De Minimis & Low-Value Shipments

Why this matters

What is confirmed

What is reported not confirmed

What may change

What compliance teams should do now

Review status

Adjacent

First U.S. de minimis measure

February 2025

Published negotiating text

None located

Treaty text

U.S. statute

U.S. regulations and rulemaking

Executive instruments

Confirmed

In a national media release titled “International Mail Entry Type 13 mandatory implementation date extended to Jan. 20, 2027,” CBP “announces the extension of the compliance date for new informal entry procedures … from Oct. 22, 2026, to Jan. 20, 2027.” CBP says “The 90-day extension provides importers, brokers, and logistics providers additional time to update their processes” and that “There are no changes to international mail entry procedures before Jan. 20, 2027.” From January 20, 2027, international postal shipments subject to Section 201, 232 or 301 duties or under Partner Government Agency jurisdiction must be filed electronically in the Automated Commercial Environment through the new Entry Type 13 process to qualify for informal entry; otherwise formal entry is required. CBP encourages filers to use the optional Entry Type 13 process during this transition period. The release links the June 24, 2026 interim final rule (2026-12669) and the October 8 Low-Value Shipments NPRM. The June 24 rule itself set the October 22, 2026 compliance date for 19 CFR 145.12(a)(2)(v)–(vi) (PGA-regulated goods; Chapter 98/99 duties; Chapter 98 or FTA duty-free claims). The release does not mention the USMCA. ICPA analysis, not stated in the source: as of October 18, 2026 ICPA has located no Federal Register notice or CSMS message amending the 19 CFR 145.12 compliance date, so the release is the only official text for the new date that ICPA has located; members who were preparing for October 22 can use the extra time to test Entry Type 13 filing, and should watch for a Federal Register document conforming the regulation.

Source: CBP national media release, International Mail Entry Type 13 mandatory implementation date extended to Jan. 20, 2027, Oct 14 ↗ (Tier 1)

Confirmed

CBP published a notice of proposed rulemaking, Low-Value Shipments (91 FR 64532, FR Doc. 2026-20650, docket USCBP-2026-0298, RIN 1685-AA38), amending 19 CFR parts 113, 128, 141, 143 and 145 for goods valued at $2,500 or less. On the Entry Type 11 deadline: “CBP is setting the deadline to make entry for informal entry type 11 to be upon or prior to the date of importation.” That replaces the current 15 calendar days after landing, and filing would be electronic. The proposal would replace the current informal postal entry process with a fully electronic Entry Type 13 (Informal Mail Entry) that carries the shipper’s identity and the UPU S-10 tracking number. All entry type 11 and entry type 13 filers would have to obtain a basic importation and entry bond subject to the conditions of 19 CFR 113.62, with a proposed $1,000 minimum liquidated-damages amount for each breach of a listed bond condition on informal entries of $2,500 or less (proposed 19 CFR 113.62(n)(6)). Carriers would report the mail tracking number on the inward manifest, mail in CBP custody 15 days after importation would be deemed voluntarily abandoned, and a consignee that is not the owner or purchaser would have to appoint a licensed broker as importer of record. The proposal also removes references to the $250 limit on informal-entry eligibility for goods classified under Chapter 99, Subchapters III and IV, HTSUS, so such goods valued over $250 up to $2,500 could use informal entry; the rule’s example is goods subject to Section 232 duties. CBP estimates about $30 in added broker fees per postal entry and cites the July 1, 2027 statutory termination of de minimis as background. No effective date is proposed; CBP’s regulatory analysis assumes the rule would take effect in 2027. Comments are due December 7, 2026. The proposal does not mention Canada, Mexico or the USMCA. ICPA analysis, not stated in the source: the proposal changes nothing for filers until CBP issues a final rule, but members filing Entry Type 11 or using the postal channel should review the bond and filing-deadline proposals and decide whether to comment before December 7.

Source: Federal Register, 91 FR 64532, FR Doc. 2026-20650, Oct 8 ↗ (Tier 1)

Confirmed

CSMS # 70137892 (October 7, 2026) reminded the trade of the post-deployment support call that day at 1:00 p.m. ET on the ACE enhancements implementing the Entry Type 13 test for international mail (INT-057 and CBP-290), with questions about the ACE enhancement directed to CREM@cbp.dhs.gov or ESAR@cbp.dhs.gov and technical questions to the ACE Account Service Desk. CBP reposted the INT-057/CBP-290 Trade Information Notice on cbp.gov on October 8, 2026 (attachment 26_1008_trade_information_notice_INT-057.pdf, marked Last Updated: September 24, 2026), replacing the September 3 version quoted in the September 22 entry above. The revised notice reads: “The Foreign Postal Operator Tracking Number SE15 must be included, otherwise ACE will send an error.” It drops the shipper/sender name (SE30) and address (SE35) from the data elements ACE will reject an ET13 entry without, leaving only SE15, and adds the PGA Flag Enforcement Table and the ACE CATAIR Stand-alone Filing for Prior Notice Data (PE/PX) chapter to the implementation guides being updated. ICPA analysis, not stated in the source: the notice does not say whether the name and address are still expected on the entry; it only changes what triggers an ACE error.

