
The 15-day entry window is being closed
On 8 October 2026 CBP proposed moving the deadline for a US informal entry from 15 calendar days after landing to on or before the date of importation. It would also require a customs bond on every informal entry, add a Final Deliver-To Party to the data, and make a consignee who is neither owner nor purchaser appoint a broker. Comments close 7 December 2026.
The Federal Register of 8 October 2026 carries a CBP proposed rule called Low-Value Shipments. It is about the informal entry, the procedure for merchandise valued at $2,500 or less, and most of the coverage it will get is about parcels and de minimis. One sentence in it is about every desk that files one.
Two weeks after, becomes before
Today, 19 CFR 141.5 gives you fifteen calendar days from landing to make entry. Formal, informal, it does not matter: fifteen days after the cargo is on the ground.
CBP’s objection is operational, and it says so plainly. The current window “does not provide CBP with sufficient time to properly conduct risk assessment and targeting before the arrival of such potentially dangerous or unlawful importations”. So the proposal sets the deadline for an entry type 11 at “upon or prior to the date of importation”, and “date of importation” is not a soft phrase. It is defined at 19 CFR 101.1 as the day the vessel arrives within port limits intending to unlade.
Read those two deadlines next to each other and the shift is not fifteen days. It is the difference between a filing that follows the cargo and a filing that has to be waiting for it.
Why that is a documents problem and not a filing problem
Fifteen days after landing is a comfortable deadline for a reason that has nothing to do with customs. It is comfortable because it sits inside the period when the shipping documents finally turn up. The commercial invoice is being corrected, the packing list is being reconciled, the supplier is being asked for the manufacturer’s registered address, and the entry gets filed once the pack is straight.
Move the deadline in front of the vessel and that sequence inverts. The pack has to be straight while the ship is still at sea. Nothing about the filing got harder. CBP puts the transmission itself at ten minutes. What got harder is being ready, and being ready is the part that is somebody else’s homework.
This is the same structure as the clock a late document pack already runs into. Packs routinely run about eight days late; the terminal and the carrier both start charging from discharge. The proposal adds a third deadline that falls earlier than either, and unlike demurrage it is not negotiable after the fact.
Every informal entry gets a bond
The second change is quieter and costs money.
A formal entry has always needed a basic importation and entry bond on the conditions in 19 CFR 113.62. An informal entry has needed one only in particular situations. CBP proposes to require one on every type 11 and type 13 entry: a single transaction bond or a continuous bond, with the broker’s own bond obligated where a consignee has had to appoint one.
Alongside it, a new floor. For most of the bond conditions, liquidated damages are currently set at the value of the merchandise involved in the default. On a $900 shipment that is a $900 exposure, and CBP says collecting it can cost more than it recovers. So the proposal amends 19 CFR 113.62(n) to set a minimum of $1,000 for each breach of a listed condition on a type 11 or type 13 entry. On low-value cargo, the penalty floor is now above the goods.
A new fact to hold: the Final Deliver-To Party
The third change adds a data element. Where the party the goods are finally going to is not the ultimate consignee named on the entry summary, the entry would have to carry that party’s identity and address. CBP calls it the Final Deliver-To Party, “the final intended recipient of the shipment, as known at the time of filing”.
It is a small field with an awkward home. On a trading book the final recipient is in the sales order, not the customs file, and the two are often maintained by different people on different systems. A desk that drops the ball here drops it because nobody owned the question, which is the ordinary way this work fails.
And a consignee can no longer self-appoint
CBP also proposes amending 19 CFR 143.26(a) so that a consignee who is neither the owner nor the purchaser of the goods (a freight forwarder, a carrier, USPS, a foreign postal operator) must appoint a licensed customs broker, and that broker acts as importer of record. The exception for duty-free shipments under 19 U.S.C. 1321(a)(2)(A) and (B) stays as it is.
For an importer buying FOB and clearing in its own name, nothing changes. For anyone whose forwarder has been entering low-value shipments as consignee, the filing moves to a broker and the broker’s bond carries it.
One change that cuts the other way
Not everything in the rule tightens. CBP proposes removing the $250 ceiling that currently blocks informal entry for goods classified in Chapter 99, Subchapters III and IV of the tariff, which is where the Section 232 and similar additional duties live. A shipment worth $251 to $2,500 that happens to carry a Section 232 duty is forced into formal entry today. Under the proposal it would not be. CBP notes the same change was made to other informal entry regulations back in 2012.
Where the paper goes
One number in the rule explains why electronic filing is being made mandatory rather than encouraged. Between 1 September 2025 and 31 May 2026 there were 52,450,418 type 11 entries. 73,534 of them were filed on paper: 0.14%, typed into ACE afterwards by CBP staff.
Which is the shape of most compliance arguments on an import desk. The exception is rare enough to feel safe and expensive enough that somebody eventually legislates it away.
What to do before 7 December
Comments close on 7 December 2026, and this is a proposal, not a rule. Two things are worth doing now rather than after.
