1. Check the Postal Route before Classifying the Goods
Confirm that the merchandise enters through the international postal network. A low-value parcel arriving through an express courier or another cargo channel falls outside this postal compliance extension. The seller’s shipping label or delivery promise alone does not establish the customs entry route.
Ask the logistics provider to confirm how the shipment enters the country and which procedure the filer intends to use. That information matters before the business decides whether particular products fall within the delayed requirements.
Identify the Condition under Paragraph (V) or (Vi)
Paragraph (v) concerns mail shipments subject to another government agency’s requirements. Paragraph (vi) concerns certain tariff treatment and duty-free claims under the Harmonized Tariff Schedule of the United States, or HTSUS.
| Provision | Covered Condition | Records to Examine |
|---|---|---|
| Paragraph (v) | The shipment is subject to another government agency’s requirements | Product specifications, intended use, and applicable agency documents |
| Paragraph (vi) | Duties apply under HTSUS Chapter 98 or Chapter 99 | Classification support, origin records, and applicable tariff codes |
| Paragraph (vi) | Duty-free treatment is claimed under Chapter 98 or a free trade agreement | The claimed provision and records supporting eligibility |
An online product description may omit the composition or intended use needed to determine agency coverage. Likewise, a supplier’s tariff code may not resolve the additional duties or preferential treatment relevant to the U.S. .ntry. A customs law review should connect those facts to the actual shipment.
2. A Separate Entry Requirement Can Still Control
The extension postpones compliance with two provisions, not the remaining formal entry requirements in section 145.12. Other provisions address shipments exceeding $2,500, quota merchandise, antidumping or countervailing duty measures, and specified alcohol and tobacco products. Exceptions and the precise scope of the relevant provision still require review.
Screen for Overlapping Requirements
CBP may also require formal entry when necessary to protect the revenue. Consequently, merchandise covered by paragraph (v) may require formal entry for an independent reason during the extension period.
For catalog screening, record each applicable condition. One product range may include both shipments affected by the extension and shipments already requiring formal entry. A single “extended until January” label can hide that distinction.
3. Separate the Compliance Date from Shipment Deadlines
CBP’s October 22, 2026 final rule moved the compliance date for paragraphs (v) and (vi) from October 22, 2026, to January 20, 2027. The additional time allows importers, brokers, and logistics providers to prepare systems and data procedures.
Keep Filing and Payment Obligations Separate
Beginning on the new compliance date, affected shipments must follow the applicable formal entry requirements or an available alternative for which they qualify. January 20 does not become a universal filing deadline for earlier imports.
Existing shipment-specific reporting and payment obligations remain separate. The extension does not generally postpone duties, excuse missing declarations, or suspend another agency’s product requirements.
4. Determine Whether Entry Type 13 Is Available
Eligible international mail shipments valued at $2,500 or less may use the Entry Type 13 test as an alternative to formal entry. The test began on September 22, 2026, and allows electronic informal entry through the Automated Commercial Environment, or ACE.
Confirm Shipment Eligibility and the Filer
The value ceiling alone does not establish eligibility. Confirm that the merchandise qualifies, identify the importer of record, and determine who can transmit the required data. A plan that depends on electronic filing remains incomplete if the proposed filer cannot submit the entry.
The Temporary Pga Data Accommodation Has a Separate End Date
CBP’s October 22 modification temporarily allows Entry Type 13 transmissions without complete electronic Partner Government Agency, or PGA, data. The agency will announce the end of this temporary acceptance in a future Federal Register notice. January 20 should not be presented as its automatic expiration date.
This accommodation addresses electronic transmission. It does not eliminate the underlying agency requirements. Chapter 98, Chapter 99, and free trade agreement claims also require the additional data applicable to those provisions.
Uncertain classification or claim eligibility should be resolved before selecting a filing procedure. A tariff and customs advisory review can examine the supporting documents and identify which requirements affect the proposed entry.
5. Build the Preparation File Around the Chosen Procedure
Collect the supplier’s product information and the logistics provider’s shipment information in a working file. Use the chosen entry procedure to identify missing records and assign responsibility for obtaining them.
Gather Product and Shipment Records
The preparation file may include:
- Commercial invoices, transaction values, and detailed merchandise descriptions.
- Composition, intended use, country of origin, and classification support.
- Applicable Chapter 98 or Chapter 99 codes and duty-free claim records.
- Agency permits, registrations, certificates, or other information required for the goods.
- Postal tracking, transport details, and importer and filer information.
The required documents depend on the merchandise and procedure. This checklist supports preparation; it does not make each listed item mandatory for each shipment.
Schedule Testing before January 20, 2027
Start by separating covered products from those with independent formal entry requirements. Then confirm the filing route and assign responsibility for missing supplier or agency information. Test whether product and shipment data reach the filer in a usable format, including how the business will handle rejected or incomplete submissions.
These are internal preparation steps, not additional legal deadlines. CBP encourages early use of the optional Entry Type 13 process during the transition. Check current implementation notices before relying on that process, particularly the temporary PGA data accommodation.
If overlapping requirements leave the route uncertain, a customs compliance and enforcement review can assess the shipment records and proposed procedure. Provide the actual product specifications, tariff claims, and transport information so the review addresses the unresolved issue.
29 Oct, 2026