Source: CBP CSMS # 70137892, Oct 7 ↗ (Tier 1)

Confirmed

USTR announced a public consultation ahead of the 2027 annual joint review of the USMCA under section 611 of the USMCA Implementation Act (19 U.S.C. 4611). The Federal Register notice (FR Doc. 2026-20341) was filed for public inspection October 2 and published in the Federal Register on October 5, 2026 (91 FR 63379). Written comments (Docket USTR-2026-0595) and requests to appear at a public hearing (Docket USTR-2026-0596) go through comments.ustr.gov: “To be assured of consideration, USTR must receive written comments by 11:59 p.m. EST on January 12, 2027.” Hearing date and location will be posted on ustr.gov, and post-hearing rebuttal comments are due seven calendar days after the hearing closes. USTR invites comment on any aspect of the operation or implementation of the USMCA, compliance issues, specific actions USTR should propose ahead of the joint review, the North American investment climate, and economic security and competitiveness. Neither the press release nor the notice mentions de minimis or Article 7.8. ICPA analysis, not stated in the source: because the notice invites comment on any aspect of the operation or implementation of the USMCA, docket USTR-2026-0595 is the formal channel for members who want low-value shipment thresholds (Article 7.8) raised in the joint review.

Sources: USTR, USTR Seeks Public Comment on the 2027 Joint Review of USMCA, Oct 2 ↗ (Tier 1); Federal Register, 91 FR 63379, FR Doc. 2026-20341, Oct 5 ↗ (Tier 1)

Confirmed

CBP’s inflation adjustment of COBRA customs user fees for Fiscal Year 2027 (91 FR 48398, FR Doc. 2026-15530, published July 31, 2026), made under the FAST Act and 19 CFR 24.22(k), states: “The adjusted amounts of customs COBRA user fees and their corresponding limitations set forth in this notice for Fiscal Year 2027 are required as of October 1, 2026.” The dutiable mail fee is $7.61. The informal entry or release merchandise processing fee is $2.77 (automated, not prepared by CBP), $8.30 (manual, not prepared by CBP) and $12.45 (prepared by CBP). The express consignment carrier and centralized hub facility fee is $1.38 per individual waybill or bill of lading. The ad valorem MPF minimum and maximum move to $34.58 and $670.86, with the rate unchanged at 0.3464 percent. The notice does not mention de minimis. ICPA analysis, not stated in the source: with de minimis treatment suspended, the dutiable mail fee and informal-entry MPF now apply to low-value postal and courier shipments that previously entered without them; members should update landed-cost models and broker fee schedules accordingly.

Source: Federal Register, FR Doc. 2026-15530, Jul 31 ↗ (Tier 1)

Confirmed

A companion 30-day PRA notice (FR Doc. 2026-20171, OMB 1651-0022) revises the Entry Summary collection to account for the Entry Type 13 Informal Mail Entry test, listed at 10 respondents and 166,667 annual burden hours, alongside electronic formal entry summaries (2,336 respondents; 1,920,073 hours) and electronic informal entry summaries (1,883 respondents; 403,538 hours). The notice restates the test’s required data set, including filer code, importer of record number, merchandise description, country of origin, 10-digit HTSUS classification, value and duty. On participation: “The test is open to owners and purchasers of merchandise being mailed to the United States and licensed customs brokers properly appointed by the owner, purchaser, or consignee of the merchandise being mailed to the United States, who will act as the importer of record (IOR) for the entry.” Carriers transporting mail to the United States transmit the postal tracking number as part of their manifest filing. Comments are due November 2, 2026; the collection was previously published at 91 FR 40016 on July 1, 2026 for a 60-day comment period. ICPA analysis, not stated in the source: together with FR Doc. 2026-20170, these two notices are the first PRA burden estimates CBP has published for the Entry Type 13 mail-entry process that now handles postal shipments previously eligible for de minimis treatment.

Source: Federal Register, FR Doc. 2026-20171, Oct 1 ↗ (Tier 1)

Confirmed

In a 30-day Paperwork Reduction Act notice (FR Doc. 2026-20170, OMB 1651-0024), CBP revised the Entry collection covering CBP Forms 3461 and 3461 ALT: “CBP is announcing a voluntary test for a new electronic informal entry process for mail in ACE through the development of new informal entry type 13--Informal Mail Entry.” The test covers mail shipments valued at $2,500 or less, and CBP estimates 10 respondents, 2,000,000 annual responses and 166,667 burden hours for it. The same revision expands the Global Business Identifier supply-chain party types to add Intermediary and Source parties, identified by LEI, GLN or DUNS, and adds data elements supporting the sanctions in E.O. 14114. Comments to OMB are due November 2, 2026. The notice follows a 60-day PRA notice published July 1, 2026 (91 FR 40021) and is a 30-day submission to OMB. ICPA analysis, not stated in the source: a PRA revision does not itself alter filing requirements; it brings the OMB paperwork approval into line with data elements CBP already deployed under the Entry Type 13 test.

