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CBP Entry PRA Revision Expands GBI and Entry Type 13

Reis Renneker

Written by Reis Renneker

CBP’s entry collection revision expands voluntary GBI data, adds sanctions fields, and incorporates the ACE Entry Type 13 mail test.

CBP Entry PRA Revision Expands GBI and Entry Type 13

The CBP Entry PRA revision brings several consequential entry-data changes into a single information collection framework. For ACE filers and customs brokers, the revision highlights expanding Global Business Identifier options, new Russian sanctions fields, updated Form 3461 instructions, and a voluntary electronic pathway for informal mail entries.

What the CBP Entry PRA Revision Covers

The revision applies to OMB Control Number 1651-0024, which encompasses entry and immediate delivery packages submitted through CBP Forms 3461 and 3461 ALT. It also covers data transmitted electronically through ACE Cargo Release in lieu of the traditional form by eligible ACE entry summary filers.

CBP issued the 30-day notice on October 1, 2026, following a 60-day notice published on July 1, 2026. Comments on the collection are due no later than November 2, 2026. As a Paperwork Reduction Act process, the review focuses on the necessity, utility, burden, and practical administration of the information collection rather than functioning as a standalone operational rule.

Three Changes Matter Most to ACE Filers

The revision consolidates three important developments. First, it incorporates recently approved changes to the voluntary Global Business Identifier, or GBI, data framework. These changes expand available supply chain party types and provide greater flexibility in the identifiers that filers may submit.

Second, the collection adds data elements associated with Russian sanctions requirements under Executive Order 14114. Form 3461 and Form 3461 ALT instructions have also been revised to address these fields and improve clarity.

Third, the revision includes the voluntary ACE informal mail Entry Type 13 test. This test creates an electronic entry option for qualifying international mail shipments valued at $2,500 or less. It is particularly relevant where a low-value mailed shipment cannot use the interim informal mail process because partner government agency data or duties outside the ordinary Chapter 1 through 97 tariff structure apply.

The collection is operationally significant because ACE Cargo Release handles a substantial volume of annual transmissions. Brokers should therefore treat field-level changes as workflow, data-governance, and client-onboarding issues, not merely as form revisions.

GBI Expansion Adds Parties and Identifier Flexibility

The Global Business Identifier initiative is intended to improve CBP’s ability to identify legal entities and other participants across international supply chains. Under the expanded framework, filers may voluntarily provide more detailed party information within GBI enrollment and ACE Cargo Release submissions.

Two optional party types, “Intermediary” and “Source”, are being added. Each may include an optional free-text description, enabling a filer to provide context about a party’s actual supply chain role when a standardized label alone may be insufficient.

Filers No Longer Need All Three Existing Identifiers

A central change is the ability to submit one or more of the following identifiers for a supply chain entity rather than all three:

  • Legal Entity Identifier, or LEI
  • Global Location Number, or GLN
  • Data Universal Numbering System identifier, or DUNS

CBP also plans to add the Altana ID, identified as ALTA, as another identifier choice. GBI participation and the related data elements remain voluntary, including the newly added party types and descriptive fields.

That flexibility can reduce a practical barrier to participation because organizations do not always maintain every recognized identifier across suppliers, manufacturers, intermediaries, and other commercial parties. It may also allow importers and brokers to begin with available data rather than postponing enrollment until every identifier has been obtained.

Voluntary, however, does not mean operationally insignificant. Brokers should define which clients will participate, which party records qualify for submission, and who is responsible for validating identifiers. Importers should similarly consider how GBI records align with vendor master data, purchase orders, commercial invoices, denied-party screening, and country-of-origin controls.

Free-text descriptions require particular discipline. Inconsistent descriptions can weaken data quality and complicate later analysis. A controlled vocabulary, documented ownership, and periodic review can help prevent the optional fields from becoming an unstructured repository of conflicting party information.

Entry Type 13 Creates an ACE Path for Informal Mail

The voluntary Entry Type 13 test provides an electronic ACE option for merchandise valued at $2,500 or less and sent to the United States through the international mail system. It serves as an alternative to the interim informal mail entry process and creates a route for certain shipments that may otherwise be ineligible for that process.

This distinction matters for low-value mail subject to partner government agency requirements or additional tariff measures. A shipment’s value alone does not determine whether it can move through a simplified process. Commodity classification, agency admissibility requirements, special tariff provisions, and additional duties may still require structured entry data.

