Customs and Border Protection opened its Entry Type 13 pilot this week, putting an electronic informal entry pathway under the international postal stream for the first time and giving low-value shipments carrying Section 232 and Section 301 duties a route that does not run through formal entry.
WASHINGTON, September 24, 2026
The single largest unresolved operational problem created by the end of duty-free de minimis treatment moved toward a solution on Monday, when US Customs and Border Protection opened the Entry Type 13 Test to filers and carriers.
The voluntary pilot, announced in a general notice published at 91 FR 38007 and signed by Susan S. Thomas, Executive Assistant Commissioner in CBP’s Office of Trade, commenced on September 22, 2026 and will continue until CBP concludes it by a further Federal Register announcement. Comments are being accepted throughout.
Entry Type 13, formally titled Informal Mail Entry, creates an electronic informal entry process in the Automated Commercial Environment for international mail shipments valued at $2,500 or less, including the enormous volume of parcels that until last year moved duty free under the de minimis administrative exemption.
For importers, e-commerce sellers, brokers and postal operators, the significance is not the entry type itself but what it makes possible. Under the interim process that Entry Type 13 sits alongside, a low-value mail shipment subject to Section 232 or Section 301 duties could not be entered informally at all. It had to go through formal entry. The pilot waives that requirement for participants, and in doing so removes what had become the most expensive friction point in postal commerce into the United States.
How the United States got here
The de minimis exemption under 19 U.S.C. 1321(a)(2)(C) allowed articles valued at $800 or less, imported by one person on one day, to enter free of duty and with minimal data. For roughly a decade it was the legal foundation of direct-to-consumer cross-border e-commerce, and volumes grew into the billions of shipments annually.
That structure was dismantled in stages. Executive Order 14324 of July 30, 2025, titled “Suspending Duty-Free De Minimis Treatment For All Countries,” was published at 90 FR 37775 on August 5, 2025. Executive Order 14388 of February 20, 2026, “Continuing the Suspension of Duty-Free De Minimis Treatment for All Countries,” was published at 91 FR 9433 on February 25, 2026. CBP then indefinitely suspended the exemption for mail through an interim final rule issued on June 24, 2026, which also established a new postal informal entry process.
One narrow survival is worth noting because it is routinely misunderstood. The suspension of the administrative exemption under 19 U.S.C. 1321(a)(2)(C) does not affect the separate de minimis exemption for qualifying bona fide gifts under 19 U.S.C. 1321(a)(2)(A) and 19 CFR 10.152. Genuine person-to-person gifts within the applicable value limit remain outside the new machinery.
Everything else changed. Once mail shipments lost de minimis eligibility, filers could no longer use the special informal procedures associated with that exemption and had to fall back on existing entry types. Formal entry, governed by 19 U.S.C. 1484 and 1485 and set out in 19 CFR part 142 with mail-specific provisions in 19 CFR 145.12(a), applies generally to shipments above $2,500 and to shipments at or below that value that do not qualify for informal treatment.
CBP established a new interim informal process for qualifying mail shipments at or below $2,500 under 19 CFR 145.12(b). But that interim process carved out a great deal. Mail shipments valued at $2,500 or less that are subject to Partner Government Agency data requirements, to antidumping or countervailing duties, to quotas, or to duties other than those in Chapters 1 through 97 of the Harmonized Tariff Schedule, including duties under Chapters 98 or 99, were ineligible. Those shipments had to be entered formally.
The Chapter 99 exclusion is the one that mattered most in practice, because Chapter 99 is where Section 201, Section 232 and Section 301 duties live. In a tariff environment in which a growing share of merchandise carries at least one trade remedy, a rule that pushes every Chapter 99 shipment into formal entry pushes a very large share of postal volume into a process designed for containerised freight.
What Entry Type 13 actually does
The pilot addresses that problem directly. CBP states that the test “temporarily creates an informal entry pathway for low-value international mail shipments subject to PGA data requirements or duties other than those set forth in Chapters 1-97 of the HTSUS,” which the notice’s footnote identifies as including Section 201, Section 232 and Section 301 duties.
