After de minimis: bulk import to a 3PL or ship parcels direct from Asia

October 13, 2026 · Flyglow Global Team · 11 min read

A $45 order shipped from a factory in Shenzhen or Ho Chi Minh City to a customer in Ohio used to clear US customs duty-free. Since August 2025 that parcel pays duty and needs its own customs entry, and the rule now has a court ruling, a CBP regulation and a 2027 statute behind it. If you sell under $800 per order from Asia, the real decision is whether you keep clearing parcels one by one or bring stock into the US in bulk and ship from a 3PL. This guide compares the three models with the fees that actually change, a worksheet you can fill in with your own numbers, and three buyer scenarios.

Key takeaways

• De minimis is suspended for every country and every mode, and the statutory repeal takes effect on July 1, 2027. Plan as if it is not coming back.
• Every direct parcel now needs an entry. The CBP fee for an automated informal entry is $2.77 from October 1, 2026, before duty and before your carrier's clearance charge.
• Bulk import replaces thousands of entries with one formal entry, but you need a customs bond, you pay for freight and storage up front, and your cash sits in inventory longer.
• DDP parcel programs move the paperwork off your desk, not the risk. Ask who the importer of record is and what value is declared.
• Pick per SKU, not per company: fast movers usually belong in a US warehouse, while the long tail can stay on parcels.

Where de minimis stands in October 2026

Section 321 of the Tariff Act let a person import goods worth up to $800 per day without duty or a formal entry. CBP says it processed over 1.36 billion de minimis shipments in fiscal year 2024, almost ten times the 2015 volume. Here is how the exemption was shut down.

The detail many sellers miss is the June 2026 rule. CBP states that its regulatory suspension would stay in place even if the executive order were changed before the 2027 repeal. Waiting for a court to bring the $800 exemption back is not a plan.

Model 1: direct parcels from Asia

The factory, or a fulfillment node near it, packs each order and hands it to an express carrier or the postal network. Each parcel is cleared on arrival.

CBP has suspended the Entry Type 86 test, so Entry Type 11 informal entry is now the main route for formerly de minimis parcels. Type 11 needs more data than the old release from manifest: classification, value, origin and a party qualified to make entry. Under CBP's fiscal year 2027 user fee notice, each automated informal entry carries a $2.77 processing fee from October 1, 2026. Your carrier or broker adds its own charge on top, and duty is paid on every parcel.

Postal shipments are not a way around it. Since July 24, 2026, mail goes through a new postal informal entry process where the filer must be a party with the right to make entry, such as a licensed broker, and must report a bond number and 10-digit HTS codes.

Direct parcels fit low or unpredictable volume, a wide catalog with few units per SKU, product tests, and goods with high value per kilo where air parcel postage is a small share of the price.

Watch the limits of informal entry. Under 19 CFR 143.21, articles valued over $250 that are classified in Chapter 99, Subchapters III and IV of the tariff schedule (the temporary additional-duty chapter) cannot use informal entry, so some higher-value parcels may need a formal entry. Splitting one order into several parcels to stay under a limit is the kind of pattern CBP looks for.

Model 2: DDP parcel programs

A consolidator or cross-border logistics company collects orders in Asia, flies them in bulk, and clears them on arrival on a "delivered duty paid" basis. You pay one per-parcel price that includes duty and clearance, and your customer pays nothing at the door.

This suits sellers who want the speed and low inventory of direct shipping without running entries themselves, and who are not ready to hold US stock.

The catch: somebody is still the importer of record, and somebody declares a value. CBP reports that goods entered under the old Type 86 test were often undervalued or misclassified. If a DDP price looks far below what duty on your product should cost, ask why. Before you sign, get written answers to these questions:

• Who is the importer of record on each entry, and in whose name is the bond?
• What value is declared: your sale price to the customer or a lower figure?
• Which HTS codes are used for your products, and who reviews them?
• Who pays if CBP later assesses more duty or a penalty?

Model 3: bulk ocean or air into a US 3PL

You ship cartons or pallets by ocean or air freight, clear them with one formal entry, store them in a US warehouse, and ship each order domestically.

Formal entry pays the merchandise processing fee at 0.3464% of value, with a $34.58 minimum and a $670.86 maximum per entry from October 1, 2026, per the same CBP fee notice. Ocean cargo also pays the harbor maintenance fee of 0.125% of value. Formal entry requires a customs bond under 19 CFR 142.4, and ocean shipments need an Importer Security Filing at least 24 hours before loading at the origin port.

