Buying small shipments from China into the US: what are your obligations as importer?
Whoever is the importer carries primary responsibility for duties and the accuracy of the entry. Since de minimis is suspended, every shipment needs an entry. Mail can be filed only by the owner or purchaser or their licensed broker, with a bond. Ocean freight needs an ISF 24 hours before loading; air cargo uses ACAS before loading. Some products need FCC, FDA or CPSC compliance before they can be imported.
- Applies to
- US small businesses and individuals buying goods from China for resale.
Who is the importer
"Importer" means the person primarily liable for duties, or their agent: the consignee, the importer of record, the actual owner, or a warehouse transferee (19 CFR 101.1). An importer of record needs an IOR number and CBP Form 5106 (19 CFR 24.5). A non-resident company can be the importer of record only if it has a resident agent for service of process in the state of the port (or where a remote entry is filed) and files a CBP Form 301 bond with a resident corporate surety (19 CFR 141.18). See Can a foreign company be the US importer?
Filing by mode
| Mode | Requirement | Status | Source |
|---|---|---|---|
| Postal informal entry up to $2,500; owner, purchaser or licensed broker; bond required | In force since 2026-07-24 | CBP e-commerce FAQ | |
| Express / other | De minimis suspended; formal or informal entry | In force since 2026-06-24 | FR 2026-12670 |
| Value limit | Informal entry up to $2,500; formal entry above | In force | 19 CFR 143.21 |
| Ocean | ISF filed 24 hours before loading abroad | In force | 19 CFR 149.2 |
| Air | ACAS data before loading, by the carrier or another eligible party | In force | 19 CFR 122.48b |
| Fees | Merchandise processing fee: $2.77 per automated informal entry; formal entry 0.3464% of value, min $34.58, max $670.86 | In force since 2026-10-01 | FR 2026-15530 |
| Proposed | File all informal entries on or before arrival; bonds | Proposed, comments to 2026-12-07 | FR 2026-20650 |
Product rules to check before ordering
| Products | Requirement | Source |
|---|---|---|
| Radio-frequency devices (Bluetooth, Wi-Fi, chargers with radios) | FCC equipment authorization before import or sale | FCC, 47 CFR 2.1204 |
| Food, drugs, devices, cosmetics | FDA electronic screening at import; food needs Prior Notice | FDA import program, 21 CFR 1.279 |
| Children's products (12 and under) | Third-party lab testing and a Children's Product Certificate; e-filing with CBP from 2026-07-08 | CPSC CPC |
Still uncertain
- How the fee applies to the new postal entry (Type 13) is not spelled out separately.
- Restrictions on foreign importers of record under Executive Order 14411 are announced but the detailed rule is not out.