The waivers are specific. For test participants, CBP waives the formal entry requirement in 19 CFR 145.12(a)(2)(v) for goods subject to PGA requirements and in 19 CFR 145.12(a)(2)(vi) for goods subject to Chapter 98 and 99 duties. It also waives 19 CFR 145.12(b) insofar as those interim informal procedures conflict with the test, and provisions in 19 CFR part 143 subpart C and part 145 to the same limited extent.
Two categories remain outside. Shipments subject to antidumping or countervailing duties and shipments subject to quotas stay ineligible for informal entry and must still be entered formally under 19 CFR 145.12(a). CBP also preserves its authority under 19 CFR 145.12(a)(1) to require formal entry of any mail shipment regardless of value where necessary to protect the revenue.
Who can participate, and what it costs them
Eligibility tracks the right to make entry. The test is open to owners and purchasers of merchandise mailed to the United States through the international postal network, and to licensed customs brokers properly appointed by the owner, purchaser or consignee.
That distinction carries real weight for the logistics sector. CBP is explicit that a consignee who is not an owner or purchaser, a category that expressly includes foreign postal operators, the United States Postal Service, freight forwarders and carriers, must obtain the services of a licensed broker who will act as importer of record for the entry.
There is no separate application. Participation is effected simply by filing an entry type 13 electronically in ACE.
There is, however, a bond requirement, and it is the element most likely to reshape commercial arrangements. Filing an entry type 13 requires a basic importation and entry bond, either a single transaction bond or a continuous bond, with the terms and conditions in 19 CFR 113.62. CBP grounds this in its broad bonding authority under 19 U.S.C. 1623 and 19 CFR 113.1, and states that the bond is necessary to protect the revenue, guarantee payment of duties, taxes and fees, and obligate the importer of record to correct non-compliance relating to admissibility.
Where a consignee appoints a broker to file, it is the broker’s bond that is obligated. That single sentence in the notice describes a significant transfer of financial risk onto the customs brokerage industry, which will now be underwriting duty payment on postal parcels at a volume and unit economics that the brokerage bonding model was not built around.
The data set
An entry type 13 requires the importer of record to transmit twelve data elements electronically: filer code; importer of record number; description of merchandise; country of origin; all applicable ten-digit HTSUS classifications, including both primary classifications in Chapters 1 through 97 and any applicable secondary classifications in Chapters 98 or 99; quantity and weight where specific duty rates apply; duty rate; value; total duty owed; carrier name; the tracking number generated by the foreign post operator; and arrival port.
Quantity and weight are conditional, required only where specific duty rates apply. Shipments subject to PGA requirements or to duties outside Chapters 1 through 97 must transmit the additional data those regimes mandate. Technical transmission requirements are in the CBP and Trade Automated Interface Requirements guidelines for ACE.
Compare that against what accompanied a de minimis parcel two years ago and the scale of the change becomes clear. A ten-digit classification, a country of origin determination and a calculated duty figure are professional customs work. Applying them to individual consumer parcels at postal volumes is a data engineering problem before it is a compliance problem.
Closing the visibility gap
The second half of the pilot addresses a gap that has frustrated CBP enforcement in the mail environment for years.
Under current regulations, carriers transporting international mail provide CBP only with the weight of arriving mail. The notice says plainly that this “fails to sufficiently address the risks in this environment and inhibits CBP from verifying that a specific mail article has been entered in accordance with all applicable requirements.” CBP notes that although it receives additional mail data under the regulations implementing 19 U.S.C. 1415(a)(3)(K), that information cannot be used for any commercial enforcement purpose, including determining merchandise entry, under 19 U.S.C. 1415(a)(3)(F).
Carriers may elect to participate in the test by reporting, on their manifest, the tracking number generated by the foreign postal operator for each arriving mail shipment. Where both carrier and filer participate, CBP can match the tracking number on the manifest to the tracking number on the entry, determine the precise time of arrival for each shipment, and confirm that an entry was timely filed.
