CBP Low-Value Shipment Rules: Type 11 and Type 13

CBP low-value shipment rules may soon impose a more structured entry, bonding, and data framework on shipments valued at $2,500 or less. Customs brokers, e-commerce importers, mail carriers, and drawback claimants should evaluate the proposal now, while recognizing that it is not yet a final rule. ## The Proposed Informal Entry Framework The proposed rule, published October 8, 2026, would revise how qualifying low-value shipments are entered into the United States. Its primary focus is merchandise valued at $2,500 or less that is eligible for informal entry, including goods transported through commercial channels and international mail. ### Proposal Status and Timing The changes remain proposed. No effective date has been established, and businesses should not treat the proposal as an operative filing mandate. Comments are due by December 7, 2026, under docket USCBP-2026-0298. CBP would need to consider public comments and publish a final rule before the proposed requirements generally become binding. This distinction matters because low-value shipment procedures have already been affected by the suspension of the $800 de minimis exemption and related interim measures. The proposed rule addresses the broader informal entry environment that follows those changes. It does not reinstate de minimis treatment or establish a new duty exemption. ### Core Areas of Change The proposal would update several connected elements of informal entry processing: - Electronic filing requirements for Type 11 informal entries

• Earlier filing based on the date of importation
• Identification of the final deliver-to party in specified transactions
• Revised right-to-make-entry requirements
• A formal electronic Type 13 process for international mail
• Carrier and tracking-number data for mail shipments
• Basic importation and entry bond requirements
• Treatment of certain Chapter 99 merchandise within informal entry procedures Taken together, these measures would make low-value entry processing more similar to conventional customs entry operations. Importers and brokers would need stronger controls over classification, party identification, entry timing, bond coverage, and transaction-level records. ## Type 11 Changes and Broker Responsibilities Type 11 informal entry has traditionally supported simplified processing for eligible merchandise below the formal entry value threshold. Under the proposal, that process would become more data-intensive and more closely tied to electronic pre-arrival or arrival-date filing controls. ### Electronic Filing and Deliver-To Data Proposed Type 11 entries would generally need to be filed electronically by or before the applicable date of importation. This could compress the time available to obtain invoices, classify merchandise, validate admissibility, determine Chapter 99 applicability, and identify the proper parties. The filing would also identify the final deliver-to party when that party differs from the ultimate consignee. That distinction can be significant in e-commerce transactions involving marketplaces, fulfillment centers, logistics providers, drop shipments, or residential recipients. Brokers may need to revise intake processes so that the final delivery destination is captured as structured entry data rather than retained only in carrier records. Data quality controls should distinguish among the importer of record, ultimate consignee, purchaser, owner, and final deliver-to party. Treating these roles as interchangeable could create filing errors, screening gaps, or inconsistent audit records. ### Right to Make Entry and Importer of Record The proposal would also tighten who may make informal entry. For certain shipments valued at $2,500 or less, a licensed customs broker would be required to act as importer of record when filing on behalf of a consignee that does not independently qualify to make entry. This approach could materially change broker risk. Serving as importer of record is not merely a data transmission function. It can involve responsibility for entry accuracy, duties, recordkeeping, admissibility, and bond obligations. Brokers should therefore evaluate whether existing powers of attorney, terms of service, client onboarding procedures, and risk controls are sufficient for the proposed model. ## Type 13 Electronic Informal Mail Entry The proposed Type 13 entry would create a standardized electronic process for eligible informal entries arriving through international mail. It would replace or supplement less structured mail procedures by connecting the filer, carrier, shipment, tracking number, and customs entry within an electronic environment. ### Filer and Carrier Data Requirements Type 13 would require additional information from both entry filers and carriers. A central requirement is the ability to associate the customs filing with the carrier's tracking number. Reliable matching would help CBP identify the physical mail article represented by an electronic entry and determine whether the article has been entered, released, held, or otherwise resolved. Operationally, this requires more than adding a field to a filing screen. Brokers and carriers may need controls for tracking-number formats, duplicate numbers, consolidated data, corrections, rejected messages, and shipments transferred between systems. Importers should also assess whether suppliers provide sufficient product descriptions, values, quantities, country-of-origin information, and classification data before importation. A voluntary Type 13 test is already available in ACE production, but test participation and a proposed regulation are not the same as a final legal mandate. Participants should continue following the requirements applicable to the test and current interim framework. ### The 15-Day Entry Period Under the proposal, an unentered informal mail article would generally be deemed abandoned if no entry is filed within 15 days of importation. The article could then be handled through applicable postal procedures, which may include destruction or return. That period creates a practical exception-management challenge. Missing commercial data, uncertain classification, partner government agency requirements, bond problems, or an unresolved importer identity could consume much of the available time. Brokers, mail carriers, and importers should define who monitors unresolved articles, who obtains missing information, and when a shipment should be escalated to a different entry process. ## Bonding, Chapter 99, and Drawback Implications The proposal would require a Basic Importation and Entry Bond for covered informal entries, including Type 11 and Type 13 transactions. This represents a significant compliance shift for businesses accustomed to treating low-value shipments as administratively simple or effectively bond-free. ### Bond Exposure and Chapter 99 Treatment The proposed framework includes a $1,000 minimum amount for liquidated damages associated with specified bond breaches. Actual exposure would depend on the bond terms, transaction facts, and final regulatory language. Brokers and importers should examine continuous and single-transaction bond strategies, underwriting requirements, bond sufficiency, and procedures for resolving entry defects. Bonding also affects transaction economics. A shipment may remain eligible for informal entry based on value, but filing fees, brokerage costs, bond expenses, classification work, and duty liability can make the landed cost substantially different from the former de minimis model. The proposal also addresses the interaction between informal entry and Chapter 99, Subchapter III of the Harmonized Tariff Schedule. This is important because additional duties can apply even when the shipment qualifies for informal entry. Eligibility for simplified entry does not generally eliminate classification, special tariff, origin, admissibility, or duty-payment obligations. ### Duty Drawback Recordkeeping Low-value entries can become relevant to duty drawback when imported merchandise is later exported or destroyed under qualifying conditions. Changes to entry type, importer-of-record identity, bond data, and electronic filing records may affect how a future claimant substantiates the import side of a drawback claim. Importers and brokers should preserve entry numbers, duty amounts, classifications, quantities, countries of origin, commercial invoices, party identities, and inventory links. If a broker acts as importer of record, the parties should clearly address record access and the evidence needed to connect imports with later exports. For drawback planning, informal does not mean immaterial. High shipment volumes can produce substantial aggregate duty exposure, while fragmented records can make recovery difficult even when the underlying transactions may otherwise qualify. ## Preparing for a Possible Final Rule The proposal gives affected businesses an opportunity to model operational consequences before any final requirements take effect. A disciplined readiness review should cover data, staffing, commercial terms, bonds, exception handling, and post-entry records. ### Practical Readiness Priorities Customs brokers should map current Type 11 and mail workflows against the proposed requirements. That review should identify when shipment data becomes available, which party validates it, and whether filing can be completed by the date of importation. Particular attention should be given to final deliver-to details and importer-of-record eligibility. Importers should evaluate whether overseas sellers, marketplaces, consolidators, and carriers can provide accurate product and party data early enough. Generic descriptions such as samples, accessories, or parts are generally inadequate for reliable classification and admissibility analysis. Organizations should also consider the following actions: 1. Estimate Type 11 and Type 13 filing volumes by channel.