Source: Federal Register, FR Doc. 2026-20170, Oct 1 ↗ (Tier 1)

Confirmed

CSMS # 70076746: “U.S. Customs and Border Protection (CBP) implemented Entry Type 13 (ET13) testing through enhancements to the Automated Commercial Environment (ACE) on September 22, 2026. In support of this deployment, CBP moved the following ACE implementation guides from draft status to current sections on CBP.gov.” On the cargo release side, the ACE CATAIR Cargo Release chapter now sits under Chapters: Current Capabilities, and the PGA Flag Enforcement Table and the Stand-alone Filing for Prior Notice Data (PE/PX) document sit under PGA Message Set Documents. On the entry summary side, the Entry Summary Create/Update and Entry Summary Query chapters are now current and the Entry Summary Error Dictionary sits under Supporting Documents. The message lists CREM@cbp.dhs.gov and ESAR@cbp.dhs.gov as contacts, and directs technical questions to the filer’s assigned Client Representative. This is the go-live confirmation the September 22 entry above noted ICPA had not yet seen. ICPA analysis, not stated in the source: filers and software vendors building to Entry Type 13 should now work from the current chapters rather than the earlier draft versions.

Source: CBP CSMS # 70076746, Sep 30 ↗ (Tier 1)

Confirmed

CBP Trade User Information Notice INT-057/CBP-290 (Pub. 1009-1119, last updated September 3, 2026): “On September 22, 2026, U.S. Customs and Border Protection (CBP) will enhance the Automated Commercial Environment (ACE) to implement the new Entry Type 13 (ET 13) for processing international mail shipments, in accordance with the Federal Register Notices (FRN) published by CBP on June 24, 2026 (Test of the New Electronic Informal Entry Process for Mail and Indefinite Suspension of the De Minimis Exemption for Merchandise Arriving Through All Modes Other Than the International Postal Network).” The test is available for mail shipments valued at $2,500 or less that are not subject to quota or antidumping/countervailing duties, and may be filed only by the owner or purchaser or a designated licensed customs broker under 19 CFR 143.26(a). The Foreign Postal Operator Tracking Number (SE15) and the shipper or sender’s name (SE30) and address (SE35) must be included, otherwise ACE will send an error. (CBP has since reposted the notice with a revised list; see the October 7–8 entry below.) Additional required data elements include filer code, arrival port, carrier and flight number, country of origin, arrival date, tracking number, duty type, description of merchandise, 10-digit HTSUS and duty rate, quantity/weight (only if using a specific duty rate), value, duty rate and total duty owed. CBP will hold a post-deployment support call on October 7, 2026 at 1:00 p.m. ET. This is the ACE production deployment that the June 24 test notice and the September 4 condition-code message (see both entries above) pointed to. ICPA analysis, not stated in the source: the notice was issued ahead of the deployment and ICPA has not yet seen a CBP message confirming the September 22 go-live; members who elect to participate in the test will need to meet the listed data-element requirements.

Source: CBP Trade User Information Notice INT-057/CBP-290, Sep 3 ↗ (Tier 1)

Confirmed

FDA published a 60-day Paperwork Reduction Act notice (FR Doc. 2026-19281) proposing to renew the Prior Notice of Imported Food information collection, with comments due November 20, 2026. FDA estimates an increase of 7,629,528 burden hours and 1,721,959 responses and attributes the adjustment “to the overall growth in United States food importation, changes in de minimis exemptions, and the aforementioned new requirements for international mail shipments.” The notice restates the final rule at 90 FR 46046 (September 25, 2025): “The final rule amended Sec. 1.281(b)(10) (21 CFR 1.281(b)(10)) to require submitters of prior notice for articles of food arriving by international mail to provide the name of the mail service and the mail tracking number beginning October 1, 2026.” Prior notice must be submitted electronically through CBP’s ABI/ACE or FDA’s Prior Notice System Interface (PNSI). The September 21 notice is a comment request and imposes no requirement of its own; the October 1 requirement comes from the 2025 final rule. ICPA analysis, not stated in the source: the attribution suggests the end of de minimis is adding low-value food parcels to the prior-notice workload, and filers using ABI/ACE for Entry Type 13 mail entries containing food will also need to supply the mail service name and tracking number in prior notice from October 1, 2026.

Source: Federal Register, FR Doc. 2026-19281, Sep 21 ↗ (Tier 1)

Confirmed

CBSA Customs Notice 26-23 implements the United States Surtax Order (2026), introduced “in response to the U.S.’ imposition of Section 338 tariffs on goods imported into the U.S. from Canada.” “Effective September 8, 2026, certain goods imported into Canada and originating in the U.S. are subject to a surtax of either 15%, 25% or 50%” of the value for duty. The notice states the surtax applies to goods released and accounted for in the Courier Low Value Shipment (CLVS) Program, that “Surtax is applicable on shipments that fall under de minimis thresholds,” including postal imports that otherwise qualify for remission under the Postal Imports Remission Order, and that accounting “will follow the instructions outlined in Memorandum D16-1-1.” ICPA analysis, not stated in the source: read together, U.S.-origin goods classified under a tariff item in Schedule 1, 2 or 3 of the surtax order carry the surtax when they enter Canada by courier or mail, whatever the shipment value; members shipping into Canada should account for it on the Commercial Accounting Declaration.

