CBP to pilot Entry Type 13 for mail parcels <=$2,500 from 22 September

The Analysis

CBP begins a voluntary pilot of Entry Type 13 on 22 September. It is a new ACE electronic informal entry built for international mail valued at $2,500 or less, and it is intended to become the standard channel for small parcels after de minimis. Every filing needs a 10-digit HTSUS classification, the country of origin, the declared value, the duty calculation and an importer ID. Formal entry still applies above $2,500 and for goods exposed to Section 301 or Section 232 punitive tariffs.

Two details do the damage. The first is that the pilot is voluntary while the standard is not. A voluntary pilot means CBP accepts filings on the new route while the old route still absorbs volume; once volume moves, the classification work does not disappear, it lands on whoever has to file. The second is that $2,500 is not a high bar for a parcel. A two-item order can cross it, and that is the line where an electronic informal entry turns into a formal one.

The five briefs below divide the work. Exporters selling DDP into the United States need to know which shipments travel as mail and who files. Import e-commerce sellers need a per-parcel cost and a split-or-merge rule anchored on the threshold. Factories need a channel that survives the conversion for samples and spares. Brands need a delivery promise that has a customs day inside it. Procurement needs broker terms that price classification rather than the parcel.

For Exporters

• By 16 September: attach a 10-digit HTSUS code and country of origin to every mail-borne SKU, with no blanks in the file.
• By 18 September: get two brokers to price Entry Type 13 and formal entry separately, per filing and per line, with error allocation stated.
• By 22 September: have a live ACE test file ready before the pilot opens rather than learning the schema in week one.
• By 26 September: show the customs cost as a named quote line and cut US mail DDP quote validity from 30 days to 14.
• By 30 September: move high-value parcels from DDP to DAP where the buyer accepts the obligation, and write the threshold down.
• Do not split parcels for Section 301 or 232 goods: they go to formal entry at any value.

CBP starts a voluntary pilot of Entry Type 13 on 22 September. It is a new ACE electronic informal entry for international mail valued at $2,500 or less, and it is meant to become the standard channel for small parcels after de minimis. Every filing needs a 10-digit HTSUS classification, the country of origin, the declared value, the duty calculation and an importer ID. Above $2,500, and for goods exposed to Section 301 or Section 232 tariffs, formal entry still applies. If you sell on DDP terms into the United States, this lands on your profit and loss first, because you are the party that files.

Run your own numbers. Assume 8,000 mail parcels a month into US consumers at an average declared value of $180. Assume 97% sit under the threshold, which is 7,760 parcels, and a broker files each at an assumed $2.80, or $21,728 a month. The other 240 parcels come from multi-item orders and go to formal entry at an assumed $107 each including the bond, or $25,680. Total is $47,408 a month and $568,896 a year, against an assumed $0.20 a parcel, or $1,600, under today's self-handling. The increase is $45,808 a month, $549,696 a year and $5.93 a parcel. On a $180 order at a 25% gross margin of $45, that is 13% of the margin, and it is the largest single cost change inside the carton.

By 16 September, take 90 days of parcel data and attach a 10-digit HTSUS code and a country of origin to every SKU that moves by mail, with no blanks, because a missing code at filing is a held parcel. By 18 September, get two brokers to price Entry Type 13 and formal entry separately, per filing and per line, with the error-allocation terms stated in writing. By 22 September, have a live test file through ACE before the pilot opens, so you are not learning the schema in the first week of volume. By 26 September, show the customs cost on the quote as a named line and cut DDP quote validity on US mail from 30 days to 14. By 30 September, move high-value parcels from DDP to DAP where the buyer will accept the obligation, and put the value threshold in writing.

Three fallbacks. Move high-value SKUs out of mail into a consolidated commercial channel with an $800 to $2,500 informal entry or a standard formal entry, where one filing covers many parcels. Hold a US-side buffer stock and ship the top SKUs domestically, which removes the customs day from the promise. Or keep DDP and price it, which is honest and often survives the comparison. The traps matter more than the fallbacks. Section 301 and 232 goods must go formal at any value, so splitting a parcel to stay under $2,500 buys nothing for those SKUs. A country of origin declared at container level is not accepted at parcel level, and a wrong code becomes a post-entry correction with penalty exposure. And the importer ID has to be a real, named US entity; you cannot invent one for a consumer parcel.

