Question: If goods are made in China and shipped to another country (i.e. Mexico, Canada, Japan, etc.) for entry to the U.S., can it qualify for de minimis treatment once it reaches the U.S.?
Answer: No. In accordance with Executive Order 14256 of April 2, 2025, as of May 2, 2025, all imported products of the PRC (including Hong Kong) are no longer eligible for the administrative exemption under 19 U.S.C. § 1321(a)(2)(C). Imported products of the PRC, except for products mailed through the international postal system, must now be entered under an appropriate entry type such as a type 01 for formally entered merchandise, or type 11 for informally entered merchandise.
For mailed products of the PRC sent from the PRC or Hong Kong that are valued up to $800, and would have been eligible for the de minimis exemption but-for Executive Order 14256, applicable duties are payable to CBP by a carrier and a carrier’s bond must be obligated for this purpose. We note that this requirement applies to products of the PRC sent from the PRC or Hong Kong that are mailed to another country but ultimately destined for the U.S.
Question: Can products of China and Hong Kong that are shipped through international mail from other countries qualify for de minimis clearance?
Answer: No. In accordance with Executive Order 14256 of April 2, 2025, as of May 2, 2025, all imported products of the PRC (including Hong Kong) are no longer eligible for the administrative exemption under 19 U.S.C. § 1321(a)(2)(C). Imported products of the PRC, which are mailed to another country from the PRC or Hong Kong, but ultimately destined for the U.S. are thus ineligible for the de minimis exemption.
For mailed products of the PRC sent from the PRC or Hong Kong that are valued up to $800, and would have been eligible for the de minimis exemption but-for Executive Order 14256, applicable duties are payable to CBP by a carrier and a carrier’s bond must be obligated for this purpose.
For mailed products of the PRC (including Hong Kong) sent from the PRC or Hong Kong that are valued over $800, or products that would not have been eligible for the de minimis exemption without regard to Executive Order 14256 (such as products subject to AD/CVD or quota), formal entry pursuant to 19 C.F.R. § 145.12(a) is required during the temporary suspension of 19 CFR § 145.12(b).
