and filing. The rule text says: “Only 0.4% of entries were filed before the day of arrival.” A further 26.6% were filed on the day of arrival, and 25.0% the day after. By those figures, the remaining 48% were filed two or more days after arrival.
CBP puts a positive spin on this. It says “just over half of ET11 entries need to be submitted only a day or two earlier to conform with the earlier deadline.” That is true. It also means that, on CBP’s figures, nearly every filer has to change something, and about half have to change a lot.
The volumes are large. CBP counted 52,450,418 type 11 entries and 24,427,685 postal entries between 1 September 2025 and 31 May 2026. It projects about 70.1 million type 11 entries a year.
CBP’s reason is security and targeting. The rule says the 15-day window “does not provide CBP with sufficient time to properly conduct risk assessment and targeting before the arrival” of dangerous or unlawful shipments.

What else is in the proposal

The deadline is the headline, but the rule does several other things that matter to forwarders. All of these come from the Federal Register notice.

A new data field. Type 11 filers must report the final deliver-to party when it differs from the ultimate consignee. This targets parcels routed through fulfilment addresses.

A new mail entry. Entry type 13 would be a permanent electronic entry for international mail. It adds shipper or sender details and the postal tracking number. Carriers must put the tracking number on the inward manifest, the list of cargo a carrier files with CBP before arrival.

Abandonment. Mail not properly entered would be treated as “voluntarily abandoned at the expiration of a 15-day period.” Supply Chain Dive notes this compares with the Postal Service’s current 30-day holding period.

Bonds. Type 11 and type 13 filers would need a basic importation bond. A bond is a guarantee from a surety that duties and penalties will be paid. The rule proposes “a new minimum amount of $1,000 for each breach of a listed bond condition.” CBP’s analysis finds that “about 2.3 million ET11 entries were entered without a bond” from August 2025 to July 2026.

Brokers as importer of record. A consignee who is not the owner or purchaser would need a licensed customs broker to act as importer of record (IOR), the party legally responsible for the entry.

Blanket formal entry. CBP “may require formal entry on a blanket basis, e.g., based on importer of record, manufacturer, or category of merchandise.” That lets CBP push whole product lines or sellers into full formal entry.

A loosening. The rule removes the $250 limit on informal entry for goods under Chapter 99, Subchapters III and IV. Those are the tariff chapters that carry extra duties such as Section 232. Goods worth $251 to $2,500 in those chapters could use informal entry again.

The cost CBP will not count

CBP is candid that this costs money. It says the rule “would result in stricter duty collection for postal entries and higher shipping costs for both ET11 and ET13 entries”. On the earlier deadline it writes: “While CBP is unable to quantify these costs, it acknowledges that they could be significant”. It also says filers may need more staff overseas to review shipments before departure.
On shipping times, CBP hedges: “The rule would have an ambiguous effect on shipping times.” Shippers might hold goods abroad while data is prepared. Or earlier filing might speed release.
Where CBP does put numbers down, they are per parcel. It assumes brokers charge about $30 more per postal shipment, citing an express-carrier brokerage fee estimate. It adds about $9.72 of filer time, for a total of $39.72 per type 13 entry. CBP also found that, from September 2025 to May 2026, postal shipments worth $30 or less were 79% of postal shipments by count but only 16% by value. A $30 fee on a $30 parcel is the point. We think a lot of that mail simply stops, or moves to express.
The Postal Service faces its own bill. CBP reports that USPS put its systems work at $12 million to $20 million and up to eight months. The bigger problem is space. The rule notes that “USPS Office of Exchanges were designed for flow-through processing, without warehousing capacity”. It adds: “USPS anticipates that it would need an initial warehouse capacity equivalent to 80% or more of the import volume under the rule.”

What happened last time

There is a recent test case for what happens when the US tightens low-value rules quickly. The de minimis exemption, which let goods worth $800 or less enter duty-free, was suspended for all countries from 29 August 2025. The Universal Postal Union (UPU), the UN agency for international mail, reported on 6 September 2025 that “postal traffic to the country dipped more than 80%”. It also said “88 postal operators informed the UPU they have suspended some or all postal services to the US.”
The lesson, in our view, is that low-value flows do not adjust slowly. They stop, then look for another route. CBP’s own analysis expects some importers to shift from postal shipments to type 11. This rule tightens that type 11 path too, so there is less room to reroute.
The rule also builds on steps already taken. CBP issued interim postal rules on 24 June 2026. A test of entry type 13 in CBP’s ACE system was set to start on 22 September 2026, according to CBP’s Cargo Systems Messaging Service notice 69289734, issued on 20 July. Under the One Big Beautiful Bill Act, the de minimis exemption ends by law on 1 July 2027.

What this means for forwarders and shippers

Our read for the people moving the freight:

Express and e-commerce consolidators carry the most risk. If they sort, classify and value parcels after landing, that work must move before departure. That means seller data feeds, origin staff, or both.

Customs brokers gain work but also exposure. More entries need a licensed broker as importer of record, and every type 11 and type 13 entry needs a bond. A $1,000 floor per breach adds up quickly across thousands of small parcels.

Sellers shipping by post face fees that can exceed the value of the goods, holds, and a 15-day abandonment clock. Expect more of them to move to express or to bulk shipments cleared before arrival.

Low-value Section 232 goods, such as small steel or aluminium parts, get some relief. Removing the $250 cap lets them use informal entry up to $2,500.

Air e-commerce lanes into US gateways will feel it first, in our view. Pre-arrival clearance favours operators who already have clean data at origin.

The blanket formal entry power is the sleeper. If CBP uses it on whole categories or marketplaces, low-value importers could be pushed into full formal entries with no warning beyond a notice.

Our prediction

We expect the 7 December comment deadline to draw heavy pushback from express carriers, broker groups and USPS. The main ask will be a phase-in of at least six months for the earlier type 11 deadline.
Our call: CBP will not finalise the rule before the first quarter of 2027. When it does, the earlier type 11 deadline will take effect no earlier than 1 July 2027, lined up with the statutory end of de minimis. Forwarders who handle low-value US imports should use the next six weeks to map how many of their own entries are filed on or after the day of arrival. On CBP’s sample, the answer is likely to be nearly all of them.

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