Peacock Tariff Consulting works with CVG-based DTC and e-commerce importers, Amazon Air sellers, DHL Express shippers, and regional pharma. CVG handles ~50 million packages per month – Amazon Air’s primary global hub and DHL’s largest global hub. Post-de-minimis, every CVG-routed parcel needs a tariff strategy.
CVG is where e-commerce meets tariffs. The end of de minimis under Section 321, Section 301 on small-parcel air freight, and Section 122 on most non-USMCA imports all land here first. DTC and e-commerce brands shipping via Amazon Air or DHL Express need advisors who understand air-cargo entry types, informal vs. formal entry thresholds, and consolidator invoicing.
Peacock Tariff Consulting works with CVG-region importers across DTC e-commerce, Amazon Air sellers, regional pharma, and the P&G ecosystem.
Post-de-minimis e-commerce – the new entry economics
Section 321 de minimis tightening in 2025 collapsed the $800-per-shipment cushion for most categories. DTC brands shipping into the U.S. via CVG now pay full duty plus Section 122 plus (where applicable) Section 301 on shipments that previously cleared informal.
For SMB DTC brands, the playbook: (1) consolidate to formal entry where economic; (2) audit HTS classification across the catalog; (3) consider FTZ for the stable inventory portion; (4) file IEEPA refunds on the April 2025 – February 2026 window.
Section 321 reclassification – what CVG shippers are filing wrong
Common Section 321 entry errors at CVG: misclassified parcel value when goods are bundled; aggregated entry where Section 321 should not apply; misuse of “manifest entry” where formal entry is required. CBP enforcement is intensifying. Our work covers entry-type audits and SOP setup for DTC brand operators.
Amazon Air and DHL Express – entry-level optimization
Amazon Air consolidates millions of seller shipments through CVG. DHL Express runs its largest global hub here. For sellers using either channel, the entry-level tariff treatment depends heavily on shipment structure, value declaration, and origin documentation. Misclassified entries compound across thousands of shipments.
IEEPA refund – high-volume parcel implications
CVG-routed e-commerce shipments paid IEEPA tariffs throughout the April 2025 – February 2026 window. For high-volume DTC brands, the cumulative IEEPA exposure is large and the per-shipment refund work is highly mechanizable. We file claims on contingency for filings above $50k.
NKY FTZ activation for e-commerce aggregators
FTZ #29 (Northern Kentucky) covers the CVG area. For e-commerce aggregators running staged inventory before Amazon FBA injection or DHL distribution, FTZ activation defers duty until consumption. Activation makes sense at $20M+ annual import volume.
Frequently asked questions
Do you serve DTC brands shipping through CVG?
Yes – DTC and e-commerce is one of our active engagement profiles for the CVG market. Catalog classification audits, Section 321 entry-type reviews, and IEEPA refund filings are common.
How does Section 321 reclassification work?
Section 321 informal entry has specific value and documentation requirements. CBP can reclassify entries that do not meet the requirements as formal entries – assessing duty plus penalties retroactively. Our work audits entry treatment and sets up SOPs to prevent reclassification.
Can you handle high-volume IEEPA refund filings for an FBA seller?
Yes. Catalog-scale IEEPA refund filings (thousands of entries across hundreds of SKUs) are mechanizable; we run them on a contingency basis where claim size justifies.
What does NKY FTZ activation cost?
FTZ Board application: $5k-15k legal+filing. Operator setup: $10k-50k. Annual operations: $30k-100k+ depending on volume. Justified at $20M+ annual import volume.
Are you affiliated with REDI Cincinnati or NKY Chamber?
No. We are independent.
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