On October 8, 2026, U.S. Customs and Border Protection (CBP) published a proposed rule, titled "Low-Value Shipments," that would rework informal entries of goods valued at $2,500 or less. Three changes in it matter most to importers. Every type 11 informal entry would need a customs bond. Each one would have to be filed electronically on or before the date of importation, not within 15 days after arrival as today. And international mail would get its own electronic entry type, type 13. This is a proposal, not a rule in force. As of October 8, 2026, nothing in it applies to your entries, and CBP is taking comments until December 7, 2026.
If you file informal entries, especially without a bond, this post covers what CBP proposes, what it would change in your workflow if finalized, and what is worth doing before the comment period closes.
What CBP published on October 8, 2026
The document is a notice of proposed rulemaking (NPRM) from the Department of Homeland Security and CBP, Federal Register document 2026-20650, published at 91 FR 64532. It sits in docket USCBP-2026-0298 under RIN 1685-AA38 and would amend 19 CFR parts 113, 128, 141, 143 and 145. The summary describes its purpose as proposing "to modify filing requirements for informal entries of goods valued at $2,500 or less and to establish a new electronic informal entry type for merchandise entering through the mail environment," plus "requiring an additional data element for carriers pertaining to mail shipments and imposing bonding requirements for certain informal entries."
Some background on the terms. An informal entry (entry type 11) is the simpler entry process CBP allows for most shipments valued at $2,500 or less. It is still a real customs entry, with classification under the Harmonized Tariff Schedule of the United States (HTSUS), a declared value, a country of origin and an importer of record (IOR). A formal entry (type 01) is the full process, required above $2,500 and in certain other cases.
The NPRM places itself in a longer sequence that it describes directly:
- Executive Order 14324 (July 30, 2025) suspended duty-free de minimis treatment for all countries.
- The One Big Beautiful Bill Act (OBBBA, enacted July 4, 2025) terminated the statutory de minimis exemption effective July 1, 2027.
- Executive Order 14388 (February 20, 2026) continued the suspension.
- Two interim final rules of June 24, 2026 suspended de minimis in CBP's regulations, effective that day, and set up a postal informal entry process.
We covered those June rules in De Minimis Suspended in 2026. This NPRM is the next layer. Shipments that once moved under the $800 exemption now go through informal entry, and CBP is proposing to tighten that process.
The headline: a bond on every informal entry
Today, most informal entries can be filed without a bond. The NPRM says so plainly: "Currently, for informal entries, including those in the mail environment, bonding is only required in certain situations," and "a basic importation and entry bond is not currently required for all ET11s."
The proposal would end that. In CBP's words, "all entry type 11 and entry type 13 filers must obtain a basic importation and entry bond." Proposed new 19 CFR 143.29 would provide that "Shipments valued at $2,500 or less that must be entered on CBP Forms 3461 and 7501, or CBP Form 7501," "will not be released from CBP custody unless a single transaction or continuous bond" containing the 19 CFR 113.62 conditions "has been secured by an approved corporate surety, or cash deposits." Proposed 19 CFR 145.15 would apply the same condition to mail.
Put plainly: no bond, no release.
The proposal would also set a floor on liquidated damages, the amount the surety and principal owe CBP when a bond condition is breached. Proposed 19 CFR 113.62(n)(6) would set liquidated damages on these low-value entries at "the value of the merchandise involved in the default or $1,000, whichever is greater." For restricted or prohibited merchandise or alcoholic beverages, it would be three times the value or $1,000, whichever is greater. On a $60 parcel, the exposure on a breach would start at $1,000, not at the parcel's value.
How many importers this reaches. CBP's own data puts the number at 68,701 importers of record who filed a type 11 entry without a bond between August 1, 2025 and July 31, 2026. CBP estimates that a bond requirement over that period would have cost those importers an extra $9,276,484 in bond premiums. That is 3.15 percent of the duties, taxes and fees paid on bondless type 11 entries in the period.
The average hides the real burden. CBP also estimates that 59,148 of those importers, the infrequent, low-volume ones, would have preferred single transaction bonds to continuous bonds. For that group, "the total cost of the bond requirement would have been 72.66% of the total duties, taxes, and fees." For an occasional importer, a single transaction bond on each small shipment could cost almost three-quarters as much as the duty itself. Higher-volume importers, for whom a continuous bond is cheaper, "would probably not be significantly affected," according to CBP.
CBP's analysis gives no per-bond premium figure, so neither do we. For how bond amounts and premiums work, see what a customs bond costs and our customs bonds guide.
File before the goods arrive, and file electronically
The second change is about timing, and it may matter more day to day than the bond.