That is the enforcement architecture of the entire exercise, and CBP is transparent about it. The agency encourages carriers to participate regardless of whether the entry filer does.
Christopher Mabelitini, Director of the Intellectual Property Rights and E-Commerce Division in CBP’s Office of Trade, is the designated contact for the test. Comments may be submitted at any time during the test period to cbpdm@cbp.dhs.gov with the subject line “Comments on the Entry Type 13 Test.” The test is authorised under 19 CFR 101.9(a), which permits the Commissioner to impose requirements different from the regulations for the purpose of evaluating new technology or operational procedures.
Economic impact analysis
The economics of postal commerce into the United States have been rewritten twice in fourteen months, and Entry Type 13 is the third rewrite.
The first change, the suspension of de minimis, added duty to shipments that previously bore none. The arithmetic there is straightforward: a $40 apparel parcel from an Asian manufacturer that once entered free now carries an applicable most favoured nation rate plus any Section 301 duty, which for many consumer goods categories is a material fraction of the retail price.
The second change, the interim informal process with its Chapter 99 exclusion, added something more expensive than duty, which is process cost. Formal entry involves broker fees, bond costs, merchandise processing fees at the formal rate, and a filing burden that does not scale down. Applied to a $40 parcel, the fixed cost of formal entry can exceed the duty itself and in some cases approach the value of the goods. For a large share of low-value cross-border e-commerce, this was not a tax. It was a prohibition.
Entry Type 13 is the third change, and it moves in the opposite direction. By permitting informal entry for Chapter 99 and PGA shipments, it restores a viable cost structure for parcels that were effectively priced out of the postal channel. The duty still applies. The formal entry overhead does not.
Who captures that saving is an open question. In a competitive e-commerce market, most of it should flow to consumers as lower delivered prices. In practice, the intermediaries that carry the compliance burden, principally licensed brokers acting as importer of record with their bonds obligated, will price for the risk they are now absorbing, and that pricing will not be trivial.
There is also a structural effect worth watching. By making postal entry electronically tractable, CBP reduces the incentive for sellers to shift volume from the postal network into express consignment channels, which had been the natural response to postal friction. The express carriers built their business partly on being the compliant alternative to a postal system that could not file entries. If the postal system can now file entries, that advantage narrows.
For the domestic retail sector, the picture is the one it has been arguing for since 2019. Domestic retailers have long contended that de minimis created a structural subsidy for foreign direct-to-consumer sellers, who faced neither the duty nor the compliance cost borne by importers of record bringing the same goods in by container. The suspension removed the subsidy. Entry Type 13 removes some of the frictional penalty that replaced it, which domestic retailers may view as a partial restoration of the advantage they spent years arguing against.
What this means for importers and US businesses
For e-commerce sellers shipping into the United States by post, the first decision is whether to participate. Participation is voluntary, requires no application, and offers access to informal entry for goods that otherwise face formal entry. For any seller whose products carry Section 232, Section 301 or Section 201 duties, or whose goods are subject to PGA data requirements, the case for participating is strong.
The second decision is who files. A seller that is the owner or purchaser of the merchandise can file in its own name in ACE, which requires ACE access, filer credentials and a bond. A seller that is not, or that prefers not to, must appoint a licensed broker who will act as importer of record. Those are different cost structures and different liability profiles, and the choice should be made deliberately rather than by default.
Classification discipline is now unavoidable. The twelve required data elements include all applicable ten-digit HTSUS classifications, primary and secondary. A seller with a catalogue of thousands of SKUs needs a classification database, a process for maintaining it, and a mechanism for applying Chapter 99 secondary classifications correctly. Getting this wrong at postal volume creates exposure at postal volume.
Bond capacity deserves early attention. Continuous bond sufficiency is calculated against duties, taxes and fees paid, and a seller or broker that has moved from paying near zero duty on postal volume to paying substantial duty will find its existing bond inadequate. Sureties have finite appetite, and the time to discover a capacity problem is not the week a peak season begins.