For Cross-Border E-commerce

• By 17 September: build a declared-value histogram over 90 days and flag every SKU landing within $200 of $2,500.
• By 19 September: set a merge cap of $2,200 and a split trigger of $2,600, with the second parcel's freight cost shown at the pack station.
• By 22 September: have the ACE test file live and both broker rates per filing confirmed in writing.
• By 30 September: load customs cost into landed cost per unit and re-price SKUs where it exceeds 5% of gross margin.
• Hold 21 days of cover at the US fulfilment partner through the transition and 30 days on the worst re-priced SKUs.
• Check the tariff line before splitting: Section 301 and 232 goods face formal entry at any value.

For a cross-border seller shipping small parcels into the United States, 22 September changes the cost of the carton rather than the cost of the goods. Entry Type 13 is the new ACE electronic informal entry for mail valued at $2,500 or less, and it requires HTSUS classification, origin, declared value, the duty calculation and an importer ID on every filing. The $2,500 line matters because it is the boundary between an electronic informal filing and a formal entry, and a two-item order can cross it.

Assume 30,000 parcels a month at an average order value of $45. Assume 29,700 sit under $2,500 and clear on Entry Type 13 at an assumed $2.20, which is $65,340. Assume 300 parcels, from multi-item and high-value SKUs, exceed the threshold and go to formal entry at an assumed $107 including the bond, which is $32,100. Total is $97,440 a month and $1,169,280 a year, against an assumed $0.15 a parcel, or $4,500, today. That is $3.25 a parcel, 7.2% of a $45 order and 20.6% of a 35% gross margin of $15.75. The split rule follows from the threshold arithmetic. Merging two $1,400 parcels into one $2,800 parcel turns $4.40 of filings into an assumed $107 formal entry, so the merge costs $102.60 more. Splitting a $2,600 parcel into two $1,300 parcels saves the same $102.60 and costs an assumed $6.50 in extra freight and packing, a net $96.10 a parcel.

By 17 September, run a declared-value histogram over 90 days of parcels and find every SKU that lands within $200 of $2,500. By 19 September, put two rules into the checkout and warehouse systems: a merge cap at $2,200 per outbound parcel and a split trigger at $2,600, with the second parcel's freight cost shown to the picker. By 22 September, have a test file live in ACE and a broker price per filing for both routes confirmed in writing. By 30 September, load the customs cost into landed cost per unit and re-price the SKUs where it exceeds 5% of gross margin. Hold 21 days of cover at the US fulfilment partner through the transition, and 30 days on the SKUs that re-price worst.

Two real alternatives and three traps. Move high-value SKUs to a consolidated commercial channel and file them as one entry, or hold them in US stock and ship domestically, which takes the customs day out of the promise entirely. The traps are the expensive ones. Splitting to stay under $2,500 does nothing for Section 301 or 232 goods, which go to formal entry at any value, so check the tariff line before you re-pack anything. A wrong HTSUS code is a post-entry correction, and at 30,000 filings a month even a 0.5% error rate is 150 corrections to argue about. And a customs day lengthens the delivery promise, which lifts the return rate on exactly the parcels you can least afford to lose.

For Manufacturing Plants

• By 18 September: assign a 10-digit HTSUS code and origin to every parcel type, checking each against Section 301 and 232 exposure.
• By 22 September: name the importer of record and get both broker rates per filing confirmed in writing.
• By 26 September: ship one control parcel and time it end to end so the buffer is measured, not assumed.
• By 30 September: raise the spare-parts buffer to five days and pull the dispatch cut-off for the week of 22 September forward two days.
• By 10 October: decide which spare kits split below $2,500 and write the rule into the shipping work instruction.
• Keep a US-side spare kit at the service partner so a customs day never stops a line.