Source: CBSA Customs Notice 26-23, Sep 7 ↗ (Tier 1)

Confirmed

CSMS # 69763204: “The Cargo Release Condition Codes documents have been posted to cbp.gov with the following changes pertaining to Entry Type 13. These changes are expected to be deployed to U.S. Customs and Border Protection (ACE) Production environment on September 22, 2026.” Error code 334 is added and error code 325 is removed for Entry Type 13, the voluntary electronic informal mail entry test announced in CBP’s June 24 interim final rule (see the June 24 entry above). ICPA analysis, not stated in the source: September 22 is also the date this page carries for the Entry Type 13 test opening, so the code changes land with the test itself; filers planning to use Entry Type 13 will want their ACE error handling to recognise code 334 and drop code 325 before the deployment. Technical questions go to your assigned Client Representative per the message.

Source: CBP CSMS # 69763204, Sep 4 ↗ (Tier 1)

A three-judge panel of the U.S. Court of International Trade ruled against Axle of Dearborn, Inc. (d/b/a Detroit Axle), holding that IEEPA authorized the President’s rescission of the de minimis exemption for low-value imports, including from China, Mexico and Canada. The panel distinguished the Supreme Court’s Learning Resources holding, reasoning that IEEPA permits rescinding a trade-related “privilege” even though it does not authorize imposing new tariffs, and rejected the APA arbitrary-and-capricious challenge to the implementing agency action. Nothing changes operationally: the suspension is already codified in CBP’s June 24, 2026 interim final rules and the statutory repeal remains set for July 1, 2027. The significance is that this closes off the principal litigation path that could have restored duty-free de minimis treatment before that repeal. Detroit Axle may appeal to the Federal Circuit.

Source: U.S. Court of International Trade, Slip Op. 26-94, Aug 13 ↗ (Tier 1)

July 24 is the single most consequential date on this page, and the four items are easy to conflate.

• The new postal informal entry process under 19 CFR part 145 took effect, replacing the interim carrier-collection process for international mail
• The comment period on both interim final rules closed
• The Section 122 surcharge expired by operation of law at 12:01 a.m. EDT at the end of its 150-day statutory limit, and with it the flat postal-item duty rate that E.O. 14388 had tied to it
• New Section 301 duties of 10 or 12.5 percent, announced by USTR on July 23 following forced-labor enforcement investigations covering 60 economies, took effect at the same moment. Canada and Mexico were placed in the 10 percent tier. These duties carry no statutory expiration and reach low-value shipments that no longer have de minimis cover

Net effect for a low-value importer: the temporary flat surcharge is gone, replaced by an open-ended Section 301 layer, and classification accuracy now determines duty rather than a single blanket percentage.

USTR listed the Mexico City round agenda as steel and aluminum and derivative products, automobiles, economic security, labor, agriculture, and electronic payment services. Customs administration and de minimis were not named. The July 23 joint statement from Ambassador Greer and Secretary Ebrard emphasized North American manufacturing, supply chains, and free-riding by non-parties, and directed a fourth round in Washington in September 2026. Canada is not party to this bilateral track. This is the principal evidence for classifying De Minimis as adjacent to, rather than a confirmed, Joint Review workstream.

The Free Trade Commission held the mandatory six-year joint review under Article 34.7. Ambassador Greer stated that the United States did not agree to renew the USMCA in its current form. Annual reviews under Article 34.7.4 now run until the parties agree to an extension or the agreement reaches its July 1, 2036 term. All existing rights and obligations, including Article 7.8, remain fully in force. Extension remains available at any time by written confirmation of the three heads of government.

CBP published three documents. The interim final rule at 91 FR 37789, CBP Dec. 26-12, amending 19 CFR part 10, indefinitely suspended the exemption for all modes other than the international postal network, effective immediately on June 24, 2026. The companion interim final rule at 91 FR 37801, CBP Dec. 26-13, amending 19 CFR part 145, suspended the exemption for mail and created the new postal informal entry process effective July 24, 2026. A general notice at 91 FR 38007 announced the voluntary Entry Type 13 electronic informal mail entry test. Comments on both rules were due July 24, 2026. The rules ground the suspension in 19 U.S.C. § 1321(a) on the reasoning that the administrative burden of the exemption now outweighs the duties forgone.

The IEEPA duties ceased to be collected and the 10 percent Section 122 surcharge took effect at 12:01 a.m. EST, applying to formerly de minimis shipments along with everything else. Goods qualifying for USMCA preferential treatment were reported to be exempt from the surcharge, which made origin documentation newly valuable on shipments that previously needed none. The Court of International Trade later held Proclamation 11012 invalid as contrary to law on May 7, 2026, and that ruling was stayed pending appeal at the Federal Circuit, leaving a refund question open for the surcharge window.

