CBP Proposes Bonds for Every Low-Value Import

U.S. Customs and Border Protection proposed on Oct. 8 that low-value imports under $2,500 need a bond and be filed electronically before arrival, with comments due Dec. 7.

I track rules like this for operators at Ecommerce Paradise, and if your Shopify store has any overseas sourcing, this lands on you or on your supplier. Parts, accessories, samples and direct-ship items that move by mail or express would pick up bond costs, earlier paperwork and a licensed broker requirement if you are not the owner of the goods. A separate CBP rule already tightens the mail channel on Oct. 22, 11 days from now, for goods that carry certain tariff chapters or agency requirements.

Most high-ticket dropshipping runs on US suppliers, so plenty of stores sit outside this. The ones that source overseas, or that rely on a supplier who ships parcels by mail, do not. Here is what CBP proposed, how the Oct. 22 date fits in, the cost math, and five moves for this week. If you are new to the model, start with my guide to what high-ticket dropshipping is, then come back to this one.

If you are about to import under your own name, form your LLC with Northwest, the best LLC formation service for ecommerce owners, before you become the importer of record. The address on an LLC filing is where plaintiffs and regulators look first, and a registered agent address keeps yours off the public record. Form your LLC with Northwest →

CBP Proposes Bonds and Pre-Arrival Filing for Imports Under $2,500

CBP published the proposed rule, titled “Low-Value Shipments,” in the Federal Register on Oct. 8 as 91 FR 64532 under docket USCBP-2026-0298. It covers informal entries, which means merchandise valued at $2,500 or less. Comments are due Dec. 7, according to the notice.

The biggest change is timing. Non-postal informal entries (called Type 11, and including express and other carriers per the notice) and a new mail entry (Type 13) would have to be filed electronically “upon or prior to the date of importation,” replacing the current 15-day window, according to a summary from customs broker GHY. Paper filing would end.

The second change is a bond. Every Type 11 and Type 13 filer would need a basic importation and entry bond, either single-transaction or continuous. “CBP proposes that shipments not be released without a bond meeting 19 CFR 113.62,” wrote Jennifer Diaz of Diaz Trade Law in a Oct. 9 analysis. The proposal sets a $1,000 minimum in liquidated damages for each breach of a listed bond condition, and Diaz notes CBP could raise the single-transaction bond floor from $100 to $1,000.

Mail gets its own penalty. Unentered mail valued at $2,500 or less that has no entry within 15 days of importation would be deemed voluntarily abandoned, and the Postal Service would then handle disposition, which can mean destruction or return to the sender. A consignee who is not the owner or purchaser would have to appoint a licensed customs broker as importer of record, with exceptions for bona fide gifts and personal or household articles.

Two smaller provisions matter to product sellers. The notice would drop the $250 informal-entry cap for certain Chapter 99 goods, so those goods valued up to $2,500 could use informal entry. It would also let CBP require formal entry on a blanket basis, by importer, manufacturer or product category.

The numbers CBP published

CBP projects about 32.7 million postal shipments and 70.1 million Type 11 entries a year, extrapolated from September 2025 through May 2026 data. GHY reports that about 2.3 million Type 11 entries were filed without a bond between August 2025 and July 2026, equal to 3.31% of projected 2026 annual entries. CBP found a single-transaction bond would be cheaper for 86% of the 68,701 importers involved, per GHY, and the other 14% filed 96% of the bondless entries.

For 59,148 importers, GHY says CBP estimates bond costs would equal 72.66% of their duties, taxes and fees. That is a broker’s reading of a dense notice, so check the figure against the Federal Register text before you quote it. CBP also assumes brokers would charge about $30 more per postal entry, and it puts the 10-year net present value of costs at about $9.30 billion at a 3% discount rate and $7.72 billion at 7%.

CBP’s stated reason: “CBP requires an electronic process for informal entries in order to effectively process data.” EY’s tax news summary adds that applying legacy informal rules to ecommerce “creates significant enforcement gaps.”

From De Minimis to Entry Type 13: How CBP Reached This Rule

This notice is the third step in a sequence. CBP’s own mail guidance says most mail merchandise has lacked de minimis eligibility since Executive Order 14324 on July 30, 2025. On June 24, 2026, CBP published an interim final rule at 91 FR 37801 that indefinitely suspended de minimis for mail shipments and created a postal informal entry process for mail valued at $2,500 or less.