Carriers should weigh manifest participation on its own terms. Transmitting foreign postal tracking numbers is an operational change with system implications, and it delivers enforcement value to CBP rather than commercial value to the carrier. The offsetting consideration is that CBP has told the industry plainly what it wants, has framed the current data gap as a risk it cannot tolerate, and is testing an approach it intends to make permanent. A carrier that helps shape the test is better placed than one that inherits its conclusions.
The penalty framework should not be overlooked. CBP states that a participant who fails to follow the test’s rules, fails to exercise reasonable care, fails to abide by applicable laws and regulations not waived, or fails to pay duties, taxes or fees in a timely manner may be subject to civil and criminal penalties, administrative sanctions, liquidated damages and other enforcement action. Participation in the test does not dilute any other statutory or regulatory obligation.
Where this is heading
CBP has said what it intends. The notice states that the agency “plans to replace the new interim process for informal mail entries with an automated informal entry process,” and that the voluntary test will let it evaluate the new entry type’s capabilities in the mail environment, particularly in light of the large volume of mail formerly eligible for de minimis.
That is a statement of direction rather than of possibility. Entry Type 13, or something closely resembling it, is the future of postal entry into the United States. The test period is the window in which its design is still negotiable, and CBP has explicitly invited comment on whether to modify, alter, expand, limit, continue, end or fully implement the entry type.
Companies that are going to be living inside this process for the next decade have a short period in which their operational experience can influence it. After that, it will simply be how mail enters the country.
The parts CBP did not solve
It is worth being clear about what the pilot leaves untouched, because the gaps define the next round of problems.
Antidumping and countervailing duty merchandise stays outside. A low-value mail shipment of a product subject to an AD or CVD order must still be entered formally, with all the cost that implies. Given that AD and CVD orders now cover a wide range of consumer-adjacent goods, from certain steel products to quartz surface products to a long list of chemicals, this is not a narrow exclusion. Sellers whose catalogues touch scope-covered merchandise will find that the pilot does nothing for them, and scope determinations in this area are notoriously difficult for non-specialists to make.
Quota merchandise is likewise excluded, and CBP retains the discretion under 19 CFR 145.12(a)(1) to require formal entry of any mail shipment regardless of value to protect the revenue. That is a reserved power rather than a routine practice, but it means no filer can treat informal treatment as guaranteed.
The test also does not resolve the question of who bears liability when the data supplied by a foreign seller turns out to be wrong. The importer of record certifies the classification, origin, value and duty owed. In the postal channel, the importer of record is frequently a broker acting for a consignee, working from data assembled by a seller in another jurisdiction whom the broker has never met and cannot audit. Reasonable care is a standard designed for a commercial importer with visibility into its own supply chain. Applying it to a broker filing thousands of parcel entries a day on third-party data is a genuinely novel problem, and the notice’s misconduct provisions do not soften it.
Finally, the pilot is a test. CBP can modify, limit or end it. Companies that rebuild their operations around Entry Type 13 are building on a foundation the agency has expressly reserved the right to change, and contracts with logistics providers and brokers should reflect that.
A note on sequencing
There is a pattern in the three Federal Register actions that produced this week’s opening, and it is worth naming.
The executive orders removed the exemption. The interim final rule established a replacement process that, by excluding Chapter 99 and PGA goods, was unworkable for a large share of the affected volume. The test then restores workability for exactly that share, on a voluntary basis, in exchange for a data set and a manifest linkage that give CBP visibility it has wanted for years and could not obtain under the statutory constraints on postal data.
That is not an accident of drafting. It is a sequence that converted an enforcement problem into a set of incentives, and the industry’s participation in the test is the price of relief from a friction the same agency created. Whether one reads that as sound administration or as leverage, it is the reason the pilot is likely to succeed where a mandatory data mandate would have met years of resistance.