The end of US de minimis: what changes for small lab imports of research chemicals

What changed, in dates

The change came in layers, through executive orders, CBP guidance, a CBP rule and legislation. The table lists the steps that matter for a lab ordering small quantities from abroad, each from the official document that announced it.

What de minimis used to do and what replaced it

Section 321 de minimis let shipments valued at 800 dollars or less enter free of duty and certain taxes. [2] [5] CBP's FAQ describes the suspension as covering merchandise valued at 800 dollars or less arriving by all modes, including international mail, unless a separate authority excepts it. [5] For courier and freight shipments, CBP told filers on 28 August 2025 that they must submit an appropriate formal or informal entry in ACE and that paper informal entries are not permitted for covered goods. [2]

Mail was handled separately. Executive Order 14324 had carriers collect and remit duty on postal items either as an ad valorem duty at the applicable IEEPA rate or, for the first six months, as a specific duty of 80, 160 or 200 dollars per item depending on that rate. [1] After the Supreme Court ruling, Executive Order 14388 set the postal duty at the rate in the February 2026 surcharge proclamation, assessed on each dutiable item's value. [3] CBP's rule then created a postal informal entry process effective 24 July 2026. [4]

Two exemptions survive: CBP says the exemptions for bona fide gifts and for personal or household articles accompanying travelers remain unchanged, and that a bona fide gift excludes anything bought, bartered or exchanged, including items said to be given with a purchase. [5] A lab purchase is not a gift.

Formal versus informal entry for a lab parcel

Informal entry is available for shipments not exceeding 2,500 dollars, except that Chapter 99 Subchapter III and IV articles valued over 250 dollars fall outside that limit. [7] CBP's FAQ says formal entry is required above 2,500 dollars and for goods under quota or antidumping and countervailing duties. [5]

For mail, CBP's rule goes further: formal entry is required for any mail shipment subject to another government agency's requirements, and for merchandise subject to Chapter 98 or 99 duties or claiming Chapter 98 or free trade agreement duty-free treatment. [4] The rule set the compliance date for those requirements at 22 October 2026 [4]; CBP's e-commerce page later announced that the compliance date for the new mail informal entry procedures moves to 20 January 2027. [6]

This matters for labs because FDA reviews all imported shipments of FDA-regulated products, with CBP referring those products to FDA. [9] If a mail shipment falls under FDA or another agency's requirements, the CBP rule above sends it to formal entry, so plan the time and cost accordingly; [4] the FDA import refusal guide on this site covers what happens during FDA review.

Who pays: DAP versus DDP

The delivery term on your order decides who arranges and pays for import clearance. Under DAP, customs clearance in the importing country, including customs duties and taxes, falls to the buyer; under DDP the seller arranges transport to the named destination and takes on import obligations, which can include authorisations, registrations and taxes. [8]

For postal shipments, CBP's rule limits who may file the new postal informal entry to the owner or purchaser of the merchandise, or a licensed customs broker designated by the owner, purchaser or consignee. [4] If a seller quotes DDP for a parcel sent by post, ask how they will make entry under that rule. If the answer is unclear, assume you may receive the bill.

What paperwork to expect

For a postal informal entry, the rule lists the data CBP needs by the 7th day of the month after arrival: filer code, bond number, description, country of origin, all applicable 10-digit HTSUS classifications, quantity or weight if a specific duty applies, duty rate, value, total duty owed, carrier, flight or conveyance number, tracking number from the foreign post, arrival port and arrival date. Payment goes through Pay.gov by the same day. [4] [5] CBP says shipments without the required data or bond are not released until those requirements are met. [5]

For courier shipments, the carrier or a broker usually files the entry and bills you for duty and charges. Ask the supplier to put an accurate description, value, country of origin and HTSUS code on the commercial invoice, because those fields drive the duty and the speed of release.

Budgeting and receiving checklist

Use the list below when you plan any import after the de minimis change, and file the answers with the order.

• Confirm the delivery term in writing: DAP or DDP, and what the price includes [8]
• Get the HTSUS code and country of origin the invoice will show [4]
• Ask whether the shipment is subject to FDA or other agency requirements [9]
• Budget duty, entry fee and broker or carrier charges even for small parcels [2]
• Check whether the value exceeds 2,500 dollars and needs formal entry [7]
• Never split one order into several parcels to stay under a threshold [4]
• Tell receiving staff that a carrier may ask for payment before delivery
• Keep the entry, duty receipt and carrier invoice with the purchase record