Pre-compliance Archives - Customs & International Trade Law Firm

De Minimis, Codified: CBP Finalizes the Postal Suspension Rule — July 24 Comment Deadline
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De Minimis, Codified: CBP Finalizes the Postal Suspension Rule — July 24 Comment Deadline
Import, Pre-compliance, tariffs, Trade Policy, U.S. Customs and Border Protection (CBP)

De Minimis, Codified: CBP Finalizes the Postal Suspension Rule — July 24 Comment Deadline

KEY TAKEAWAYS

De minimis is not new news — the $800 duty-free exemption was already suspended for all countries on August 29, 2025. What’s new is CBP’s interim final rule codifying the postal piece and creating a formal postal informal entry process.
Two key dates: the postal IFR takes effect July 24, 2026 (compliance by October 22, 2026), and public comments on the rulemaking are due July 24, 2026.
If your business ships low-value parcels by mail, the entry mechanics are now being locked into regulation. The comment window is your one chance to shape them before they harden.

De Minimis Is Over. Now CBP Is Writing the New Rules.

For years, the de minimis exemption was the quiet engine of e-commerce: shipments valued at or under $800 entered the United States free of duty and with minimal formality. That era already ended. As we covered in De Minimis No More: What It Means for Importers and Consumers, a July 30, 2025, Executive Order suspended duty-free de minimis treatment for all countries effective August 29, 2025, accelerating the repeal that the 2025 budget law had set for July 1, 2027.

So the headline is not that de minimis is ending — it ended ten months ago. The development now is regulatory: CBP is codifying how low-value shipments, particularly through the international mail channel, must be […]

By Jennifer Diaz|2026-06-29T09:44:50-04:00June 29, 2026|Import, Pre-compliance, tariffs, Trade Policy, U.S. Customs and Border Protection (CBP)|0 Comments

CBP Seized Your Goods at the Border: Your Options and Next Steps
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CBP Seized Your Goods at the Border: Your Options and Next Steps
Enforcement, Import, International Trade, Pre-compliance, U.S. Customs and Border Protection (CBP)

CBP Seized Your Goods at the Border: Your Options and Next Steps

For more information on this topic, check out our webinar: ‘Goods Detained or Seized by CBP? Understand Your Options.” Watch here.

Summary: When CBP seizes imported goods at the border, importers have several options — including filing a Petition, submitting an Offer in Compromise, or pursuing court action. This article explains the difference between detention and seizure, outlines the steps importers should take immediately after receiving a CBP Seizure Notice, and describes how a customs attorney can help recover seized merchandise and prevent future seizure.

Importers expect the import process to run smoothly, but when a product is not compliant with U.S. laws and regulations, CBP is authorized under 19 CFR Part 162 and 19 CFR Part 151 to detain or seize goods upon importation.

When goods arrive at a U.S. port of entry, CBP has the authority to detain a shipment if there is a question about its admissibility or compliance with U.S. laws and regulations. Detention is not the same as seizure. It is a temporary hold that gives CBP time to review the shipment and allows the importer to respond. During this window, a customs attorney can communicate directly with CBP on your behalf, provide the documentation or legal arguments needed to resolve the issue, and work to get your goods released before the situation escalates.

If you do not respond effectively, CBP may move forward with a formal […]

By Jennifer Diaz|2026-08-21T14:21:54-04:00June 19, 2026|Enforcement, Import, International Trade, Pre-compliance, U.S. Customs and Border Protection (CBP)|0 Comments

The CPSC eFiling Deadline is Right Around the Corner!
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The CPSC eFiling Deadline is Right Around the Corner!
ACE, Import, Pre-compliance, U.S. Consumer Product Safety Commission (CPSC), U.S. Customs and Border Protection (CBP)

The CPSC eFiling Deadline is Right Around the Corner!

Summary: On December 18, 2024, the CPSC voted to approve a Final Rule requiring importers of regulated consumer products to electronically file Certificate of Compliance data at the time of entry. The rule takes effect July 8, 2026, for most imported consumer products. This article covers what the CPSC eFiling requirement means for importers, and the steps businesses should take now to ensure compliance before the deadline.

On July 8, 2026, the CPSC’s mandatory eFiling requirements take effect for most imported consumer products. That means importers can no longer wait to be asked for a Certificate of Compliance. These certificates must now be electronically filed in CBP’s Automated Commercial Environment (ACE) at the time of entry, not after the fact.