Find out which of your US entries are type 11. The code is on the 7501 and your broker picks it; if you are importing samples, spares, replacement parts or small trial orders, more of your book is informal than you think. Then ask one question of each: on the day that vessel enters port limits, is the entry data complete? Not the pack. The thirteen facts CBP’s release list names.
If the honest answer is “usually, a few days later”, the proposal is not a paperwork change. It is a chasing deadline, and it moves to before the ship arrives.
And the postal channel is moving on the outbound side too. On 19 October 2026 the Postal Service added a section to the International Mail Manual on unpaid destination customs charges, under which USPS invoices the mailer for duties a foreign authority could not collect from the addressee — payable in full even where the mailer disputes the assessment.
Questions this raises
What is the deadline to file a US informal entry?
Today it is 15 calendar days after the merchandise lands, under 19 CFR 141.5 — the same deadline as a formal entry. CBP proposed on 8 October 2026 to move it for informal entries to "upon or prior to the date of importation", which 19 CFR 101.1 defines as the vessel's arrival within the limits of a US port with intent to unlade. The rule is a proposal and comments close on 7 December 2026.
Will informal entries need a customs bond?
Under the proposal, yes — every one. CBP would require a basic importation and entry bond with the conditions in 19 CFR 113.62 on all entry type 11 and entry type 13 filings, either a single transaction bond or a continuous bond. Today an informal entry needs a bond only in particular situations. CBP also proposes a $1,000 minimum for liquidated damages on a breach of most of those bond conditions.
What is the Final Deliver-To Party?
A proposed new data element: the identity and address of the party the goods are ultimately intended to reach, where that is not the ultimate consignee named on the entry summary. CBP would require it only when the two differ, to avoid collecting the same fact twice. It is the fact nobody on an import desk currently has to write down, and it usually sits in the sales order rather than in the customs file.
Can a freight forwarder still file an informal entry?
Not as importer of record on somebody else's behalf, under the proposal. CBP would amend 19 CFR 143.26(a) so that a consignee who is neither the owner nor the purchaser — a forwarder, a carrier, USPS or a foreign postal operator — must appoint a licensed customs broker who then acts as importer of record. Shipments exempt from duty under 19 U.S.C. 1321(a)(2)(A) and (B) are unaffected.
What happens if no entry is filed?
The two informal codes would diverge. A type 11 shipment stays abandonable at six months after arrival. A mail article under the proposed type 13 would be deemed voluntarily abandoned 15 days after the date of importation and then destroyed or returned to the sender by USPS. CBP's own analysis says USPS expects a significant number of shipments to be abandoned under that deadline.
Does this change anything for goods worth more than $2,500?
The deadline and bond changes are written for informal entry, which is merchandise valued at $2,500 or less. One proposed change runs the other way and widens informal entry: CBP would remove the $250 cap on using informal procedures for goods classified in Chapter 99, Subchapters III and IV of the tariff, so a $251 to $2,500 shipment carrying Section 232 duties would no longer be forced into formal entry.
Sources
- US Customs and Border Protection, "Low-Value Shipments", proposed rule, 91 FR 64532 (8 October 2026) — proposes to require informal entries to be "filed electronically as an entry type 11 filing, upon or prior to the date of importation"; identifies the current deadline as 19 CFR 141.5's 15 calendar days after landing; requires a basic importation and entry bond with the conditions in 19 CFR 113.62 for every entry type 11 and entry type 13, and proposes a $1,000 minimum for liquidated damages in 19 CFR 113.62(n); adds a Final Deliver-To Party data element where that party differs from the ultimate consignee on CBP Form 7501; amends 19 CFR 143.26(a) so a consignee who is not an owner or purchaser must appoint a licensed broker to act as importer of record; removes the $250 limit on informal entry for Chapter 99 Subchapter III and IV goods; adds 19 CFR 145.6 deeming unentered mail abandoned after 15 days against six months for type 11; and records 73,534 of 52,450,418 type 11 entries filed manually on paper between 1 September 2025 and 31 May 2026. Footnote 9 defines entry types 01, 11 and 12. Comments due 7 December 2026 · checked 2026-10-10
- 19 CFR § 141.5, Time limit for entry — "Merchandise for which entry is required will be entered within 15 calendar days after landing from a vessel, aircraft or vehicle, or after arrival at the port of destination in the case of merchandise transported in bond" · checked 2026-10-10
- 19 CFR § 101.1, Definitions — "Date of importation" means, for merchandise imported by vessel, the date on which the vessel arrives within the limits of a port in the United States with intent then and there to unlade such merchandise, and otherwise the date the merchandise arrives within the Customs territory of the United States · checked 2026-10-10
- 19 CFR § 113.62, Basic importation and entry bond conditions — the bond conditions CBP proposes to require on every informal entry · checked 2026-10-10
- 19 CFR part 143 subpart C, Informal entries — § 143.21 merchandise eligible, § 143.23 form of entry, § 143.26 right to make entry · checked 2026-10-10
- Docket operational baseline, import–export desk · checked 2026-08-08