CBP wants a customs bond and earlier filing on every import under $2,500: what it means for low-value purchases
A proposed rule would end post-arrival filing for informal entries, require a bond on each one and create a new electronic entry for international mail. Comments are due Dec. 7, and parts, samples and marketplace buys are all in scope.
Article summary
- Why it matters: Many companies buy small, fast shipments from overseas outside the main purchasing channel: spare parts, samples, lab supplies, marketplace orders on a purchasing card. U.S. Customs and Border Protection’s proposal would put a bond, an earlier filing deadline and new data requirements on every one of those shipments under $2,500, which adds cost and can add delay if suppliers and couriers are not ready.
- What to do first: Find the low-value import spend. Pull purchasing-card, marketplace and expedited-parts transactions with overseas suppliers, and identify who acts as importer of record on each.
- Prefer suppliers and couriers that file for you. For recurring small orders, favor terms where an express carrier or broker files the entry before arrival under its own bond, and confirm that in the order terms.
- $2,500
- value ceiling for shipments covered by the proposal
- Dec. 7
- comment deadline, docket USCBP-2026-0298
- 2.3M
- informal entries filed without a bond, Aug. 2025–July 2026
- $1,000
- minimum liquidated damages for a bond breach
The details
The proposal. CBP published the notice of proposed rulemaking on Oct. 8 (FR Doc. 2026-20650, docket USCBP-2026-0298). Comments are due Dec. 7. It covers merchandise valued at $2,500 or less, including international mail, and nothing in it is in effect yet. CBP gave no effective date for a final rule.
What would change, according to the proposed rule and summaries by GHY International and Customs & International Trade Law:
| Today | Proposed |
|---|---|
| Informal (Type 11) entries can be filed within 15 days after arrival | Filed electronically on or before importation |
| Bonds required for informal entries only in some cases | A single-transaction or continuous bond required for every Type 11 and Type 13 entry |
| Mail entered through a worksheet and pay.gov process | New electronic Type 13 informal mail entry, with sender details and the postal tracking number |
| Goods under certain Chapter 99 provisions above $250 need formal entry | $250 limit removed, so those goods up to $2,500 could use informal entry |
| Formal entry generally required case by case | CBP could require formal entry on a blanket basis by importer, product type or seller |
The proposal also requires the name and address of the final deliver-to party when it differs from the ultimate consignee, and a licensed customs broker as importer of record when the consignee is neither the owner nor the purchaser. Mail under $2,500 that is not entered within 15 days would be treated as abandoned. Minimum liquidated damages for a bond breach would be the greater of the merchandise value or $1,000, according to GHY.
Why CBP wants it. CBP says the changes would help it identify high-risk shipments and improve compliance, noting that international mail has historically had higher seizure rates. De minimis was suspended for all countries from Aug. 29, 2025, and the One Big Beautiful Bill Act ends it by statute from July 1, 2027.
CBP’s own impact figures. About 2.3 million Type 11 entries were filed without a bond between Aug. 1, 2025 and July 31, 2026, or 3.31% of the roughly 70.1 million Type 11 entries CBP projects for 2026. GHY reports CBP found that 68,701 importers filed those unbonded entries, and that for the 59,148 better suited to single-transaction bonds, bond costs would equal 72.66% of their duties, taxes and fees on those entries. For postal entries, CBP assumes a broker fee of about $30 per shipment plus $9.72 in filing time, $39.72 in total. CBP said it cannot certify the rule avoids a significant impact on a substantial number of small businesses.
What procurement teams should do
- Find the low-value import spend. Pull purchasing-card, marketplace and expedited-parts transactions with overseas suppliers, and identify who acts as importer of record on each.
- Prefer suppliers and couriers that file for you. For recurring small orders, favor terms where an express carrier or broker files the entry before arrival under its own bond, and confirm that in the order terms.
- Consolidate where you can. Fewer, larger shipments under a continuous bond will usually cost less than many single-transaction bonds; ask your customs broker to model it.
- Tighten supplier data. Earlier filing means suppliers must send accurate values, descriptions and deliver-to addresses before shipping. Add that to supplier onboarding for overseas vendors.
- Comment if it affects you. Companies that depend on international mail or small expedited shipments can file comments by Dec. 7 with their own cost and timing data.
What to watch next
- Dec. 7, 2026. The comment deadline. Watch whether express carriers, brokers and small-business groups push for thresholds or phase-ins.
- A final rule. CBP gave no timetable, but the July 1, 2027 statutory end of de minimis is the natural planning date.
- CBP entry guidance. Any interim instructions on Type 13 mail entries or blanket formal-entry requirements will show where enforcement focuses first.
The bigger picture
Low-value imports used to sit outside most procurement controls because they rarely triggered duty or paperwork. The suspension of de minimis, a stack of new tariffs and now this proposal turn every small overseas order into a customs transaction with a cost and a compliance owner. That fits a broader enforcement push: CBP’s data analytics and the Justice Department’s focus on tariff evasion are raising the risk of getting entries wrong.
For category managers, the practical effect is to move tail spend from overseas marketplaces toward domestic distributors or consolidated programs where the landed-cost math now favors them. Track the dates on our Tariff & Trade Deadline Tracker, and see what’s at stake for China-origin goods as 178 Section 301 exclusions expire Nov. 10.
Questions procurement teams are asking
What does CBP's low-value shipment proposal change?
For goods valued at $2,500 or less, it would require informal entries to be filed electronically on or before importation instead of within 15 days of arrival, require a customs bond on every Type 11 and new Type 13 mail entry, and add data such as the final deliver-to party.
When is the deadline to comment on CBP's low-value shipment rule?
Comments are due Dec. 7, 2026, on Regulations.gov under docket USCBP-2026-0298. The rule is a proposal and nothing in it is in effect yet.
Does the de minimis exemption still apply?
No. De minimis was suspended for all countries from Aug. 29, 2025, and the One Big Beautiful Bill Act ends it by statute from July 1, 2027, so low-value imports already require entry and duty.
How we reported this
This story draws on 5 sources, listed below, and reflects figures as reported on October 15, 2026. The sections on why it matters and what procurement teams should do are Procurement Signal analysis. It is not legal or financial advice. See our editorial standards.
Sources
- Federal Register (public inspection) — CBP proposed rule on low-value shipments, FR Doc. 2026-20650
- GHY International — CBP proposes new rules for low-value shipments; comments due Dec. 7
- Customs & International Trade Law — CBP proposes bonds and earlier filing for low-value informal entries
- Charles M. Schayer & Co. — CBP proposes major changes for low-value imports
- National Law Review — Tariff-ied! This week in international trade (Oct. 12, 2026)