Importers that are not compliant with the applicable effective date may experience delays in the release of their shipments and increased scrutiny by CPSC at the port of entry. For products entering from a Foreign Trade Zone, the compliance date is January 8, 2027.

CPSC’s eFiling Proposal

Since 2008, importers have been required to maintain Certificates of Compliance stating that the product they are importing meets all applicable safety standards. However, these certificates did not need to be filed at the time of import.

In June 2022, CPSC announced a Beta Pilot test with CBP for the eFiling of certificate data for regulated […]

By Jennifer Diaz|2026-06-30T19:04:46-04:00June 18, 2026|ACE, Import, Pre-compliance, U.S. Consumer Product Safety Commission (CPSC), U.S. Customs and Border Protection (CBP)|0 Comments

Importer End-of-Year Checklist: How to Strengthen Compliance and Prepare for the Year Ahead
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Importer End-of-Year Checklist: How to Strengthen Compliance and Prepare for the Year Ahead
Best Practices, Import, International Trade, Pre-compliance, U.S. Customs and Border Protection (CBP)

Importer End-of-Year Checklist: How to Strengthen Compliance and Prepare for the Year Ahead

For U.S. importers, the end of the year is a critical moment to evaluate compliance, correct issues, and prepare for the year ahead. With tariff changes, supply chain uncertainty, and an increased focus on enforcement, importers who take a proactive approach now will start the new year strong. Here’s a practical checklist for your year-end review.

1. Review Import Data for Accuracy

Begin with a thorough audit of your import data. Confirm that HTS classifications are correct and current, declared values accurately reflect your transactions, and country-of-origin determinations are well documented. Small mistakes can lead to large penalties.

2. Reassess Tariffs and Duty Exposure

Year-end is the ideal time to evaluate whether you are paying unnecessary duties and explore your options for tariff mitigation strategies. Consider what exclusions have changed, whether tariff engineering may reduce costs, or whether sourcing strategies should be updated. Many importers discover duty-saving opportunities simply by reassessing their tariff positions annually.

3. Strengthen Forced Labor Compliance

With UFLPA enforcement intensifying, importers must confirm that supplier information, ownership structures, and supply chain documentation are up to date. Now is the time to verify traceability records, refresh internal training, and assess whether high-risk suppliers require additional review.

4. Update Written Compliance Procedures

If your compliance manual or SOPs haven’t been updated this year, they’re likely outdated. Written processes should reflect current regulations, product updates, tariff changes, and internal workflow adjustments. CBP expects importers to document their […]

By Jennifer Diaz|2025-12-22T09:00:19-05:00December 22, 2025|Best Practices, Import, International Trade, Pre-compliance, U.S. Customs and Border Protection (CBP)|0 Comments

Jewelry Company Charged in $86M Duty Evasion Scheme
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Jewelry Company Charged in $86M Duty Evasion Scheme
Enforcement, Import, International Trade, Pre-compliance, U.S. Customs and Border Protection (CBP)

Jewelry Company Charged in $86M Duty Evasion Scheme

On November 17, 2025, the owner of an Indonesian jewelry company (USB Gold) and two employees were charged with taking part in a scheme to evade over $86 million in duties on jewelry imports.

The employees were arrested and charged with one count of conspiracy to commit wire fraud and were detained. The company co-owner, who was also charged, remains in Indonesia and has not yet been arrested.

The defendants allegedly engaged in a complex scheme to import over $1.2 billion of jewelry and illegally defraud the United States out of more than $86 million in customs duties and tariffs.

The alleged scheme included two parts:

First, UBS Gold made jewelry in Indonesia and shipped it to Jordan, which had a Free Trade Agreement with the United States, before sending it to the United States. The defendants then falsely claimed that UBS Gold jewelry had been manufactured in Jordan, which avoided the duty that would otherwise apply.
Second, when the U.S. announced additional tariffs on Indonesia and Jordan earlier this year, the company began shipping scrap gold from the U.S. to Jordan, which they falsely claimed was gold jewelry that simply needed to be assembled or finished in Jordan. Instead, the defendants and co-conspirators swapped the scrap gold for UBS Gold jewelry made in Indonesia, which they then shipped from Jordan to the U.S. The […]

By Jennifer Diaz|2025-11-26T07:43:19-05:00November 26, 2025|Enforcement, Import, International Trade, Pre-compliance, U.S. Customs and Border Protection (CBP)|0 Comments

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