Tariff Deep Dive: Customs Calculation of New Duties and Fees For Shipments Not Eligible for De Minimis Entry

Updated: August 14th, 2025 originally written April 29, 2025

Summary

As of May 2, 2025, goods from China and Hong Kong no longer qualify for Section 321 de minimis entry, and starting in August 2025, this removal applies to all countries. Section 321 previously allowed shipments under $800 to enter the U.S. duty-free with minimal paperwork; now, all shipments must clear customs as either Entry Type 01 (Formal Entry) for goods over $2,500 or Entry Type 11 (Informal Entry) for goods under $2,500—both requiring duties, taxes, and processing fees. This change means higher costs, longer processing times, and stricter compliance requirements for ecommerce importers, making it essential to use accurate HS codes, maintain proper documentation, and adapt supply chains through multi-carrier strategies and global partnerships to stay compliant and minimize delays.

Intro

As of May 2nd, 2025 goods manufactured in China (technically, goods with a China or Hong Kong Country of Origin) no longer qualify for Section 321 de minimis entry.  In August of 2025, the removal of de minimis entry will be unrolled for all countries. This means shipments will no longer eligible for lower scrutiny de minimis clearance. Instead, shipments will need to be processed by U.S. Customs and Border Protection (CBP)  under Entry Type 01 (Formal Entry) or Entry Type 11 (Informal Entry) based on declared value of goods.  Customs calculations will change dramatically when this happens. For U.S. businesses and consumers, previously low value goods have not had to include duties, taxes and fees. The shift away from Section 321 de minimis entry brings new considerations, including duties, taxes, and fees that importers must now account for. Keeping up with the latest regulation changes and tariffs is necessary to keep up with cross border commerce in 2025. 

What does losing Section 321 eligibility mean for your business?

Section 321 allows shipments valued at $800 or less to enter the U.S. duty-free, provided they met certain conditions. With this entry method removed ecommerce sellers and importers must adjust their strategies to comply with formal entry procedures.  Read more at how de minimis removal affectes ecommerce merchants. This change means:

• Higher Costs: Duties, taxes, carrier and customs processing fees now apply.
• Longer Processing Times: The elimination of the fast-track lane and the requirement to use more formal clearance lanes requires additional electronic declarations, paperwork and inspections.
• More Compliance Requirements: Importers must file proper documentation including 10 digit Harmonized System (HS) Codes, accurate declared values and Country of Origin.
• To navigate these new requirements, it’s essential to understand the two main entry types available for ecommerce goods that don’t qualify for the Section 321.

Entry Type 01 vs. Entry Type 11: What’s the Difference?

When importing goods, your shipment will now fall under either Entry Type 01 (Formal Entry) or Entry Type 11 (Informal Entry). Here’s how they compare:

Entry Type 01 – Formal Entry

• Required for shipments valued over $2,500.
• Required for shipments of products subject to quotas, government agency approval, or antidumping and countervailing duties
• Duties, taxes, tariffs, and fees must be assessed and paid before goods are released
• May require additional compliance checks or inspections depending on the product.

Entry Type 11 – Informal Entry

• For shipments valued under $2,500.
• Duties, taxes, tariffs, and fees still apply, but the customs clearance is simplified.
• Reduced customs scrutiny and processing fees
• Faster clearance process compared to Entry Type 01.

The key takeaway? Once de minimis entry is no longer eligible for shipments, it will need to go through customs under another Entry type. If your shipment is under $2,500, it qualifies for Entry Type 11. If it’s over $2,500, it must go through Entry Type 1. Either way, importers should be prepared for additional costs and regulatory steps.

How do you Calculate Customs Costs?

The United States (like all other countries) assesses duties, taxes, tariffs, and specific import fees based upon the commodity HS classification, the country of origin, the customs value, and the type of import. These fees and how they are implemented is explained in the CBP User Fee Table and Federal Register Notice on Customs User Fees To Be Adjusted for Inflation in Fiscal Year 2025. Previously under Section 321, these fees and duties existed but were waived. The main fee we’re touching on here is the Merchandise Processing Fee (MPF).

Entry Type 01 fees:

• 0.3464% ad valorem on Free on Board (FOB) value.
• Minimum fees: $32.71
• Maximum fees: $634.62
• If applicable, $3.93 if the entry needs to be manually processed by a CBP agent.

Entry Type 11 fees:

• $2.62 for Automated Entry or Release Not Prepared by CBP Personnel:
• $7.85 for Manual Entry or Release Not Prepared by CBP Personnel
• $11.78 for Entry or Release Prepared by CBP Personnel

In order to explain, we will go over two examples:

Example 1: Entry Type 01 entry

In this example we will look at a high-value shipment imported into the US with a customs value of $3,000 and was not manually processed by CBP. The steps for calculating costs would be:

First, calculate the ad valorem of $3,000
.3464% of $3,000 = $10.39.

Compare $10.39 to min and max. Since $10.39 is under the minimum, the fee would increase to $32.71 by default.

Add in the applicable duties (including tariffs), which ranges by commodity and country of origin. You can checkout what tariffs have been applied in 2025 at the Trade and Tariff Hub. 

Since the shipment was not manually processed, you do not need to include the additional fee.

Therefore, a $3,000 shipment would have a $32.71 additional fee from customs clearance. This is on top of applicable duties and tariffs.

Example 2: Entry Type 11 entry

In this example we will look at a shipment with customs value of $20. In this example, the shipment will qualify for Automated Entry or Release Not Prepared by CBP Personnel. The steps for calculating costs would be:

Since the shipment will be processed as Automated Entry or Release Not Prepared by CBP Personnel it will incur a $2.62 fee.

Since the Country of Origin is China, it will incur 20% IEEPA and 10% retaliatory tariffs.  

Therefore, a $20 shipment will have a $2.62 additional fee from customs clearance and $6.00 tariff fee. Additionally, if it was mailed through the postal system there would be an additional 120% fee or $100 fee decided upon by the carrier.

The above examples assume that the merchant and their carrier complied with all the declaration requirements and, therefore, there were no additional delays. In cases of non-compliance, shipments will be held at customs, and further charges will be incurred for storage and brokerage. If the shipments are held too long, they will be “Returned to Sender” at the merchant’s expense, auctioned off, or destroyed.

How do you prepare for these changes?

With Section 321 no longer an option, ecommerce businesses should take proactive steps to mitigate disruptions:

• Ensure accuracy of declarations with 10 digits classifications, alongside upfront electronic paperwork submissions to customs in order to avoid penalties and fines.
• Leverage multi-carrier network so they can adapt quickly to ones that can support the optimal lanes in a cost-effective manner.
• Work with a global partner that can help optimize supply chain across manufacturing B2B and DTC regionally.

The removal of Section 321 eligibility for ecommerce shipments will be a significant shift that will impact importers’ bottom lines and logistics strategies. The calculations listed above are just focused on customs fees, they do not touch on additional carrier fees that might apply, import duty, or the 10% import fee issued by the U.S.. Understanding Entry Type 01 and Entry Type 11 will help businesses adjust to the new reality, ensuring compliance while minimizing delays and costs.

As global trade policies continue to evolve, staying informed and adaptable is crucial. If you’re an ecommerce seller or importer, now is the time to reassess your supply chain strategy and plan accordingly.

Need help navigating these changes? Contact us today.