Three instruments issued the day of the decision. Executive Order 14389 (Ending Certain Tariff Actions) terminated the IEEPA duties while preserving the underlying national emergency declarations. Executive Order 14388 (Continuing the Suspension of Duty-Free De Minimis Treatment for All Countries), 91 FR 9433, expressly continued the de minimis suspension and tied the postal-item duty rate to the new surcharge. Proclamation 11012 imposed a temporary 10 percent import surcharge under Section 122 of the Trade Act of 1974. The pairing is the clearest available evidence that the administration treats the de minimis suspension as legally separable from the IEEPA tariffs.

In Learning Resources, Inc. v. Trump, No. 24-1287, consolidated with Trump v. V.O.S. Selections, Inc., No. 25-250, the Court held 6 to 3 that IEEPA does not authorize the President to impose tariffs. Chief Justice Roberts wrote the principal opinion; the portions applying the major questions doctrine were joined by only two other Justices and are a plurality rather than a majority holding. Refund questions were remanded to the lower courts. The decision did not address de minimis directly, and its application to a suspension of an administrative exemption remains unresolved. See Open Legal Issues.

CBP’s notice at 90 FR 42418 effectuated E.O. 14324, modified the Harmonized Tariff Schedule, and set out the interim postal process under which carriers or other qualified parties collect and remit duties on a periodic basis. Shipments already ineligible for the exemption, such as goods subject to antidumping or countervailing duties or quota, continued to require an appropriate entry type.

Executive Order 14324 suspended the duty-free de minimis exemption under 19 U.S.C. § 1321(a)(2)(C) for all covered products valued at US$800 or less regardless of country of origin, effective 12:01 a.m. EDT on August 29, 2025. Non-postal shipments must be entered in the Automated Commercial Environment by a party qualified to make entry, with applicable duties paid. The order set a separate duty rate for postal-network shipments and superseded section 2 of E.O. 14256 in part. Canada and Mexico were covered from this date forward.

Section 70531(b) of the One Big Beautiful Bill Act, H.R. 1 of the 119th Congress, repeals the commercial-shipment de minimis exception under 19 U.S.C. § 1321(a)(2)(C) effective July 1, 2027. The same section creates a civil penalty for entering merchandise under the exemption in violation of other customs law, effective August 3, 2025. This is the only de minimis measure grounded in an act of Congress rather than executive or regulatory action, and it is the reason the current suspension is best understood as a bridge rather than a reversible policy.

Following notification from the Secretary of Commerce that collection systems were in place, Executive Order 14256 removed duty-free de minimis treatment for low-value imports of Chinese and Hong Kong origin, effective May 2, 2025. Canadian and Mexican goods were not covered at this stage, but the order established the operational template later applied to all countries.

Canada filed a request for consultations under CUSMA Article 31.4 concerning the U.S. IEEPA duties on Canadian goods. Article 7.8.1(f) on express shipments is one of eight provisions cited, alongside Articles 2.4.1, 2.4.2, 2.7.1, 2.8.1, 2.8.3, 2.9, and 2.10.1. This is the only CUSMA proceeding in which the de minimis commitment has been formally invoked. See Disputes & Consultations.

Executive Orders 14193 (Canada), 14194 (Mexico), and 14195 (China) imposed additional duties under IEEPA and provided that duty-free de minimis treatment would remain available for covered articles only until the Secretary of Commerce notified the President that adequate systems were in place to process and collect the new duties. This is the first point at which de minimis eligibility for Canadian and Mexican goods became conditional, and it is the measure Canada later challenged under Article 7.8.1(f).

Sept. 22, 2026

The voluntary Entry Type 13 electronic informal mail entry test opens in the ACE production environment. Eligible filers are the owner, the purchaser, or a designated licensed customs broker. Open to mail shipments valued at US$2,500 or less. The test runs until CBP concludes it by Federal Register notice.

Oct. 1, 2026

Prior notice for articles of food arriving by international mail must include the name of the mail service and the mail tracking number, under 21 CFR 1.281(b)(10) as amended by FDA’s final rule at 90 FR 46046 (September 25, 2025). FDA restated the requirement in its September 21, 2026 prior notice renewal (FR Doc. 2026-19281).

Before year-end 2026

Fourth U.S.–Mexico bilateral negotiating round. Reported for Sept. 28–29, then reported on Sept. 23 as postponed to October. On Oct. 16 Secretary Ebrard told Mexican legislators the round is still to be set and must come before year-end. ICPA has located no announced date for the fourth U.S.–Mexico round as of Oct. 18, 2026. Watch for whether customs administration or trade facilitation appears on the agenda for the first time.

Dec. 7, 2026

Comments due on CBP’s Low-Value Shipments proposed rule (91 FR 64532, docket USCBP-2026-0298). The proposal would require all Entry Type 11 and Entry Type 13 filers to obtain a basic importation and entry bond, set the Entry Type 11 deadline at or before the date of importation, and replace the current informal postal entry process with a fully electronic Entry Type 13. No effective date is proposed.