That process took effect July 24. Filers send a monthly spreadsheet by the 7th day of the month after arrival and pay duties through Pay.gov, according to CBP’s July guidance. Only the owner, the purchaser or a licensed broker can file, and a bond must be on file first. CBP opened a voluntary Entry Type 13 test in its ACE system on Sept. 22, per trade press and CBP guidance.

Oct. 22 is the next hard date. The interim rule states: “The compliance date for 19 CFR 145.12(a)(2)(v) and (vi) is on October 22, 2026.” After that, mail that is subject to partner government agency requirements, carries Chapter 98 or 99 duties, or claims duty-free treatment under Chapter 98 or a free trade agreement can no longer use the postal informal process. It needs Type 13 or formal entry. Customs City, a trade publication, notes that Chapter 99 is where Section 201, 232 and 301 duties sit.

The Consumer Product Safety Commission is moving on the same day. A Sept. 1 CPSC bulletin says the agency will require eFiled certificates for mail shipments starting Oct. 22. Separately, the statutory end of de minimis arrives July 1, 2027 under Pub. L. 119-21, as the proposed rule notes in its background.

I covered the consumer-side fallout when Shein’s profit dropped 67% as duty-free shipping ended. This notice is the compliance side of the same story.

The counterpoint

Nothing in the proposal is in effect today, as Diaz states plainly. The comment period runs to Dec. 7, and the final text can change. The coverage I read reports no organized pushback yet, so I cannot tell you where trade groups or carriers will land. CBP itself, per GHY, says it cannot certify that the rule avoids a significant impact on a substantial number of small businesses. Diaz expects small businesses and newer importers to feel it most.

What CBP’s Bond Math Means for Stores With Overseas Suppliers

My read: the bond is the cost that surprises small importers, and the earlier filing deadline is the operational headache. Customs duty was already a cost of doing business after de minimis closed. A bond, a broker and pre-arrival data are new fixed costs that do not scale down with a small parcel.

Here is hypothetical math, not reported figures. Say your store pulls in 40 overseas parcels a month and a broker files each at CBP’s assumed $30. That is $1,200 a month, or $14,400 a year, before any duty. On a $300 accessory kit, $30 is 10% of the product value. On a $1,500 part it is 2%. Low-ticket stores get hurt first, which is one more reason I keep telling people high-ticket beats low-ticket.

On the bond itself, the notice’s cost tables, as I read them, put continuous bonds at a minimum of $50,000 with premiums around 0.883%. If that holds, the minimum works out to roughly $441 a year. That is my arithmetic from figures in the notice, so confirm real quotes with a surety before you plan around it.

The bigger exposure is who ends up as importer of record. If your supplier ships direct to your customer by mail and the customer is not the owner or purchaser, the proposal pushes a licensed broker into the chain. Ask your supplier today who files, who holds the bond and who pays the broker. If the answer is “I don’t know,” your margin has a hole in it.

Scenarios worth running. If a SKU carries Section 232 or 301 duties, the Oct. 22 date matters now, because that mail can no longer use the cheap postal process. If a SKU ships by freight from a US warehouse, almost none of this touches you. Stores in furniture and cabinets should also watch the cabinet tariff increase set for Jan. 1, because duty and paperwork costs stack.

Winners are stores with US-warehoused inventory. Their competitors who ship parcels from overseas lose their pricing edge as landed cost rises. My breakdown of the 77 Chinese goods named for tariff cuts shows how much SKU-level detail matters here, because a cut on one HTS line does nothing for the next.

Tools help at the edges. Easyship quotes duties and taxes at checkout so you stop eating them. Clean tracking data will matter once entries are filed before arrival, which makes AfterShip more than a customer convenience.

For paying overseas suppliers, Wise is one option. Airwallex is another.

My Airwallex setup guide covers the cross-border side.

The cleanest fix is to avoid the problem. Source from US authorized dealers who ship from domestic warehouses, and the importer-of-record question belongs to them. That is how I build stores, and it is the reason my team’s turnkey done-for-you build starts with supplier selection instead of a theme.

