Audit your import workflow for reliance on Section 321 de minimis: as of May 2, 2025 the $800 de minimis exemption was eliminated for goods of Chinese or Hong Kong origin — those shipments now owe full duties and Section 301 tariffs regardless of value.
As of August 29, 2025 the administration suspended duty-free de minimis entry for all countries globally, requiring full customs inspection and tariff collection on all shipments regardless of value — verify the current regulatory status at the time of implementation as this area is subject to ongoing executive and congressional action.
For postal shipments, note that beginning February 28, 2026 the ad valorem duty calculation method based on proper HTS classification is required; update your classification and valuation data pipelines accordingly.
Remove any logic that automatically routes sub-$800 shipments to Section 321 entry type without checking the current country-of-origin and regulatory status at the time of shipment.
Work with your customs broker to determine the correct entry type (formal entry, informal entry, or Section 321 if still applicable for the specific origin) for each shipment and update carrier and 3PL instructions.
Monitor CBP's Federal Register notices and your customs broker's regulatory alerts, as the de minimis situation remains in active legislative flux with potential threshold and category changes pending.
Known gotchas
The situation is highly dynamic — rules that applied in early 2025 differ from those in late 2025 and again in early 2026; hard-coding a threshold or country list is fragile and will need continuous maintenance.
Even where de minimis exemptions are suspended, individual countries may have trade agreements or carve-outs; do not apply a uniform global rule without checking bilateral treaty status.
Failing to collect and remit duties on shipments that no longer qualify for de minimis exposes the importer or DTC merchant to CBP penalties and carrier brokerage back-billing.
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