Not yet dated

CBP response to comments on the two interim final rules, and publication of final rules. ICPA has located no announced date as of Oct. 18, 2026. Final rules could change entry mechanics, bond requirements, or the scope of the exclusions.

Jan. 12, 2027

Written comments (Docket USTR-2026-0595) and requests to appear at the public hearing (Docket USTR-2026-0596) on the 2027 USMCA joint review are due to USTR by 11:59 p.m. EST via comments.ustr.gov. The notice does not mention de minimis or Article 7.8, but invites comment on any aspect of the operation or implementation of the USMCA.

Jan. 20, 2027

Compliance date for the postal exclusions, moved from Oct. 22, 2026 by CBP’s October 14 release, which states “There are no changes to international mail entry procedures before Jan. 20, 2027.” The release describes the Jan. 20 requirement only for international postal shipments “subject to Section 201, 232 or 301 duties or the jurisdiction of a PGA.” Under the June 24 rule (19 CFR 145.12(a)(2)(v)–(vi)), merchandise subject to Partner Government Agency requirements, merchandise subject to Chapter 98 or Chapter 99 duties, and merchandise claiming Chapter 98 or free trade agreement duty-free treatment require formal entry, with Entry Type 13 as the alternative. ICPA analysis, not stated in the source: the release does not mention Chapter 98 or free trade agreement claims; ICPA reads its “no changes ... before Jan. 20, 2027” statement as moving the whole 145.12(a)(2)(v)–(vi) compliance date, so the free trade agreement exclusion is the one to read closely if you ship CUSMA-originating goods by mail. No Federal Register notice or CSMS message amending the 19 CFR 145.12 compliance date had been located as of Oct. 18, 2026.

July 1, 2027

Statutory repeal of the commercial de minimis exception under section 70531(b) of the One Big Beautiful Bill Act. After this date the exemption is unavailable for commercial shipments as a matter of statute, and restoring it would require congressional action. The personal and gift exceptions under 19 U.S.C. § 1321(a)(2)(A) and (B) are not repealed.

Article 7.8.1(f) commitment

US$800

Practice as of Jul 26, 2026

Article 7.8.1(f) commitment

US$117 duties / US$50 taxes

Practice as of Jul 26, 2026

Article 7.8.1(f) commitment

C$150 duties / C$40 taxes

Practice as of Jul 26, 2026

• Formal or informal entry filed in ACE by a party qualified to make entry
• 10-digit HTSUS classification, country of origin, value, and payment of the applicable duty on every shipment
• Section 321 release on manifest is no longer available for commercial goods
• CUSMA preference may be claimed where the good qualifies and documentation is present

• New postal informal entry under 19 CFR part 145, for mail valued at US$2,500 or less
• Filers must obtain a basic importation and entry bond (single transaction or continuous) with the conditions of 19 CFR 113.62
• Filers limited to the owner, the purchaser, or a designated licensed customs broker; consignees who are not owners or purchasers must use a broker as importer of record
• Monthly duty reporting and payment following CBP’s international mail duty worksheet process, due early in the month following arrival
• Excluded categories must use formal entry. For PGA-regulated shipments, goods subject to Chapter 98 or 99 duties, and Chapter 98 or FTA duty-free claims (19 CFR 145.12(a)(2)(v)–(vi)), the compliance date is now Jan. 20, 2027 (moved from Oct. 22, 2026: CBP’s Oct. 14 release says there are no changes to international mail entry procedures before Jan. 20, 2027, and names Section 201, 232 and 301 and PGA shipments; it does not mention Chapter 98 or FTA claims), after which formal entry or Entry Type 13 applies

Restoration of duty-free treatment for USMCA-originating low-value shipments

The U.S. suspension applies to all origins with no carve-out for USMCA-originating goods. Origin affects the duty rate owed, not whether an entry must be filed.

Canadian small and medium enterprises told Global Affairs Canada during the 2025 CUSMA consultations that they want either restored U.S. thresholds or new carve-outs for low-value shipments within North America. Global Affairs Canada published this as stakeholder input, not as a Canadian negotiating position.

Proponent: Canadian SME stakeholders, via GAC consultations

Legal mechanism required: Regulatory reversal before July 1, 2027, then legislation

Last verified: Jul 26, 2026

Negotiated reciprocal reduction under the existing Article 7.8 mechanism

Article 7.8 already permits the United States to apply a reciprocal threshold to Mexican and Canadian express shipments, capped at the other party’s own amount. The mechanism has not been used.

A settlement in which the United States applies a low reciprocal threshold rather than none, in exchange for Canadian and Mexican increases, would resolve the treaty question without an amendment. No party has proposed this publicly. It is included because it is the only path ICPA has identified that operates entirely within the existing text.

