CBP Proposes Overhaul of Low-Value Entries: Mandatory Pre-Arrival Filings, Mandatory Customs Bonds, and New Mail Procedures - Sobel Network Shipping Co., Inc.
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CBP Proposes Overhaul of Low-Value Entries: Mandatory Pre-Arrival Filings, Mandatory Customs Bonds, and New Mail Procedures

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Trade Advisory: What Importers Need to Know About CBP’s Proposed Informal Entry Rule

U.S. Customs and Border Protection (CBP) has issued a Notice of Proposed Rulemaking (NPRM) targeting low-value shipments valued at $2,500 or less. If finalized, the regulation will fundamentally alter informal entry procedures, eliminating the longstanding 15-day post-arrival filing window and introducing strict bond and data mandates across commercial cargo and international mail.

1. End of the 15-Day Post-Arrival Filing Window

Under current regulations, informal entries (Entry Type 11) can generally be filed up to 15 calendar days after shipment arrival. CBP’s proposed rule mandates that all Entry Type 11 filings be submitted electronically on or before the date of importation.

By moving the filing deadline upstream, CBP aims to obtain critical shipment data earlier, allowing the agency to target high-risk shipments, identify illicit trade, and enforce partner government agency (PGA) requirements prior to release. Importers and filers will no longer have the luxury of reviewing documentation after freight touches down; classification, valuation, origin, and consignee details must be finalized prior to arrival.

2. Mandatory Customs Bonds and Stiffer Liquidated Damages

Currently, Entry Type 11 entries only require a customs bond under specific circumstances. Under the proposed framework:

  • Every informal entry filer (both Type 11 and the newly proposed Type 13) must maintain either a continuous customs bond or secure a single transaction bond under 19 CFR 113.62.

  • Minimum Liquidated Damages: CBP proposes a new minimum penalty threshold for bond breaches on informal entries. Liquidated damages will be assessed at the merchandise value or a minimum of $1,000, whichever is greater. For restricted goods or alcoholic beverages, damages jump to three times the value or $1,000.

3. Formalization of Postal Shipments: Entry Type 13

To tighten controls over the international postal network, CBP is proposing Entry Type 13 (ET13).

  • ET13 will serve as the dedicated electronic informal entry pathway for postal merchandise valued at $2,500 or less.

  • Mail shipments will not be released from CBP custody until electronic entry is filed.

  • Packages remaining unentered 15 days after arrival will be treated as voluntarily abandoned and turned over to USPS for return or destruction.

4. Broker Representation & Consignee Visibility

  • Deliver-to Party Requirement: Importers will be required to provide the name and full address of the final “deliver-to” party whenever it differs from the ultimate consignee listed on CBP Form 7501.

  • Mandatory Broker Representation: If a consignee named on an informal shipment is neither the owner nor the purchaser of the goods (such as a carrier, freight forwarder, or postal operator), they will be legally required to appoint a licensed customs broker to act as the Importer of Record (IOR).

5. Additional Key Provisions

  • Chapter 99 Threshold Increase: The proposal removes the current $250 cap on certain Chapter 99 goods (Subchapters III and IV), allowing eligible trade-remedy merchandise between $250 and $2,500 to qualify for informal entry rather than forcing a formal entry.

  • Discretionary Blanket Formal Entries: CBP proposes codified authority to mandate formal entry on a blanket basis for specific importers, commodities, or manufacturers deemed higher risk.

Sobel Network Shipping Takeaway & Recommendations

While this rule remains in the notice-and-comment phase, the direction of CBP enforcement is unmistakable: low-value shipments are being aligned with standard commercial entry compliance.

  • Audit Your Supplier Data Pipelines: Importers must ensure suppliers provide commercial invoices, HTS codes, and dispatch manifests well before arrival.

  • Evaluate Bond Coverage: Businesses relying on high-volume informal entries should assess whether their current bond structure covers upcoming liabilities or if a continuous bond needs to be secured.

  • Partner with Your Customs Broker: As CBP tightens the administrative window at the border, having an automated, compliant electronic filing pipeline is essential to prevent cargo holds, abandonment, or liquidated damages.