The Mail Rule's Last Grace Period Ends October 22 - And Only Licensed Brokers Can File

## The Mail Rule's Last Grace Period Ends October 22

On June 24, 2026, CBP published an interim final rule - 91 FR 37801, CBP Dec. 26-13, docket USCBP-2026-0761 - that did two things at once. It indefinitely suspended the $800 de minimis exemption for merchandise arriving through the international postal network, and it built an entirely new postal informal entry process to replace the counter-collection system that had governed mail for decades.

The de minimis suspension for mail took effect the day it published. The new entry process took effect July 24, 2026. But buried in the effective-date paragraph is a delayed compliance date that most importers have not calendared: October 22, 2026, for 19 CFR 145.12(a)(2)(v) and (vi).

That is the last soft edge in the rule, and it closes in under three months.

If your inbound mail volume includes anything touching a partner government agency, anything dutiable under HTSUS Chapter 98 or 99, or anything on which you claim Chapter 98 or free trade agreement duty-free treatment, you can still run those shipments through the informal postal process today. On October 22 that ends. Those shipments then need formal entry - CBP Forms 3461 and 7501 - or the voluntary Entry Type 13 electronic test, which CBP has said will open coinciding with the end of the delayed compliance window.

What Actually Changed on July 24

The old world: a CBP officer at an International Service Center hand-prepared a mail entry form, the package moved to the destination post office, and the addressee paid duty at the counter on pickup. That world is gone. CBP officers no longer manually prepare entry forms for these shipments, and duties are no longer collected on delivery.

The new world, under revised 19 CFR 145.12(b): a party with the right to make entry under 19 CFR 143.26(a) transmits an informal mail entry for each shipment valued at $2,500 or less and classifiable in HTSUS chapters 1 through 97. The duty is calculated up front from the actual HTS classification and country of origin, and it is paid by the filer - not the recipient.

That is a structural change, not a paperwork change. Every low-value parcel that used to move on a customs declaration sticker now needs a classification decision, a valuation, a bond, and a payment.

Postal entries do at least remain exempt from the merchandise processing fee under 19 CFR 24.23(c)(1)(v). That is one of the very few pieces of good news in the rule. Everything else - duties, taxes, and applicable fees - now applies at the real rate for the real HTS line, replacing the flat 10% ad valorem proxy that the interim Executive Order 14324 process had been using.

The Change Nobody Budgeted For: Only Brokers Can File

This is the operational shock in the rule, and it sits in the preamble rather than the regulatory text.

The updated International Mail Duty Worksheet (IMDW) now requires the filer to provide all applicable 10-digit HTSUS classifications for the merchandise. Classification is customs business. CBP therefore concluded that submitting the IMDW is itself customs business - which means that if the filer is not the owner or purchaser of the goods, only a licensed customs broker may submit it.

CBP's own estimate is that roughly half of the parties currently qualified to file under the interim process are not licensed brokers. Every one of those parties is now excluded. Foreign postal operators and importers who relied on them have to find a licensed broker, negotiate a contract, and onboard before their next inbound cycle. CBP acknowledged in the economic analysis that this could cause temporary hiatuses or reductions of mail from certain countries during the transition - and declined to quantify the cost.

There is one efficiency built in: a broker may file a single monthly IMDW covering all of that broker's clients for the month. If you are shopping for a broker to handle postal volume, ask specifically whether they consolidate.

If you have never had to classify at the 10-digit level before, start with our guide on how to read an HTS code - the difference between a 6-digit international subheading and the 10-digit US statistical suffix is exactly where postal filers get this wrong.