Proponent: Not attributed; ICPA analysis

Legal mechanism required: None beyond existing Article 7.8, plus domestic implementation

Last verified: Jul 26, 2026

North American trusted-shipper low-value data framework

Eligibility for simplified treatment turns on value, channel, and merchandise category. There is no trilateral trusted-shipper data framework.

Analysts have floated conditioning preferential low-value treatment on advance data, seller and marketplace identification, and forced-labor and counterfeit screening. The Entry Type 13 test is the closest existing analogue, but it is a domestic CBP program, not a trilateral framework. No proposed text located in government sources.

Proponent: Not formally attributed

Legal mechanism required: Free Trade Commission decision or treaty amendment

Last verified: Jul 26, 2026

Congressional restriction of executive tariff authorities

Section 122 has expired. Section 301, Section 232, and Section 338 remain available to the executive without prior congressional approval. The de minimis suspension itself now rests on 19 U.S.C. § 1321(a) and, from July 1, 2027, on the statutory repeal.

Trade press reports bills introduced in July 2026 that would repeal Section 122 and Section 338 and require congressional approval before use of Sections 201, 232, and 301. ICPA has not located the bill text or a Congress.gov record and is not naming a bill number or sponsor here. Relevance to this page is indirect: such legislation would affect the duty layers now applying to low-value shipments, not the de minimis repeal itself, which is already statutory.

Proponent: Reported congressional sponsors, not confirmed

Legal mechanism required: Legislation

Last verified: Jul 26, 2026, bill text not located

Canada v. United States: IEEPA import duties related to the flow of illicit drugs

Complaining party Canada; responding party United States; no third party

Articles 2.4.1, 2.4.2, 2.7.1, 2.8.1, 2.8.3, 2.9, 2.10.1, and 7.8.1(f)

The measures at issue

Status

ICPA analysis: what codification changed about the dispute posture

1. Scope of “under normal circumstances” in Article 7.8.1

Whether the qualifier permits an indefinite, countrywide suspension, or only temporary or targeted departures. Central to any treaty claim and entirely untested.

2. Substantive exemption or processing obligation

Whether Article 7.8 confers a duty exemption or primarily an obligation to provide simplified customs formalities. The answer determines whether requiring an entry with duty paid breaches the article or merely changes the procedure.

3. Effect of the reciprocity mechanism

Whether an express, bounded path to reduce the U.S. threshold implies that elimination was outside the parties’ contemplation. See Thresholds & Procedures for ICPA’s reading.

4. Authority basis after Learning Resources

E.O. 14388 continued the suspension in reliance on IEEPA the same day the Court held IEEPA does not authorize tariffs. On August 13, 2026 the Court of International Trade held in Detroit Axle (Slip Op. 26-94) that the rescission “is not tantamount to the imposition of tariffs because suspending the de minimis exemption imposes no new duties.” Detroit Axle may appeal to the Federal Circuit.

5. Whether the June 2026 rules cure any authority defect

The interim final rules ground the suspension independently in 19 U.S.C. § 1321(a). Whether that grounding stands on its own, or remains dependent on the executive orders it implements, is unresolved.

6. Administrative Procedure Act exposure

Both June rules issued as interim final rules effective on or shortly after publication, with comment afterward. Earlier de minimis actions drew APA challenges on this basis. Whether the good-cause justification holds has not been tested.

7. Reach of the Article 7.8.3 carve-out

Whether a shipment must itself contain restricted or controlled goods before the carve-out applies, or whether channel-level risk is enough to justify treating an entire category differently.

8. Availability of general and security exceptions

Whether a Chapter 32 exception can justify the measure in full, and what evidentiary showing a necessity test would require given that targeted controls were available.

9. Live status of Canada’s Article 7.8.1(f) claim

The measures challenged in the March 4, 2025 request were terminated in February 2026. Whether the claim survives, and whether it would need to be refiled against the June 2026 rules, is not addressed in any public statement located.

10. Postal versus non-postal differential treatment

The two channels have been governed by different instruments and different mechanics throughout. Whether that differential is itself relevant to an Article 7.8 analysis has not been examined in any published source located.

11. CUSMA preference availability by channel

Canadian trade-association guidance reports that goods in the postal stream cannot claim CUSMA preference under the current process while commercial courier shipments can. If accurate, that raises a preference-access question independent of de minimis. Verify against CBP guidance

12. Section 301 forced-labor duties on low-value shipments

The July 24, 2026 Section 301 duties reach shipments that would formerly have entered duty-free. The combination of no de minimis and an open-ended Section 301 layer is new, and the interaction has not been addressed in published guidance.

13. Stacking with Section 338 duties on Canadian goods

Whether the new Section 301 duties stack with the 50 percent Section 338 duties on listed Canadian goods in effect since Aug. 22, 2026 is reported as unaddressed in initial CBP guidance. Material to any low-value Canadian-origin lane. See the Agriculture and Automotive pages for the Section 338 annexes.

14. Refund exposure for the Section 122 window

The Court of International Trade held Proclamation 11012 invalid on May 7, 2026; the ruling was stayed and is on appeal at the Federal Circuit. If the surcharge is ultimately voided, entries from Feb. 24 to July 24, 2026, including formerly de minimis shipments, become refund candidates.