Required Entry Type 13 Data

An Entry Type 13 transmission generally includes:

  • Filer code
  • Importer of record number
  • Merchandise description
  • Country of origin
  • All applicable 10-digit HTSUS classifications
  • Quantity and weight when a specific duty rate applies
  • Duty rate
  • Entered value
  • Total duty owed
  • Carrier name
  • Tracking number assigned by the foreign postal operator
  • Arrival port

Participation is available to owners or purchasers of mailed merchandise and to licensed customs brokers appointed as the importer of record. Carriers may transmit foreign postal tracking numbers through manifest data, which makes tracking-number coordination an important part of the filing workflow.

For brokers, the test requires more than mapping another entry type in ACE. Intake processes must capture classification, value, origin, tracking, duty, and agency data early enough to support release. Broker appointment and importer-of-record responsibilities also need to be resolved before transmission. More detailed Entry Type 13 operational guidance can help teams evaluate the filing path.

The estimated collection burden reflects the potential scale of the test: 10 respondents, approximately two million annual responses, and 166,667 burden hours. These are PRA estimates rather than forecasts of actual adoption, but they indicate that CBP anticipates a high-volume environment among a comparatively small initial participant group.

Recent Developments
  • October 1, 2026: CBP published 30-day PRA notices for revisions to the Entry (OMB 1651-0024) and Entry Summary collections, incorporating GBI expansions and the Entry Type 13 Test, with comments due November 2, 2026.
  • The Entry Type 13 Test for a new electronic informal mail entry process in ACE commenced on September 22, 2026, for shipments valued at $2,500 or less.
  • September 30, 2026: CBP issued CSMS #70076746 moving ACE CATAIR implementation guides for the Entry Type 13 Test from draft to current capabilities sections.
  • The PRA revision expands the GBI Test by adding two new optional party types (Intermediary and Source) plus free-text fields, and initiating addition of the Altana ID identifier.
  • October 22, 2026, remains the delayed compliance date after which certain low-value mail shipments subject to PGA requirements or Chapter 98/99 duties require formal entry unless filed as Type 13.

Frequently Asked Questions

What Is the CBP Entry PRA Revision?

The revision updates the federal information collection covering Forms 3461 and 3461 ALT, entry and immediate delivery packages, and electronic ACE Cargo Release submissions. It incorporates GBI changes, Executive Order 14114 data fields, revised form instructions, and the voluntary Entry Type 13 mail test under OMB Control Number 1651-0024.

Is Global Business Identifier Participation Mandatory?

No. GBI participation and its related data remain voluntary. Filers may submit one or more supported identifiers for a supply chain entity, and the Intermediary and Source party types are optional. Organizations should nevertheless establish validation and governance procedures before adding voluntary party data to production filings.

Which Shipments May Use Entry Type 13?

The test generally covers merchandise valued at $2,500 or less that is sent to the United States through the mail. It can provide a pathway for shipments involving partner government agency data or duties that make them ineligible for the interim informal mail process. Eligibility should be reviewed shipment by shipment.

Who May File an Entry Type 13 Transmission?

The test is open to owners or purchasers of the mailed merchandise and licensed customs brokers appointed as the importer of record. Carriers may provide postal tracking numbers through manifests, but that transmission does not replace the participating filer’s responsibility for complete and accurate entry data.

When Are Comments on the Revision Due?

Comments are due no later than November 2, 2026, through the federal 30-day Paperwork Reduction Act review portal. Relevant comments may address whether the collection is necessary, whether burden estimates are reasonable, how data quality could be improved, and how filer burden could be reduced through automation or clearer instructions.

How Stable Software Can Help

A Flat-License Duty Drawback Platform for Brokers

Entry-data changes reinforce the importance of structured, reusable customs information across the import lifecycle. Accurate importer, classification, origin, value, and entry records can also support downstream duty drawback analysis when imported merchandise is later exported or destroyed.

Stable Software offers DrawbackAI, flat-license duty drawback software that U.S. customs brokers can white-label for importer clients. Brokers file under their own filer codes, maintain the client relationship, and pay a flat software license rather than surrendering a percentage of the refund. Customs brokerage firms evaluating how to expand drawback services can learn more about Stable Software’s approach for customs brokers.

Resources

TypeResource
Federal RegisterFR Doc. 2026-20170, CBP Entry information collection revision (Forms 3461 and 3461 ALT)
PRA commentsOMB 30-day comment portal for Entry collection 1651-0024

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