The 14 Data Elements

Under 19 CFR 145.12(b)(3), the entry is transmitted to CBP as an Excel spreadsheet emailed to CBPDM@cbp.dhs.gov. Yes, in 2026, by email. The required elements are:

1. Filer Code 2. Bond Number 3. Description of Merchandise 4. Country of Origin 5. All applicable 10-digit HTSUS classification(s) 6. Quantity/Weight - conditional, required only where a specific (non-ad-valorem) duty rate applies 7. Duty Rate 8. Value 9. Total Duty Owed 10. Carrier 11. Flight/Conveyance Number 12. Tracking Number (generated by the foreign post operator) 13. Arrival Port 14. Arrival Date

Five of these are new relative to the interim Executive Order 14324 process: filer code, bond number, description of merchandise, all applicable 10-digit HTSUS classifications, and the conditional quantity/weight field. CBP's own Paperwork Reduction Act estimate tells the story - the burden per response went from 2 hours to 6 hours (OMB control number 1651-0147).

The Bond Requirement - New 19 CFR 145.15

This is the provision that will strand shipments if it is not handled in advance. New section 145.15 states that a mail shipment valued at $2,500 or less will not be released from CBP custody unless a bond meeting the conditions of 19 CFR 113.62 - the basic importation and entry bond conditions - has been transmitted to CBP under Part 113, secured by an approved corporate surety or by cash deposit under 19 CFR 113.40.

Practical reading:

- Either a single transaction bond or a continuous bond works. The rule leaves the choice to the filer. - The bond must be on file before release, not after. No bond number on the worksheet means the entry is not accepted and the parcel does not move. - The rule specifies no activity code, no minimum dollar amount, and no formula. There is no 10%-of-duties calculation written into 145.15, and no floor. That is genuinely absent from the rule, not an omission in this summary - which means bond sizing is a conversation with your surety, informed by your annual duty exposure.

If you are running any recurring postal volume at all, a continuous bond is almost certainly cheaper than per-shipment STBs. Size it against your projected annual duties using our customs bond calculator, and read the customs bond guide for how the 113.62 conditions actually bind you - they secure duties, redelivery, and your obligation to correct non-compliance affecting admissibility.

Duty Rate Timing and the 7th-of-the-Month Deadline

Two timing rules matter.

Rate lock. Under 19 CFR 145.12(b)(2), merchandise released on a mail informal entry is dutiable at the rates in effect when preparation of the entry is completed - and preparation is complete when the entry is properly transmitted to CBP. In a year where rates have moved repeatedly, that transmission timestamp is your rate.

Payment. The spreadsheet and the payment are both due via Pay.gov no later than the 7th day of the month following the shipment's arrival. CBP's own example: a package arriving April 15 means worksheet and payment are due no later than May 7.

Note what is not in this rule. There is no Periodic Monthly Statement, no ACE statement processing, and no ACH. Searching the full text returns zero occurrences of any of them. The "monthly" character of the process comes entirely from that 7th-of-the-following-month deadline - it is a manual Pay.gov transaction, not a PMS draw. If your finance team assumed this would flow through existing ACE statement plumbing, it will not.

What Gets Kicked to Formal Entry

Under 19 CFR 145.12(a)(2), formal entry is required for any mail importation that is:

1. Over $2,500 in value; 2. Subject to any absolute or tariff-rate quota, open or closed; 3. Subject to any AD/CVD determination, instruction, or order, or otherwise precluded by law from informal entry; 4. Alcoholic beverages; cigars, cigarillos and cheroots; cigarettes containing tobacco; cigarette tubes and papers; smoking tobacco including water pipe, pipe and roll-your-own; snuff; chewing tobacco; 5. Subject to the requirements of another government agency (PGA); 6. Subject to duties under HTSUS Chapter 98 or 99, or claiming duty-free treatment under Chapter 98 or a free trade agreement.

Categories 5 and 6 are the ones with the October 22 compliance date. Until then they may still use the informal postal process.

Two more provisions worth knowing. Under 145.12(a)(1), CBP retains discretion to require formal entry on any mail shipment regardless of value where necessary to protect the revenue. And under 145.12(a)(3), separate shipments each at or under $2,500, mailed abroad at different times, cannot be aggregated to force formal entry - unless the shipments were split to avoid duty. CBP also removed the old requirement that formal entries be made at the customhouse, and where a parcel is addressed to a point that is not a CBP port or customs station, the port of entry will be the one nearest the destination.

