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U.S. Customs and Border Protection (CBP)

Call 305-456-3830 or email info@diaztradelaw.com.

Postal De Minimis Rule Update: CBP Makes the January 20, 2027 Mail Entry Deadline Official and Eases PGA Data for Entry Type 13 

U.S. Customs and Border Protection (CBP) published a final rule in the October 22, 2026 Federal Register that moves the compliance date for the postal rule’s formal entry requirements from October 22, 2026, to January 20, 2027. The same day, CBP modified its Entry Type 13 test so filers can submit an electronic mail entry before their Partner Government Agency (PGA) data is complete. Importers, e-commerce sellers, and licensed customs brokers handling mail shipments subject to PGA requirements, Chapter 98 or 99 duties, or Chapter 98 and free trade agreement claims now have a published date and a lower barrier to start filing Entry Type 13. 

Key Takeaways 

  • On October 22, 2026, CBP published a final rule setting January 20, 2027, as the compliance date for the postal formal entry provisions in 19 CFR 145.12(a)(2)(v) and (vi) (91 FR 66638). 
  • The rule covers mail shipments subject to Partner Government Agency (PGA) requirements, subject to duties under HTSUS Chapter 98 or 99, or claiming duty-free treatment under Chapter 98 or a free trade agreement. 
  • CBP stated that the extension does not change the process currently used for informal mail entries during the delay, and that parties may come into compliance earlier. 
  • In a separate notice effective October […]
By |2026-10-23T16:10:52-04:00October 23, 2026|ACE, Customs Broker, U.S. Customs and Border Protection (CBP)|0 Comments
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IEEPA Refund Class Certified: Why Importers With Significant Phase 3 Refunds Should Still File Their Own Suit 

By Jennifer Diaz and David Craven  |  October 2026 

On October 8, 2026, the U.S. Court of International Trade certified a nationwide class of importers of record that paid IEEPA duties and have not filed their own refund lawsuits, in Freestyle World, Inc. v. CBP, Ct. No. 26-01088. Certification does not issue refunds, and class members do not have access to CAPE Phase 3, which CBP opened on October 6 for finally liquidated entries of importers holding their own court orders. Importers with significant refunds on finally liquidated entries should weigh filing their own case now rather than waiting on the class. 

Key Takeaways 

  • On October 8, 2026, the U.S. Court of International Trade (CIT) certified a class of importers of record that paid IEEPA duties between February 1, 2025, and February 19, 2026, excluding any entity that separately filed its own refund action. 
  • Class certification is not a refund order. The CIT has not entered classwide relief, and further proceedings are pending. 
  • CBP deployed CAPE Phase 3 on October 6, 2026, for finally liquidated entries of importers that filed suit and hold court orders directing reliquidation. Class members do not currently have Phase 3 access through the class. 
  • As of October 19, 2026, the government had not appealed the class […]
By |2026-10-29T09:56:53-04:00October 19, 2026|tariffs, U.S. Customs and Border Protection (CBP)|0 Comments
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Commerce Defines “U.S. Content” for USMCA Steel and Aluminum Articles Under Proclamation 11032 

On October 14, 2026, the Bureau of Industry and Security (BIS) published a Federal Register notice defining “U.S. content” for products of Canada and Mexico that qualify for preferential tariff treatment under the United States-Mexico-Canada Agreement (USMCA), for purposes of the Section 232 duties under clause (2)(d) of Proclamation 11032. The guidance is effective for products entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on October 14, 2026. Importers of Canadian and Mexican aluminum and steel articles listed in Annex I-C to the Proclamation, and the customs brokers and filers who prepare their entries, should review how they value U.S. content before their next entry. 

Key Takeaways 

  • BIS defines U.S. content in two parts: (1) the value attributable to parts wholly obtained, entirely produced, or substantially transformed in the United States; and (2) to the extent not otherwise accounted for in part (1), the value attributable to steel melted and poured, aluminum smelted and cast, and/or copper smelted and cast in the United States. 
  • The guidance applies to entries on or after 12:01 a.m. Eastern Time on October 14, 2026. 
  • Under clause (2)(d), the 25 percent duty applies only to the non-U.S. content of USMCA-qualifying Annex I-C articles of Canada and Mexico, and the total effective duty may not be […]
By |2026-10-15T17:04:23-04:00October 15, 2026|U.S. Bureau of Industry and Security (BIS), U.S. Customs and Border Protection (CBP)|0 Comments
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CBP Proposes Bonds and Earlier Filing for Low-Value Informal Entries: Comments Due December 7 

U.S. Customs and Border Protection (CBP) has issued a Notice of Proposed Rulemaking (NPRM) for Low-Value Shipments that would change informal entry requirements for shipments valued at $2,500 or less, including shipments arriving through international mail. The proposal would add a bond requirement for informal entries, move the Type 11 filing deadline earlier, and create a new electronic Entry Type 13 for mail. Importers, e-commerce sellers, licensed customs brokers, and carriers that handle low-value shipments are affected, and comments are due December 7, 2026. 

Key Takeaways 

  • CBP proposes that all Type 11 (informal) and new Type 13 (informal mail) entry filers obtain a basic importation and entry bond, single transaction or continuous, before release. 
  • The proposed Type 11 filing deadline moves from “within 15 calendar days after landing,” to “upon or before the date of importation”, and Type 11 entries would be filed electronically. 
  • A new Entry Type 13 for international mail of $2,500 or less would be filed electronically by the owner or purchaser in ACE or by a licensed customs broker. 
  • Carriers filing inward manifests would report the mail tracking number, and unentered mail of $2,500 or less would be considered abandoned after 15 days. 
  • Comments are due December 7, 2026, under docket USCBP-2026-0298 on regulations.gov. 

Low-Value Shipments Face New Entry Requirements 

CBP […]

By |2026-10-09T11:49:46-04:00October 9, 2026|ACE, Customs Broker, Import, U.S. Customs and Border Protection (CBP)|0 Comments
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BIS Announces $2 Million Settlement with Lambda Research Corporation for 66 Export Control Violations 

On October 2, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a $2 million administrative settlement with Massachusetts-based Lambda Research Corporation involving 66 alleged violations of the Export Administration Regulations (EAR). The case involved exports of optical and illumination design software, automatic software updates, and transactions with parties on the Entity List and Unverified List. 

Key Takeaways 

  • EAR99 does not mean unrestricted. Even software classified as EAR99 may require an export license when the recipient is on the BIS Entity List. 
  • Automatic software updates can constitute exports. BIS charged Lambda with violations involving software updates transmitted to restricted parties after their addition to the Entity List. 
  • Restricted-party screening must be ongoing. A customer who was not restricted when a transaction began may become subject to licensing requirements later. 
  • Distributors do not eliminate export compliance obligations. Exporters must evaluate the actual end users of their products, including transactions conducted through intermediaries. 
  • The Unverified List creates additional compliance requirements. Certain transactions involving Unverified List parties require a UVL statement even when an export license is not otherwise required. 
  • Informal compliance efforts are insufficient. BIS cited Lambda’s lack of written export compliance procedures, employee training, and designated compliance personnel. 
  • Voluntary self-disclosure does not eliminate penalties. […]
By |2026-10-09T11:35:03-04:00October 9, 2026|EAR, Enforcement, Export, penalty, U.S. Bureau of Industry and Security (BIS), Uncategorized|0 Comments
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