Under current 19 CFR 141.5, merchandise has to be entered within 15 calendar days after landing. The proposal keeps that general rule but adds a paragraph (b) for these low-value entries: they "must be entered upon or prior to the date of importation." The preamble says it more simply: "the new entry filing deadline would be the time of arrival rather than 15 days after arrival."
The proposal also moves type 11 to electronic filing. Today, as the preamble notes, "entry type 11 filers have the option to make entry on paper or electronically." CBP proposes to "require electronic filing for entry type 11," with the filer transmitting "the electronic equivalent of CBP Forms 3461 and 7501, or CBP Form 7501" through a CBP-authorized EDI system. Form 3461 is the entry/release data and Form 7501 is the entry summary. A CBP-authorized EDI system means electronic data interchange through the Automated Broker Interface (ABI), the certified connection into CBP's Automated Commercial Environment (ACE).
CBP is candid about what the timing change costs. Its own analysis says the deadline "could be disruptive," that "the filer may need to employ more people abroad so that they can look at the shipment," and that "the costs of this new procedure could be significant." CBP also notes that under an arrival deadline, "the filer would not be able to use the transit time to gather data and file entry." CBP did not put a dollar figure on these costs.
That is the workflow change to plan around. Today, many low-value importers and their filers use the 15-day window to look at the package, confirm what is in it, classify it and then file. Under the proposal, classification, value, origin and party data would all have to be in hand before the goods land. That information has to come from the supplier, the commercial invoice or your own product catalog, not from the box.
Four more changes in the same proposal
A final deliver-to party. Filers would have to identify the final deliver-to party when that party differs from the ultimate consignee on the entry summary. CBP's stated reason is that "effective targeting requires identifying the party to whom an imported good" is ultimately going. If you sell through a fulfillment center or ship onward to end customers, your entry data would need to carry that destination.
The $250 cap on Chapter 99 goods goes away. Current 19 CFR 143.23(d) keeps articles "valued in excess of $250 classified in Chapter 99, Subchapter III and IV" of the HTSUS out of informal entry. The proposal would remove the $250 reference, so goods valued over $250 but not over $2,500 "would no longer be prohibited from using informal entry procedures." For some importers, this is the one part of the NPRM that opens a door instead of closing one.
Formal entry on a blanket basis. Proposed 19 CFR 143.22 would let CBP "require a formal consumption or appraisement entry for any merchandise or category of merchandise," and the preamble describes doing so "on a blanket basis" by importer of record, manufacturer or category of merchandise. Under the proposal, informal entry would be available unless CBP decides otherwise for your goods, your supplier or you.
Consignees who are not owners must use a broker. Proposed 19 CFR 143.26(a) would require that a consignee who is not the owner or purchaser, which CBP's examples list as "a foreign postal operator, the United States Postal Service, a freight forwarder, or a carrier," "must appoint a customs broker to act as the importer of record for the entry." If your goods currently reach you through an intermediary that enters them in its own name, ask now how that arrangement would work under the proposal.
Mail gets its own entry type: type 13
The proposal creates "a new regulatory entry type 13—Informal Mail Entry" for mail shipments valued at $2,500 or less. It would replace the postal informal entry process in 19 CFR 145.12(b) that took effect after the June 2026 interim final rule. Type 13 would be filed electronically, on or before the date of importation, and would add shipper/sender data.
Two related changes support it:
- Abandonment. Proposed 19 CFR 145.6 says a mail shipment that "remains in CBP custody 15 days after the date of importation will be deemed voluntarily abandoned." Mail that is not entered on time would not wait in a queue. It would be treated as given up.
- Tracking on manifests. Proposed 19 CFR 145.7 would require the party filing the inward manifest to provide "the Universal Postal Union S-10 tracking number" for each mail shipment, matching the number on the entry. CBP says this will "allow CBP to determine the precise time of arrival for each mail shipment," which is how it would check that the entry was filed on time.
The NPRM also states that a CBP test of type 13 "will commence on September 22, 2026." We have not confirmed the status of that test independently. Look for CBP's test notice if you ship by mail.
What does not change, and what is not in effect
The $2,500 informal-entry threshold stays. Proposed 19 CFR 143.21(a) keeps informal entry for "shipments of merchandise not exceeding $2,500 in value."
Nothing here applies to your entries as of October 8, 2026. This is a notice of proposed rulemaking. CBP will review comments and may issue a final rule, revise the proposal or do neither. The NPRM sets no effective date or compliance date. CBP's economic analysis assumes "the rule would take effect" in 2027, but that is a modeling assumption, not a date you can plan against. Any final rule would set its own dates.