CBP stated plainly that it cannot estimate what share of postal entries will fall into the ineligible categories, because it does not have classification data for the postal environment. Neither, probably, do you. That is the work to do before October 22.

What This Costs, By CBP's Own Numbers

The scale here is worth internalizing. CBP processed over 1.36 billion de minimis shipments in FY2024, up from 139 million in 2015. Postal de minimis entries specifically ran 108.4 million in FY21 and 74.8 million in FY24 - a compound annual decline of 11.63%. Post-suspension, the September through November 2025 run-rate of 7,254,980 postal entries annualizes to roughly 29.1 million.

Against that base, CBP estimates the rule generates about $316.2 million in additional annual postal duties in year one, using an 8.62% effective non-IEEPA duty rate drawn from a 392,312-entry Entry Type 11 sample. The monetized compliance cost CBP put on the record is only the added IMDW burden - about $175,536 a year at a $36.57 loaded broker wage.

That gap between $316 million of transferred duty and $176 thousand of acknowledged compliance cost is where the real-world friction lives. The classification work, the broker onboarding, the bond, and the reconciliation are not in CBP's cost figure.

The Checklist Before October 22

1. Inventory your inbound mail volume by category. You need to know, by SKU, which parcels touch a PGA (FDA, USDA, CPSC, FCC, EPA, DOT), which fall under Chapter 98 or 99, and which carry an FTA claim. Those are the shipments losing informal treatment on October 22.

2. Classify at 10 digits, not 6. The worksheet requires all applicable 10-digit HTSUS lines. Merchants running large cross-border catalogs typically cannot do this by hand and use landed-cost and duty-classification software such as Zonos to assign and maintain HS lines at scale. (Disclosure: this is an affiliate link - FreightFigures may earn a commission if you sign up, at no additional cost to you. See our full affiliate disclosure.) For a modest catalog, a broker classification review is usually the better spend.

3. Get the bond on file now. A continuous bond application through a surety takes time, and 145.15 is a release condition. Do not discover this at the ISC.

4. Line up a licensed broker if you are not the owner or purchaser. Ask whether they file a consolidated monthly IMDW, what they charge per line versus per worksheet, and whether they will take postal volume at all - many will not.

5. Re-run your landed cost with duty actually in it. The mail channel is no longer a duty-free channel, and MPF exemption does not offset a real duty rate on every parcel. Model it in the landed cost calculator and read how to calculate landed cost in 2026 for the full method.

6. Price the alternative honestly. For a lot of sellers the answer is no longer parcel-by-parcel mail at all. Consolidating into container freight, clearing once, and fulfilling domestically usually beats per-parcel entry once duty, bond, broker fees, and 6 hours of worksheet labor per filing are in the model. That comparison is worth running before you rebuild a postal compliance function you may not need.

The Longer Horizon

None of this is a temporary posture. The de minimis exemption was suspended for most modes effective August 29, 2025 and for mail on June 24, 2026, and the One Big Beautiful Bill Act (Pub. L. 119-21, section 70531(b)(3)) statutorily terminates the exemption on July 1, 2027. The regulatory suspension runs indefinitely until CBP affirmatively determines it is no longer inconsistent with the purpose of 19 U.S.C. 1321(a), no longer jeopardizes the revenue, and no longer facilitates unlawful importations. Any change gets announced by the Commissioner in the Federal Register.

Two carve-outs survive untouched: bona fide gifts under 19 U.S.C. 1321(a)(2)(A) at $100, or $200 from certain island possessions, and personal and household articles up to $200 accompanying a traveler under 1321(a)(2)(B).

For the broader background on how the exemption came apart across every mode of transport, see our full guide to the de minimis exemption suspension. For the fee structure that applies once you are filing real entries, see US customs user fees, MPF and HMF in 2026.

CBP received 11 comments before the July 24 comment deadline. The rule is in force either way.

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