The parcels a factory sends to the United States are the ones nobody wants to file: samples, spare parts, warranty units, a kit of components. From 22 September, CBP's Entry Type 13 pilot puts a filing on each of them, requiring a 10-digit HTSUS code, a country of origin, a declared value, the duty calculation and an importer ID. Above $2,500, and for goods under Section 301 or 232 tariffs, formal entry applies. The direct cost is a filing fee. The indirect cost is a customs day, and when the parcel is a spare part, that day is downtime.

Assume 1,200 outbound parcels a month to US customers and service partners at an average declared value of $420. Assume 94% sit under the threshold and file on Entry Type 13 at an assumed $2.20, which is 1,128 parcels and $2,482 a month. The other 72 parcels come from multi-line spare kits that cross $2,500 and go to formal entry at an assumed $107, or $7,704. Total is $10,186 a month and $122,232 a year, against an assumed $0.30 a parcel, or $360, today. That is $8.49 a parcel and $9,826 a month of new cost. Put one more number next to it: if the customs day extends delivery by two days on 72 spare-part shipments, the service partner's buffer has to absorb it, and a production line waiting on a part costs far more than $107.

By 18 September, inventory every parcel type going to the United States and assign a 10-digit HTSUS code and a country of origin, with each code checked against the tariff line for Section 301 and 232 exposure. By 22 September, name the importer of record and get a broker's per-filing price in writing for both routes. By 26 September, ship one control parcel through the route and time it end to end, so the two-day buffer is measured rather than assumed. By 30 September, raise the buffer on spares to five days and pull the dispatch cut-off for the week of 22 September forward by two days. By 10 October, decide which spare kits get split into under-$2,500 parcels and which stay whole, and write the rule into the shipping work instruction.

Three alternatives. Send spares as consolidated commercial cargo rather than as mail, which turns many parcels into one entry. Keep a US-side spare kit at the service partner, so a customs day never stops a line. Or move the sample flow to a commercial courier channel with an informal entry under $2,500, priced at a different rate. The traps are specific. A spare kit priced at $2,400 that crosses $2,500 when one line item is added goes to formal entry on that shipment, so split the kit deliberately or price it with the threshold in mind. Section 301 and 232 parts go formal at any value, which makes splitting pointless and a tariff-code error expensive. And the importer ID must be a real US entity; a Chinese factory cannot be the importer of record on a mail parcel into the United States without one.

For Brand Owners

• By 19 September: re-tier the promise by dispatch channel and label each channel with the customs treatment it uses.
• By 23 September: price the customs cost into affected SKUs, hold price on the rest, and write down what is absorbed versus passed through.
• By 30 September: brief customer service with the exact wording of every changed promise, including the reason.
• By 7 October: set the DDP versus DAP value threshold and stop the checkout pushing an order past $2,500 without a flag.
• By 15 October: confirm how replacement shipments after a return are treated, since each replacement is a new entry.
• Absorb or pass through per SKU, not chain-wide: a chain-wide absorb at $2.60 an order is $811,200 a year.

A customs day is a delivery promise and a return rate. From 22 September, CBP pilots Entry Type 13, an electronic informal entry for international mail valued at $2,500 or less, requiring HTSUS classification, origin, declared value, the duty calculation and an importer ID on every parcel. Above $2,500, and for Section 301 or 232 goods at any value, formal entry applies. If your promise to a US consumer is DDP and it carries an arrival date, both the cost and the date are now yours.

Assume 20,000 US consumer orders a month at an average order value of $60 and a 35% gross margin of $21. Assume 26,000 parcels, because some orders ship in two, and a filing cost of an assumed $2.20 plus $0.40 of internal admin, so $2.60 a parcel. That is $67,600 a month and $811,200 a year. Per order it is $3.38 on the parcel count, and $2.60 against a $21 gross margin is 12.4% of margin. Holding that margin needs a $2.60 price rise, which is 4.3% of a $60 price, and that is the pricing decision in one number. The date is the second number. If the transition week adds 1.5 days and a late parcel returns at 4 points higher, that is 800 extra returns on 20,000 orders, and at an assumed $12 a return it is $9,600 in a single week, on top of the $67,600 of filing cost.