15. Effect of the July 1, 2027 statutory repeal on the treaty conflict

Whether the repeal moots the Article 7.8 question, because the United States will have no domestic exemption to extend, or entrenches it, because the treaty commitment remains on the books and would then be unmeetable without new legislation.

CBP: National media release – International Mail Entry Type 13 mandatory implementation date extended to Jan. 20, 2027 (October 14, 2026)

Federal Register (CBP): Low-Value Shipments, Notice of Proposed Rulemaking, 91 FR 64532, FR Doc. 2026-20650, Docket USCBP-2026-0298 (October 8, 2026)

CBP: CSMS # 70137892 – REMINDER: Post-Deployment Support Call for Implementation of Entry Type 13 Test in ACE for U.S. Mail Processing (INT-057) and Mail Entry Type 13 Test (CBP-290) (October 7, 2026)

Federal Register (USTR): USMCA joint review request for public comments and notice of public hearing, 91 FR 63379, FR Doc. 2026-20341 (October 5, 2026)

USTR: USTR Seeks Public Comment on the 2027 Joint Review of USMCA, Dockets USTR-2026-0595 and USTR-2026-0596 (October 2, 2026)

Federal Register (CBP): Agency Information Collection Activities; Revision; Entry, FR Doc. 2026-20170 (October 1, 2026)

Federal Register (CBP): Agency Information Collection Activities; Revision; Entry Summary, FR Doc. 2026-20171 (October 1, 2026)

CBP: CSMS # 70076746 – Implementation Guides for Entry Type 13 Test in ACE for U.S. Mail Processing (INT-057) and Mail Entry Type 13 Test (CBP-290) Moved from Draft to Current Chapters (September 30, 2026)

Federal Register (CBP): Customs User Fees To Be Adjusted for Inflation in Fiscal Year 2027, 91 FR 48398, FR Doc. 2026-15530 (July 31, 2026)

Federal Register (FDA): Agency Information Collection Activities; Proposed Collection; Comment Request; Prior Notice of Imported Food Under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002, FR Doc. 2026-19281 (September 21, 2026)

CBP: Trade User Information Notice INT-057/CBP-290 – Implementation of Entry Type 13 Test in ACE for U.S. Mail Processing (September 3, 2026)

CBSA: Customs Notice 26-23 – United States Surtax Order (2026) (September 7, 2026)

CBP: CSMS # 69763204 – Cargo Release Condition Codes Documents has been Posted to cbp.gov (September 4, 2026)

U.S. Court of International Trade: Axle of Dearborn, Inc. d/b/a Detroit Axle v. United States, Slip Op. 26-94 (Aug 13, 2026)

Federal Register: Indefinite Suspension of the De Minimis Exemption, All Modes Other Than International Postal (91 FR 37789)

Federal Register: Indefinite Suspension for Mail Shipments and New Postal Informal Entry Process (91 FR 37801)

Federal Register: Test of the New Electronic Informal Entry Process for Mail, Entry Type 13 (91 FR 38007)

Federal Register: E.O. 14324, Suspending Duty-Free De Minimis Treatment for All Countries

Federal Register: E.O. 14388, Continuing the Suspension of Duty-Free De Minimis Treatment (91 FR 9433)

Federal Register: CBP Notice of Implementation of E.O. 14324 (90 FR 42418)

Federal Register: Imposing a Temporary Import Surcharge to Address Fundamental International Payments Problems

Supreme Court of the United States: Learning Resources, Inc. v. Trump, No. 24-1287 (Feb. 20, 2026)

USTR: USMCA Chapter 7: Customs Administration and Trade Facilitation, Article 7.8

USTR: Ambassador Greer Issues Statement on the USMCA Joint Review

CBP: E-Commerce Frequently Asked Questions, de minimis and Entry Type 13 guidance

Global Affairs Canada: Active and Concluded State-to-State Dispute Settlement Cases

Global Affairs Canada: Canada’s Request for Consultations, U.S. IEEPA Import Duties (Mar. 4, 2025)

El Financiero: Postergan cuarta ronda de negociaciones del T-MEC entre México y EU (September 17, 2026)

CRS: Supreme Court Rules Against Tariffs Imposed Under IEEPA (LSB11398)

CRS: USMCA Joint Review: Process and Role of Congress (R48787)

Troutman Pepper Locke: No More Free Ride: Navigating CBP’s New International Mail Entry Process

BDO: CBP Suspends De Minimis Exemption and Introduces New Postal Entry Requirements

White & Case: USMCA 2026 Joint Review: United States Declines to Extend Agreement

White & Case: United States Terminates IEEPA-Based Tariffs Following Supreme Court Decision

Skadden: US Trade Court Strikes Down Section 122 Tariffs, but Ruling’s Fate Is Uncertain

Baker McKenzie: New Section 301 Forced Labor Tariffs Take Effect July 24, 2026

The Braumiller Group: USMCA: Negotiation Preparations