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De minimis changes: a DTC planning guide

Revisit your shipment route, entry requirements and unit economics without assuming every parcel has the same treatment.

Source review: September 28, 2026. Confirm later amendments and your carrier's implementation before shipping.

What de minimis was

The administrative exemption under 19 U.S.C. 1321(a)(2)(C) covered qualifying low-value imports, not an unconditional waiver for anything priced below $800. Losing that exemption is different from determining the duty actually owed on a particular product.

The timeline to check

• August 29, 2025
  CBP's August 28 guidance implemented the suspension for covered goods from all countries, with exceptions and separate postal procedures. CBP CSMS 66065494.
• June 24 / July 24, 2026
  The postal interim final rule was published June 24. Its stated effective date is July 24, except the suspension provision effective June 24. Publication and effective dates are not interchangeable.
• October 22, 2026
  The published compliance date applies specifically to 19 CFR 145.12(a)(2)(v) and (vi), not every part of postal processing. June 24 postal rule, Dates section (PDF).
• Before the next shipment
  Check amendments, shipment eligibility and the carrier's entry process. This guide does not predict whether future legislation or litigation will change the rules.

What it costs you

Do not apply a blanket rate to every parcel. Establish classification, origin, customs value, entry date, shipping channel, applicable exclusions and fees. Postal and non-postal procedures can differ. Qualifying bona fide gifts have a separate exemption; a commercial order is not a gift just because the sender labels it one. CBP's June 24 Entry Type 13 notice discusses the separate gift exemption (footnote 3, PDF).

Compare the complete delivered cost: goods, freight, applicable duty, carrier clearance charges, returns and fulfillment. No generic percentage here can replace that calculation.

The four moves

1. Rebuild landed cost into pricing

Model your top 20 SKUs in the duty-stack calculator using supported inputs and broker-confirmed assumptions. The portal's snapshot is incomplete and is not a live quote. Test whether to absorb costs, adjust pricing or disclose separately collected import charges before checkout.

2. Fix your HTS codes

Correct classification and admissibility mattered even when no duty was due. Review descriptions, materials, intended use and origin evidence with your broker; do not choose a code only because it produces a lower result.

3. Compare direct-ship vs. US fulfillment

Model both routes using equivalent goods and volumes: direct-shipping clearance costs versus bulk import, domestic storage, pick-and-pack, inventory financing and returns. Bulk fulfillment is not inherently duty-free and is not automatically cheaper. Use the parcel planning tool to organize the comparison.

4. Maintain a review schedule

Keep a tariff watchlist and recheck affected SKUs before purchase orders and shipment entry. The portal does not currently deliver automated tariff-change emails. Use the bulk re-rating tool to compare scenarios, then verify differences against primary guidance.

Also in this series: How to read a duty stack · The IEEPA ruling and your refund