Reminder: De Minimis Released Ended on August 29
An executive order has suspended duty-free treatment under de minimis for goods from all countries. U.S. Customs and Border Protection (CBP) will reject requests for de minimis entry and clearance for ineligible shipments. This includes Section 321 manifest electronic filings, the option of 321 filing in the truck manifest portal, and the use of type 86 entries for release. Electronic filing of a formal or informal entry with CBP is now required for low-value shipments, except for postal shipments.
For commercial shipments that move into the U.S. through the international postal network and were eligible for de minimis release, the carrier delivering the package to the U.S. will be responsible for the duties that are due. CBP will no longer prepare entries for the consignee.
Postal shipments will be subject to IEEPA tariffs using one of two methods:
- Ad Valorem Duty: A duty equal to the IEEPA tariff for the country of the product based on the declared value.
- Specific
Duty: A flat duty ranging from $80 to $200 per item depending, on the IEEPA
tariff rate of the country of origin.
- Countries with an IEEPA rate of less than 16% will be assessed $80 per item.
- Countries with an IEEPA rate between 16% and 25% will be assessed $160.
- Countries with an IEEPA rate above will be assessed $200.
The specific rate will only be available for 6 months.
CBP will still allow ‘de minimis’ treatment for bona fide gifts.
The CAFC has Issued a Ruling on the Appeals of the CIT Decision on Tariffs
The U.S. Court of Appeal for the Federal Circuit (CAFC) has affirmed with the CIT that the President does not have unlimited tariff authority under IEEPA and that President Trump’s reciprocal tariffs, the fentanyl tariffs on Canada, Mexico, and China, are contrary to law and has sent the case back to the CIT for further consideration. The ruling does not go into effect until October 14, 2025, which will allow time for the government to work on its appeal. The decision did not block the government from still collecting tariffs. This ruling does not include section 232 tariffs or China 301 duties.
Updated Carmichael Tariff Charts
With all the recent changes to the trade environment, Carmichael has taken the opportunity to update our guide on the additional tariffs in an effort to keep our customers informed. Carmichael will continue to update these charts and will post a link to the updates on our memo to our clients. Click Learn More to view our latest version! Tariff charts 08072025