Today's bond rules still apply. The current rule on informal-entry bonds, which require a bond only in certain situations, governs until a final rule says otherwise. Do not let anyone tell you that a bond is already required on every type 11 because of this document.
What it means for self-filing versus a broker
Two parts of the proposal apply no matter who files.
The bond belongs to the importer of record. It is not tied to the filer. Under the proposal, you would need a single transaction or continuous bond whether you file your own entries through ABI software or a licensed broker files them for you. Switching from one model to the other would not avoid the bond.
The arrival deadline rewards a data pipeline over a document chase. If your SKUs are stable and your supplier sends classification-ready invoices before shipping, filing at or before arrival is mostly a timing change. If you currently work out what is in each box after it lands, the proposal would push that work upstream, whoever files.
After that, the decision comes down to the usual factors: volume, catalog stability, partner government agency exposure, and whether someone in-house owns the work. Our broker vs. self-filing decision framework goes through them. On price, Strix self-filing runs $30 per entry through our ABI-certified software, and full brokerage runs $100–$250 per entry. Under the proposal, either cost would sit on top of a bond premium, so price both together.
One note for mail shippers. CBP's analysis expects that "most filers of postal entries would be brokers" under type 13. That is CBP's assumption about the market, not a requirement for owners and purchasers filing their own entries.
What to do before December 7, 2026
- Check your bond status. Look at the last 12 months of your type 11 entries in ACE and see how many went bondless. If the answer is "most of them," you are in the group of 68,701 importers CBP counted.
- Compare single transaction and continuous bonds against your actual volume. CBP's own numbers show the gap. Low-volume importers using single transaction bonds would carry most of the burden. Have a surety or broker quote both against your shipment count, not a hypothetical one.
- Test whether you could file at arrival. Take your last month of informal entries and ask when you had the HTSUS code, value and origin for each one. If the answer is often "after it landed," start with your suppliers' pre-shipment documentation.
- Map your deliver-to parties. If goods ship onward from the port to someone other than the ultimate consignee, make sure your data captures that party.
- Revisit Chapter 99 goods between $250 and $2,500. If you file these as formal entries today only because of the $250 cap, the proposal could change that. Re-plan only after a final rule.
- Comment. CBP itself calls the arrival deadline potentially "disruptive" and says its costs "could be significant." The NPRM also describes a less costly alternative that keeps the 15-day window. If your operation would bear those costs, the docket is where CBP has asked to hear about them, and specific, quantified comments are the useful kind. Comments go through regulations.gov under docket USCBP-2026-0298 and must be received by December 7, 2026.
CBP has another open comment period. We covered its supply chain visibility ANPRM separately.
Not because of this proposal. As of October 8, 2026, the NPRM is not in effect, and CBP itself describes current informal-entry bonding as "only required in certain situations." The every-entry bond requirement would apply only if CBP finalizes it, on whatever date a final rule sets. Separate rules may already require a bond for your particular goods, so confirm against your own entries.
When would this take effect?
The proposal sets no date. CBP's cost analysis assumes an effective year of 2027, which is an assumption for the economic model. CBP must first close the comment period on December 7, 2026, review the comments and publish a final rule. That rule would state its own effective and compliance dates.
Is the $2,500 informal-entry limit changing?
No. The proposed text keeps informal entry for shipments not exceeding $2,500. The proposal would remove the separate $250 cap on HTSUS Chapter 99, Subchapter III and IV goods, so those goods could also use informal entry up to $2,500. It would also let CBP require formal entry for specific importers, manufacturers or categories of merchandise.
How do I comment?
Through the Federal eRulemaking Portal at regulations.gov, under docket USCBP-2026-0298. Comments must be received on or before December 7, 2026. Comments that describe your actual entry volumes, your current filing timeline and the cost of moving to filing at arrival tell CBP the most.
How we help
This proposal is still months from any final version, and the importers best placed for it will be the ones who looked at their own entries early, not the ones reacting to the final rule. We can help in four ways:
- Clear: file your informal and formal entries through self-filing at $30 per entry or full brokerage at $100–$250 per entry.
- Consult: review your type 11 history, your bond position and how the proposal would land on your shipments, including whether you have a comment worth filing.
- Comply: put the right bond in place and correct filed entry summaries when needed, with post summary corrections at $150 per entry for up to 10 lines.
- Automate: move classification and party data upstream so an at-arrival deadline is a setting, not a scramble.
CBP decides what the final rule says and how it applies. We handle the filing and the preparation. If you file informal entries without a bond today, talk to our team this month, or start with self-filing or brokerage.
This article describes a proposed rule as of October 8, 2026, its date of publication. Nothing in it is in effect. Check the final rule, if one issues, before changing how you file.