De Minimis Is Gone and eFiling Is Coming: The Compliance Cascade for Small-Parcel Sellers

Two federal changes, ten months apart, are usually covered as separate stories. For anyone selling through small parcels — direct to customers, into a third-party logistics (3PL) warehouse, or into Fulfillment by Amazon (FBA) — they are one story. The first rule rerouted your parcels. The second attaches safety paperwork to the route they now travel. Chapter two starts July 8, 2026 — less than four weeks away.

Executive Order 14324 (signed July 30, 2025) suspended duty-free de minimis treatment for all countries effective August 29, 2025 — and U.S. Customs and Border Protection (CBP) implemented it without soft edges: non-postal shipments of any value now file an appropriate entry type in the Automated Commercial Environment (ACE), Type 86 entries are gone, and Section 321 manifest release is eliminated for low-value commercial shipments. Customs brokers report roughly ten times the filing volume since. The full mechanics — postal duty bands, the July 1, 2027 statutory repeal, why the exemption question is closed twice over — are in the de minimis exemption explainer.

The Consumer Product Safety Commission (CPSC) eFiling rule — 90 FR 1800, published January 8, 2025, amending 16 CFR part 1110 — requires importers to file certificate of compliance data electronically with CBP at the time of entry, through ACE, using CPSC's Partner Government Agency (PGA) Message Set.

It becomes mandatory July 8, 2026 for all covered imports: commodity entries, informal entries, former de minimis parcels, and international mail through a modified mechanism. Foreign Trade Zone entries (type 06) follow on January 8, 2027. The rule contains no de minimis exemption — and the Type 86 process that once handled low-value entries no longer exists.

Read the rows top to bottom and the mechanism is clear. Rule 1 moved your parcels into the formal entry system. Rule 2 uses that system as its attachment point. To be precise: eFiling would have reached covered products in any pipe — it even reaches mail, outside ACE. What rule 1 changed is that the certificate data now lands on a formal entry you are already filing, broker and all. A parcel that used to clear on a manifest with no formal entry now generates an ACE entry — and if the product inside is covered by a CPSC rule, standard, or ban, that entry must carry certificate data.

De minimis didn't just remove a duty exemption — it attached fixed costs to shipments that used to clear free. Every non-postal parcel now needs an ACE entry, and broker fees are commonly cited at $75 to $200 per entry. Run that against a $40 customer parcel and the arithmetic fails: the entry can cost more than the goods inside it. The economics push hard toward consolidation — fewer, larger entries into a 3PL or FBA instead of parcel-by-parcel clearance.

For postal shipments, the carrier remits the duty: through February 28, 2026 this ran on per-item bands of $80, $160, or $200, and after that date it is ad valorem only. If you ship by mail today, you are in the ad valorem regime.

eFiling sharpens the same consolidation logic. From July 8, certificate data is one more thing each entry must carry — and the Reference Message Set (three pre-registered identifiers instead of the full data set) matters most for exactly the sellers making many repeat entries.

The paperwork itself is not new. Children's products need a Children's Product Certificate (CPC, backed by CPSC-accepted third-party lab testing); general-use products under a CPSC rule need a General Certificate of Conformity (GCC) — and in both cases you, the importer, issue it. What is new is that the certificate's data elements travel with the customs entry. Which products need which certificate and what your broker will and won't handle are covered in their own guides; the short version is that a broker can transmit everything as your authorized agent, but the finished product certifier — normally you — owns the data's accuracy.

1. Map every SKU against CPSC rules. Coverage follows the product, not the tariff code. Use which products require CPSC eFiling as a starting frame.
2. Close certificate gaps, children's products first. A CPC cannot exist without third-party testing by a CPSC-accepted lab, so any covered children's product without test results is your longest lead-time item.
3. Choose a filing mode. Decide between transmitting the full data set or the three-identifier Reference Message Set, and pre-register repeat SKUs in the CPSC Product Registry.
4. Brief your customs broker. Agree on who transmits what and where the data lives — the division of labor is covered in who does what between you and your broker. FBA sellers can work from the eFiling checklist for Amazon sellers.
5. Mail importers: register before shipping. ACE cannot process mail, so certificate data goes into the CPSC Product Registry before the shipment arrives.

The stakes are concrete: after July 8, entries without eFiled certificate data risk rejection and port holds, non-certified or non-compliant products risk refusal of admission, and the underlying certificate obligations carry CPSC civil penalties of up to $120,000 per knowing violation and $17,150,000 per related series.

Before you plan the run-up to July 8, check which deadlines hit your products with the free 2026 Compliance Deadline Checker.

Why does the end of de minimis affect CPSC eFiling?

Because former under-$800 parcels now flow through standard ACE entries, and that is exactly where CPSC's certificate message set attaches on July 8, 2026. The eFiling rule has no low-value exemption, so covered products need certificate data at entry regardless of value.

Can I still use Type 86 entries for low-value shipments?

No. Following Executive Order 14324, effective August 29, 2025, Type 86 entries may no longer be used and Section 321 manifest release has been eliminated for low-value commercial shipments. Non-postal shipments of any value must file an appropriate entry type in ACE.

How is duty collected on postal shipments now?

The carrier remits the duty. Through February 28, 2026, this ran on per-item bands of $80, $160, or $200; after that date it is ad valorem only.

Does using a customs broker move CPSC liability off me?

No. A broker can file as your authorized agent under 19 U.S.C. 1484(a)(2)(B), but the finished product certifier — normally the importer — owns the validity, accuracy, completeness, and availability of the certificate data.

What should small-parcel sellers do before July 8, 2026?

Map every SKU against CPSC rules, issue or collect the right certificate for each covered product, choose between the Full and Reference Message Sets, and brief your customs broker. Mail importers must also enter certificate data in the CPSC Product Registry before shipments arrive.