I am not a customs broker or an attorney, and this is reported information, not legal advice. Talk to a licensed broker before you change how you import.

Want to work through the Oct. 22 mail deadline with other store owners and me inside the community? Join the Skool community →

Oct. 22 Mail Deadline: Five Moves to Make This Week

You have 11 days before the mail rule bites and until Dec. 7 to comment on the bigger proposal. Do these five things first:

Export the last 90 days of orders from Shopify and tag each SKU by origin (US warehouse or overseas) and ship method (freight, express or mail). Anything overseas and by mail is your exposure list.
Ask every overseas supplier or forwarder three questions in writing: who is the importer of record, is there a bond on file, and do any of your SKUs carry Chapter 98 or 99 duties or CPSC requirements. A vague answer means you plan for the worst case.
Rerun landed cost on your top 20 overseas SKUs with a $30 broker fee per parcel and the duty rate on each HTS line. If margin drops under your floor, my guide to raising profit margins without raising prices covers the levers.
Line up a US alternative for the worst offenders. Inventory Source, Wholesale2b and Spocket all list US-based suppliers, and my supplier vetting checklist works for any marketplace.
Decide whether you will comment by Dec. 7 at Regulations.gov under docket USCBP-2026-0298. If you want a second set of eyes on your sourcing model first, grab a slot through my discovery call page.

Keep the receipts for every step. Clean books make a broker’s job faster, and Finaloop keeps landed costs tied to the right orders.

Frequently Asked Questions

Is the CBP proposal in effect?
No. It was published Oct. 8 as a proposed rule and nothing in it is in effect today, per Diaz Trade Law. The Oct. 22 mail date comes from the earlier interim final rule and is already scheduled.

Does the Oct. 22 date apply to my store?
Only if you or your supplier import mail valued at $2,500 or less that is subject to agency requirements, carries Chapter 98 or 99 duties, or claims duty-free treatment under a free trade agreement. If everything ships from a US warehouse, it does not. My EU product ID customs post covers the mirror-image rule for selling into Europe.

What is Entry Type 13?
It is a voluntary electronic informal entry for international mail valued at $2,500 or less, filed in CBP’s ACE system by the owner, purchaser or a licensed broker. The new proposal would make it mandatory for postal shipments, per GHY.

Does this hit high-ticket dropshippers using US suppliers?
Mostly no, and that is one reason I steer people toward US authorized dealers. If you are still picking products, grab the free high-ticket niches list. Then read the full niches post to see which categories ship from domestic warehouses.

Do I need an LLC to be an importer of record?
The coverage I read does not say you need one, but importing under your own name puts the filing in your name. Many owners form an LLC first, and I explain how to get a business address without renting an office. Check with a licensed broker or attorney for your case.

Will de minimis come back?
The proposed rule’s background says the statutory termination takes effect July 1, 2027 under Pub. L. 119-21, and CBP’s June rule suspends it for mail indefinitely. I would not plan around a return.

How do I comment on the proposal?
Submit comments through Regulations.gov under docket USCBP-2026-0298 by Dec. 7. The Federal Register page links to the docket, and GHY advises naming the provisions you address and including supporting data.

Want my team to build and run a store on US suppliers so none of this lands on you? See the turnkey done-for-you service →

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Trevor Fenner

Trevor Fenner is an ecommerce entrepreneur and the founder of Ecommerce Paradise, a platform focused on helping entrepreneurs build and scale profitable high-ticket ecommerce and dropshipping businesses. With over a decade of hands-on experience, Trevor specializes in high-ticket dropshipping strategy, niche and product selection, supplier recruiting and onboarding, Google & Bing Shopping ads, ecommerce SEO, and systems-driven automation and scaling. Through Ecommerce Paradise, he provides free education via in-depth guides like How to Start High-Ticket Dropshipping, advanced training through the High-Ticket Dropshipping Masterclass, and fully done-for-you turnkey ecommerce services for entrepreneurs who want a faster, more hands-off path to growth. Trevor is known for emphasizing sustainable, real-world ecommerce models over hype-driven tactics, helping store owners build scalable, sellable, and location-independent brands.