By 19 September, re-tier the promise by dispatch channel rather than by product, and label each channel with the customs treatment it uses, so the promise matches the route. By 23 September, price the customs cost into the affected SKUs and hold price on the rest, and put the split between absorbed and passed-through cost in writing before the pilot opens. By 30 September, brief customer service with the exact wording of every promise that changed, including the reason, because a customer warned in advance is not a return. By 7 October, set the value threshold for DDP versus DAP and check that the checkout cannot push a single order past $2,500 without flagging it for review. By 15 October, confirm how replacements shipped after a return are treated, since a replacement is a new entry rather than a continuation of the original one.

Two alternatives. Absorb the cost where a SKU has pricing room and conversion must be protected, and pass it where the SKU is elastic, but decide per SKU rather than chain-wide, because a chain-wide absorb at $2.60 an order is $811,200 a year. Or hold the fastest and highest-value SKUs in US stock and ship them domestically, which removes both the filing cost and the customs day from the promise and turns a variable cost into a fixed one. The traps are a chain-wide DDP promise that quietly eats formal entries on multi-item orders, a promise priced on the launch week rather than the steady-state filing rate once volume arrives, and packaging changes made to keep one order under the threshold that push the next order over and create a formal entry on a $2,600 carton nobody authorised.

For Procurement Teams

• By 15 September: get three brokers to price both routes per filing and per line, with classification included and error allocation stated.
• By 19 September: sign a pilot agreement with 24-hour filing turnaround, a named contact and a weekly error report.
• By 22 September: run your own ACE test file so you control the data your provider files against.
• By 30 September: cap re-work, with no charge for broker errors, a fixed fee for your own, and a monthly error rate with a remedy.
• By 31 October: add a change-of-law clause so the rate card reprices if the voluntary pilot becomes the standard.
• Reject tiered cards that only pay off above roughly 73,000 filings a month; at 30,000 a flat rate wins by $19,500.

The pilot opens on 22 September and it is voluntary, which is the most useful thing about it: the brokers who want your volume will price it before the volume arrives. Entry Type 13 needs a 10-digit HTSUS classification, origin, declared value, the duty calculation and an importer ID on every filing for mail valued at $2,500 or less, while formal entry still applies above $2,500 and for Section 301 or 232 goods. That is a classification service sold per filing, and classification is the line item brokers price badly when the underlying file is not clean.

Compare two rate cards on 30,000 filings a month. Card A is a flat $2.20 a filing, which is $66,000. Card B is $3.40 for the first 20,000 and $1.75 above, which is $68,000 plus $17,500, or $85,500. Card B looks cheaper at the top tier and is $19,500 a month worse at your volume. The break-even is about 73,000 filings a month: below that, the flat card wins, and 30,000 a month is a long way below it. Now price the error clause. Assume a 0.5% classification error rate, which is 150 corrections a month; at an assumed $45 each, allocating the correction cost to whoever caused it is worth $6,750 a month and $81,000 a year, which on its own pays for a serious data-quality programme.

By 15 September, ask three brokers to price Entry Type 13 and formal entry separately, per filing and per line, with classification included and the error-allocation rule stated in the quote. By 19 September, sign a pilot agreement with a 24-hour filing turnaround, a named contact and a weekly error report, and hold it to a 30-day review. By 22 September, have your own test file live in ACE, because a provider that files your data is not the same as a provider that fixes your data. By 30 September, cap the re-work: no charge for a correction caused by the broker, a fixed fee for one caused by your file, and a monthly error rate with a remedy attached. By 31 October, add a change-of-law clause, because a voluntary pilot that becomes the standard channel changes your volume overnight and the rate card should reprice with it rather than against you.

Two alternatives to a per-filing contract. Buy the classification as a fixed data service that converts your SKU master into 10-digit codes once, then file against it, which turns a per-parcel cost into a per-SKU one. Or negotiate a blended rate across both routes, so formal-entry parcels are priced inside the same card rather than at a separate, higher tariff. Three traps. A tiered card that only pays off above about 73,000 filings a month, which at 30,000 a month is a discount you will never reach. A classification-included price quoted against a file with no HTSUS codes in it, which the broker will re-price once the pilot data shows the real effort involved. And a contract with no cap on re-work, where 150 corrections a month at an assumed $45 each quietly adds $81,000 a year to a card you thought was fixed.

↑ Back to the key points