2. Identify shipments that may require a broker to act as importer of record.
3. Review bond capacity and potential liquidated damages exposure.
4. Test tracking-number matching and exception workflows for mail.
5. Separate current requirements from proposed future obligations.
6. Preserve import data needed for audit, reconciliation, and drawback analysis.
7. Submit comments by December 7, 2026, if the proposal creates material operational or compliance concerns. Comments are often most useful when they quantify transaction volumes, implementation costs, data limitations, system lead times, and practical alternatives. Until a final rule is published, businesses should continue operating under the current ACE tests, interim rules, and other applicable entry requirements. ## Frequently Asked Questions ### Are the New Type 11 and Type 13 Requirements Effective Now? No. The October 8, 2026 action is a proposed rule, and no final effective date has been set. Existing ACE tests and current interim requirements remain operative. Businesses may prepare for the proposal without treating every proposed element as mandatory. ### What Shipments Would the Proposal Affect? The proposal primarily concerns informal entries for merchandise valued at $2,500 or less. It could affect e-commerce importers, consignees, customs brokers, international mail carriers, and parties entering goods through Type 11 or the proposed Type 13 process. ### Would Every Low-Value Shipment Require a Customs Broker? Not necessarily. The required filing party would depend on the right-to-make-entry rules, ownership or purchaser status, and the specific transaction. The proposal would, however, require a licensed customs broker to act as importer of record for certain informal entries. ### Why Do These Changes Matter for Duty Drawback? Drawback claims depend on supportable import and export records. Changes to entry type, importer identity, duty data, and bond information can affect how imported merchandise is traced to qualifying exports or destruction. Early record design can reduce later substantiation problems. ### Does Informal Entry Eliminate Chapter 99 Duties? Generally, no. Informal entry is a processing method, not a blanket exemption from additional tariffs. Importers must still determine whether Chapter 99 provisions apply and calculate duties based on the classification, origin, and applicable tariff measures. ## How Stable Software Can Help ### Strengthening Drawback Readiness The proposed low-value shipment framework increases the importance of preserving entry-level data for merchandise that may later be exported. Customs brokers need a practical way to support importer clients while maintaining control over filing relationships and economics. DrawbackAI is Stable Software's flat-license duty drawback software for U.S. customs brokers. Brokers can white-label the software for importer clients and file drawback claims under their own filer code. Stable Software charges a flat software license and never takes a percentage of the refund. Brokers assessing the drawback implications of Type 11 and Type 13 activity can explore how DrawbackAI fits into a scalable client service model.

Resources