The duty base can differ too. Customs value normally starts from transaction value: the price paid when the goods are sold for exportation to the United States. For bulk stock bought from a factory, that is usually the factory price. For a parcel sold straight to a consumer, the relevant sale is often the consumer sale. Confirm with your broker how this applies to your setup, because it can change the duty per unit more than any fee does.

Container rates move every week. Drewry's World Container Index for October 8, 2026 put Shanghai to Los Angeles at $7,624 per 40ft container, down 3% on the week. Our guide to FCL, LCL and air freight from Asia covers choosing the mode.

The costs are cash and time. Money is tied up from the factory deposit until the last unit sells. You also pay for storage, and you carry the risk of slow movers sitting in a warehouse.

Side-by-side comparison

A per-order cost worksheet

The table below is an illustration, not a quote. It uses assumed inputs: a product that sells for $60 to a US consumer and costs $15 from the factory, an assumed combined duty rate of 20%, and 5,000 units shipped in one ocean container at the October 8, 2026 Drewry spot rate. Replace each assumption with your own HTS rate, freight quote and carrier fees.

The fixed lines show why bulk often wins on fees for proven products. The open lines decide the answer: international parcel postage against freight plus 3PL storage, pick-pack and domestic postage. Fill them in for your top ten SKUs before you move anything.

Use this checklist to sort each SKU:

1. Does the SKU sell at least a carton's worth every few weeks, with a forecast you trust?
2. Is your duty rate high enough that a lower duty base changes the margin?
3. Can you fund inventory for the full ocean transit plus the time it takes to sell through?
4. Is the product bulky or heavy, so per-parcel air postage is a large share of the price?
5. Do you, or a broker acting for you, have a bond and a clean HTS classification?

Three or more "yes" answers point toward bulk import for that SKU. Mostly "no" means parcels, direct or DDP, are still the safer choice.

Buyer scenarios

A homeware brand has 40 SKUs and steady sales. Most revenue comes from 12 SKUs that sell every week. Those move to ocean freight into a US 3PL, and a continuous bond covers repeat entries. The other 28 stay on parcels until they prove demand.

An accessories seller has a $35 average order and light products. Parcel postage per order is small, but $2.77 plus a carrier clearance fee and duty on every parcel adds up. The seller tests a DDP program for three months and asks for the declared values in writing, then compares the landed cost per order with a small air freight shipment into a US 3PL.

A new brand is testing products from a Vietnam factory. Demand is unknown and cash is short. Direct parcels make sense for the first runs, using a licensed broker for entries. Once a product reorders twice, the seller consolidates cartons at an origin warehouse, books an air freight shipment into a US 3PL, and moves to ocean freight as volume grows.

FAQ

Is de minimis coming back for US imports?

Not on current law. The statutory repeal in the One Big Beautiful Bill Act takes effect on July 1, 2027, and CBP has written the suspension into its own regulations until then. The Court of International Trade upheld the suspension on August 13, 2026.

Does the suspension apply to goods from every country?

Yes. Since August 29, 2025, duty-free de minimis treatment is suspended for all countries, not only China. It also covers postal shipments, which have used the new postal informal entry process since July 24, 2026.

What is the difference between informal and formal entry?

Informal entry is allowed for shipments valued at $2,500 or less, with some exceptions for goods carrying additional Chapter 99 duties above $250. Formal entry applies above $2,500, requires a customs bond, and pays the merchandise processing fee as a percentage of value with a minimum and maximum.

Who pays duty under a DDP parcel program?

The program collects duty in its per-parcel price and pays it to CBP as, or through, the importer of record. If the declared value or classification is wrong, CBP can assess more duty or a penalty. Get the importer of record, declared value basis and liability terms in writing.

Can I split a large order into several parcels to keep entries informal?

Splitting shipments to avoid entry requirements or limits is a pattern CBP watches for. Plan entries around how the goods are actually sold and shipped, and ask a licensed broker before changing parcel patterns.

When does bulk import into a 3PL not pay off?

When a SKU sells slowly, when cash is too tight to hold several months of stock, or when duty rates are low and the product is light. In those cases the storage cost and inventory risk can outweigh the savings on fees and duty base.

Next step

Pull your top SKUs, their HTS codes and last quarter's order data, and run them through the worksheet above. If you want help comparing options, Flyglow handles parcel shipping from Asia, ocean and air freight, customs brokerage and e-commerce fulfillment, and can price both routes for the same SKUs. Request a quote with your SKU list and monthly order volume.