De Minimis Suspension: Costs and Entry Options for Small Importers
Chen Cui Co-Founder of GingerControl What changed: Corrected postal dates and formal-versus-informal entry costs; removed universal duty, ISF, bond and brokerage claims, the unsourced 80% decline and automatic 100% fines.
Global suspension began August 29, 2025 under Executive Order 14324, after the earlier China/Hong Kong suspension. On June 24, 2026 CBP's interim rules indefinitely suspended the exemption for both non-postal and postal shipments. The postal rule's new informal-entry procedure took effect July 24; October 22 is the compliance date for specified mail provisions, not a new suspension date.
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In this post
Review the U.S. de minimis suspension with the applicable postal or other entry rules before assuming a low-value parcel receives duty-free treatment.
For specified mail shipments at the end of that compliance window, the rule describes formal entry or participation in the optional Entry Type 13 test as alternatives. Do not tell every postal customer that formal entry is the only permitted route. Confirm the current test and participation conditions with the filer.
Does every parcel now owe duty or require formal entry?
No. Losing de minimis treatment means duties must be determined under the applicable tariff and entry rules. A free MFN rate or valid exemption can still produce zero duty; other layers may produce positive duty. Formal versus informal treatment depends on goods, value, restrictions and mode, not merely loss of Section 321.
Check destination de minimis rules separately from the base tariff rate, using the destination and applicable dates.
For non-postal goods, 19 CFR 143.21 generally permits eligible shipments up to $2,500, with exceptions and a current $250 limit for the specified Chapter 99 subchapters. CBP's October 8 proposal to remove that lower limit was a proposal, not an enacted change as of October 12. Postal entry has separate rules and the Type 13 alternative noted above.
What are the actual FY2027 processing fees?
Do not use the formal-entry minimum in every parcel estimate. Effective October 1, 2026, the CBP fee notice provides these MPF amounts where the fee applies:
| Entry processing | FY2027 MPF |
|---|---|
| Automated informal, not prepared by CBP | $2.77 |
| Manual informal, not prepared by CBP | $8.30 |
| Manual informal, prepared by CBP | $12.45 |
| Formal | 0.3464% of value; $34.58 minimum, $670.86 maximum |
Applicable fee exemptions must be checked separately. Carrier clearance, brokerage and other commercial charges are quoted charges, not a uniform statutory $15, $25 per parcel. Ocean-specific filing obligations and port fees should not be applied indiscriminately to air or postal parcels. Bond requirements also depend on the entry procedure; the postal informal process has a specific bond requirement.
How can a small importer compare direct parcels with consolidation?
Separate three ledgers: statutory duty, government processing fees and supplier/carrier charges. For each route record goods and units, entry method, duty assumptions, MPF treatment, freight, clearance quote, inventory and domestic fulfillment cost. Then compare total route cost ÷ units delivered, keeping the same delivery service and returns assumptions.
Use Incoterms and importer cost responsibilities to assign freight, risk and clearance responsibilities before comparing supplier quotes.
For an assumed 100-unit order, $200 of route-specific fixed cost contributes $2 per unit; $500 contributes $5. These are illustrative costs, not market brokerage rates or a prediction that consolidation always saves money. Consolidation can also change storage, delivery time and who is importer of record, so evaluate those differences before selecting it. See landed-cost comparison.
If higher per-unit import cost is passed into retail prices, use household tariff-cost analysis as macroeconomic context while keeping the merchant’s own cost calculation separate.
How should a merchant prepare product data?
Collect descriptions, materials, function, origin evidence and truthful customs values before shipment. Ask the carrier or customs representative for the data and clearance route it requires; do not copy a postal six-digit label requirement into a claim that a US entry never needs a more precise tariff classification. Errors can create delays, duty corrections or enforcement exposure, but there is no automatic universal 100% fine for every HS mistake.
Which GingerControl tools fit small importers?
Use GingerLite's Classification Researcher for one product case and GRI reasoning, then save the chosen classification in Parts Library. The Tariff Calculator calculates the US duty layers for the entry date; it is not a global checkout or carrier clearance service. GingerLite is $150 a month for 300 credits, with top-ups if needed. The free MPF/HMF calculator helps compare fee assumptions. Checkout DDP integration belongs with an appropriate checkout provider, and commercial carrier charges still come from the carrier.
Frequently Asked Questions
Does a $40 commercial parcel still get the $800 shortcut?
No. The global suspension removed that de minimis assumption. Determine actual duty and an allowed entry procedure from classification, origin, value and mode.
Is every parcel now charged positive duty?
No. A free tariff rate or applicable exemption can still produce zero duty. Losing de minimis requires the normal tariff analysis, not an automatic positive rate.
Must every small shipment pay the $34.58 formal MPF minimum?
No. Where applicable, automated informal entry not prepared by CBP has $2.77 MPF in FY2027. Confirm entry eligibility and any fee exemption first.
Can every non-postal shipment under $2,500 use informal entry?
No. Exceptions apply, including the current $250 limit for specified Chapter 99 subchapters. The October 8 proposal to remove that limit was not yet implemented as of October 12.
Did postal de minimis suspension start July 24, 2026?
No. The rule suspended postal treatment June 24. July 24 began the new postal informal procedure; October 22 is the compliance date for specified provisions.
Does October 22 make formal entry the only postal choice?
No. For specified eligible shipments, the rule describes formal entry or the optional Entry Type 13 test. Confirm conditions with the filer.
Do air and postal parcels all need ocean ISF and the same bond?
No. Filing and bond requirements depend on mode and entry procedure. The postal informal process has its own bond requirement; ocean obligations should not be generalized to all parcels.
Does GingerLite replace carrier clearance or global checkout DDP?
No. It supports classification and the US duty analysis. Obtain commercial clearance charges from the carrier and use an appropriate provider for checkout DDP.
References
- Executive Order 14324, global de minimis suspension
Source: Executive Order 14324, global de minimis suspension
Checked: 2026-10-12 - CBP, 91 FR 37789, de minimis suspension
Source: CBP, 91 FR 37789, de minimis suspension
Checked: 2026-10-12 - CBP, 91 FR 37801, mail informal entry and de minimis suspension
Source: CBP, 91 FR 37801, mail informal entry and de minimis suspension
Checked: 2026-10-12 - CBP Dec. 26-14, FY2027 customs user fees
Source: CBP Dec. 26-14, FY2027 customs user fees
Checked: 2026-10-12 - 19 CFR 143.21, merchandise eligible for informal entry
Source: 19 CFR 143.21, merchandise eligible for informal entry
Checked: 2026-10-12
New to importing, or new to the compliance seat?
Hand this to GingerOS.
Pick a 30-minute slot on the next page with Chen Cui, our CEO. Bring one notice or one SKU list (an ERP export, a spreadsheet or an email will do) and see what GingerOS does with it.
Reviewed by Michael Weick, LCB / CCS
