The thirteen facts a US import entry needs

US Customs and Border Protection published two notices on 1 October 2026, one for the entry and one for the entry summary. They are Paperwork Reduction Act notices, which is the least promising genre in the Federal Register and the reason almost nobody in trade reads them. They are also the only place CBP writes down, in one list, what an import entry needs and how long the agency thinks it takes.

The form is gone; the data took over

The release filing is nominally CBP Form 3461, Entry/Immediate Delivery. Under 19 CFR § 142.3(a) the release package is the 3461 “or its electronic equivalent”, evidence of the right to make entry, a commercial invoice, a packing list where appropriate, and whatever any other agency wants for that shipment.

The electronic equivalent has eaten the form. CBP’s own burden table puts ACE Cargo Release at 29,832,210 responses a year and Form 3461, paper or electronic, at 12,995. One of those is how the United States imports; the other is a rounding error that still has instructions.

Which matters to a desk for an unglamorous reason. A form is something you fill in at the end. Data is something you either hold or are still chasing.

The list, as CBP prints it

This data consists of 12 required elements: importer of record; buyer name and address; buyer employer identification number (consignee number), seller name and address; manufacturer/supplier name and address; Harmonized Tariff Schedule 10-digit number; country of origin; bill of lading; house air waybill number; bill of lading issuer code; entry number; entry type; and estimated shipment value.

Count the semicolons: the notice says twelve and prints thirteen labels. The same paragraph announces “four optional data elements” and names three: the container stuffing location, the consolidator, the ship-to party. Which two of the thirteen CBP treats as one element is not stated anywhere in the notice, and it does not matter much, because a desk has to produce all of them either way. Build the checklist off the facts, not off the count.

What the list describes is a set of facts about other people. Your own records hold the importer of record, the buyer and the buyer’s identification number; your filer supplies the entry number and the entry type. Everything else belongs to somebody else: the seller’s registered name and address, the manufacturer’s name and address, which on a trading purchase is frequently not the seller’s and has to be asked for; the 10-digit tariff classification, which needs a specification good enough to classify from; the country of origin, which the supplier declares and a certificate evidences; and the transport identifiers.

Country of origin is the one element on the list that carries a second obligation behind it. Declaring it on the entry is not the same as marking it on the goods, which 19 U.S.C. 1304 requires separately — and the exceptions to that are the J-List at 19 CFR 134.33, the table CBP publishes of classes of article that need no origin marking. It is the list to check before a supplier is told nothing has to be printed, because the exception covers the article and never the outermost carton.

Three of those identifiers have a property worth noticing. The bill of lading, the bill of lading issuer code and the house air waybill number do not exist until the cargo has been booked and loaded. No amount of organisation produces them early. So the entry can never be finished early. It can only be ready early, with the other ten elements already correct and agreed, waiting for three fields that arrive with the shipping documents. A desk that is still arguing about the manufacturer’s address when the bill of lading lands has spent its free time on the wrong question.

Ten minutes, and five

The burden tables are the part of a PRA notice everyone skips. Here they are worth the minute, because they are CBP’s own answer to how long this takes.

A formal electronic import entry, release and declaration together, is fifteen minutes of CBP-estimated effort. One paper declaration with a lumber declaration attached costs more than twice that on its own.

These are burden estimates for the collection of information: entering the data and transmitting it. They are not an estimate of assembling the facts, and nothing in the notice claims they are. That distinction is the whole argument. Desk work on an import container runs about 2.2 hours, of which 45 to 90 minutes is preparing and checking the document pack. The typing is fifteen minutes of it. The rest is email.

Entry type 13, and the gap it closes

Both notices announce the same new test:

CBP is announcing a voluntary test for a new electronic informal entry process for mail in ACE through the development of new informal entry type 13—Informal Mail Entry. The new informal entry type 13 is applicable for shipments valued at $2,500 or less that are sent to the United States via mail.

The interesting half is what it unblocks. Mail shipments under $2,500 could already go informal through the interim process in 19 CFR 145.12(b). But § 145.12(a)(2) forces formal entry on “any mail shipment subject to the requirements of another government agency” and on anything dutiable under Chapter 98 or 99 of the tariff. So a low-value mailed sample that happened to need an FDA prior notice fell out of the simple path entirely. Entry type 13 “creates an informal entry pathway for low-value mail shipments subject to Partner Government Agency (PGA) data requirements or duties other than those set forth in Chapters 1-97”, which is the exclusion read backwards.

Entry type 13 is therefore not a new procedure so much as a new code attached to an existing one, which is why the code itself is worth being able to read off a filing rather than look up.

Its twelve elements are a shorter list than cargo release, and one of them is new in kind: the “tracking number generated by the foreign post operator”. Carriers transporting mail may transmit the postal tracking number with their manifest. CBP’s burden estimate for the test is ten respondents filing 200,000 responses each.

A week after this notice, on 8 October 2026, CBP proposed making 13 a regulatory entry type rather than a test — and proposed moving the informal entry deadline in front of the vessel while it was there. The entry type codes are where 13 sits against 01, 11 and 12, and what the proposal would change is the subject of its own post.

Two new fields on the release filing

Two changes to the 3461 are recorded rather than announced, and both are the kind that turns up as a rejected transmission rather than as a memo:

• Russian sanctions elements under Executive Order 14114. The notice says new data elements “have been added to comply with the Russian sanctions outlined in Executive Order 14114”, and that the 3461 and 3461 ALT instructions were updated to include them along with new text fields. The elements and their burden live in a separate collection package, so the notice names them and stops.
• Global Business Identifier. Voluntary, and expanding: the party types a filer may identify go from six to eight with “Intermediary” and “Source” added, a filer may now submit one of the three identifiers rather than all three, and CBP is adding a commercially maintained identifier to the test.

Neither is mandatory today. Both are fields on a filing your broker makes in your name, which means the first time either matters, it will matter on a specific container.

What to do with this

Read the element list as a specification for your own masters. Every one of the thirteen labels is either a fact about a party, a fact about the goods, or a fact about the transport. The party facts belong in a master record you keep, not in the last email; the goods facts belong in the purchase contract, settled when you buy rather than when you ship; the transport facts arrive when they arrive.

Then check the pack against that specification before the three late fields land, not after. Doing it by hand is 45 to 90 minutes a container and it is the job import documentation checklist software exists to take over: reading the invoice, the packing list and the certificate against the contract and naming the field that disagrees. What the regulation gives you, and what a checklist assembled from a vendor’s blog post does not, is the authoritative list of the fields CBP will be looking at.

The deadline structure is the other half. Release and duty are two filings: the entry summary is due within 10 working days of entry, and CBP restated that in the notice. The container’s free time is running against the release, not against the 7501, which is the distinction that decides whether a late document costs you storage or only costs you a filing extension.