Key Takeaways
- Filing moves to arrival. CBP’s proposal would require Entry Type 11 informal entries for shipments of $2,500 or less to be filed upon or before arrival. This is a significant change, as current rules allow importers to file within 15 days after arrival.
- More data per shipment. Type 11 filings would add the final deliver-to party when it differs from the consignee. New Entry Type 13 postal filings would also carry the sender and the package tracking number.
- Most filers aren’t ready. CBP’s own sampling found that over half of Type 11 entries from September to November 2025 would have missed the earlier deadline.
- Costs rise, and comments close Dec. 7. CBP expects higher shipping costs and stricter duty collection on postal entries, so model the impacts before the comment window closes.
CBP Proposes On-Arrival Filing for Entry Type 11 and New Entry Type 13 Postal Rules
Agency: U.S. Customs and Border Protection | Effective: Not set; proposed rule, comments due Dec. 7 | Authority: Federal Register proposed rule, published Oct. 8
Informal Type 11 entries would be due upon or before arrival and must name the final deliver-to party if it differs from the consignee. Postal shipments filed as Entry Type 13 would need sender and tracking data, and CBP would deem them abandoned after 15 days without a filing.
What CBP put on the table. CBP published a proposed rule in the Federal Register on Oct. 8 that tightens customs clearance for imports moving as low-value informal entries and as international mail. Both entry types cover shipments valued at $2,500 or less [1]. If you feed direct-to-consumer fulfillment from Asia, this would likely impact your operations.
The 15-day cushion goes away. Today you have 15 days after arrival to file an Entry Type 11. The proposal makes the filing due upon or before arrival instead. Operational processes that clean up invoice data after the freight lands would no longer work.
Half the field would miss if the rule passes. CBP sampled entries from September through November 2025 and found that over half of Type 11 imports wouldn’t have met the earlier deadline [1]. That’s the agency’s own baseline, not an outside forecast.
The volume at stake. Roughly 52.4 million Type 11 entries arrived from Sept. 1, 2025, to May 31, 2026, according to CBP. Postal entries added about 24.4 million over the same period [1].
A new required field. The proposal adds the final deliver-to party as a required Type 11 data element when it differs from the consignee. If you ship into a 3PL or a fulfillment center, those two parties can differ. You’ll need the final deliver-to address at the order level, not pulled from a default consignee record.
Mail gets its own entry type. Entry Type 13 is a new processing approach for international mail valued at $2,500 or less. CBP says its data set is “almost the same” as Type 11, plus the shipper or sender and the package tracking number.
Carriers carry part of the load. If passed, carriers would also have to submit the package tracking number on the inward manifest, so CBP can verify the date of importation. That means the tracking number your filer uses would need to be the same one your carrier transmits.
The abandonment clock halves. Type 13 imports would have 15 days to be filed before CBP deems them “voluntarily abandoned,” a change from the current USPS holding period of 30 days [1]. CBP says few items go unclaimed today, but it warns that some importers may not receive shipments under the tighter deadline.
This builds on this year’s postal test. The proposal extends CBP’s earlier rule changes this year to collect more postal data and crack down on noncompliant shipments, including an Entry Type 13 test. CBP framed that test as moving mail “into parity with all other goods being imported into the United States” [1].
CBP would be able to target violative shipments more accurately and efficiently because CBP would receive more data and because entry data would arrive sooner and be more reliable.
U.S. Customs and Border Protection, proposed rule
What enforcement gains. CBP says the changes would help prevent unlawful imports and improve trade compliance. The agency’s stated lever is sooner, more reliable entry data [1]. Early, accurate data is what you would be responsible for controlling.
CBP expects higher costs. The agency says the changes “would result in stricter duty collection for postal entries and higher shipping costs” across both entry types. CBP expects those costs to likely spur a decline in imports [1].
Transit time could go either way. CBP calls the effect on shipping times “ambiguous” [1]. Shippers short on time to gather data could delay imports, or earlier filing could mean goods are released and delivered sooner [2].
USPS faces a rebuild. USPS estimates that system updates for Type 13 would cost up to $20 million and take up to eight months [1]. Longer average holding periods could also strain storage at USPS facilities.
The post office lacks warehousing. CBP notes that USPS Office of Exchanges were designed for flow-through processing without warehousing capacity. USPS expects to need initial warehouse capacity equal to 80% or more of import volume under the rule [1]. If you ship by mail, build buffer into your delivery promises.
The window to push back. Comments must be received on or before Dec. 7 [1]. If pre-arrival filing breaks your Asia-to-consumer flow, use the comment docket to document why.
Importer of Record Liability & Exposure Matrix
| Entry Type or Element | Current Standard | Proposed Requirement | Importer Exposure |
|---|---|---|---|
| Entry Type 11 ($2,500 or less) | Filed within 15 days of arrival | Filed upon or before arrival | Over half of sampled entries would have missed the deadline |
| Final deliver-to party | Not a required data element | Required if different from the consignee | Order-level delivery data needed at filing |
| Entry Type 13 (postal, $2,500 or less) | Under CBP test since earlier this year | Sender and tracking number on the entry; carrier lists tracking number on the inward manifest | Stricter duty collection and higher shipping costs, per CBP |
| Postal abandonment | USPS holds items for 30 days | Deemed voluntarily abandoned after 15 days without a filing | Some shipments may not reach the importer |
5-Point Importer Compliance Action Checklist
Immediate Risk Mitigation Steps for Importers:
- Time your vendor data. Measure when commercial invoice, value, and classification data reaches your broker today, and move it ahead of vessel or flight arrival.
- Capture the deliver-to party. Add the final delivery point, whether a 3PL, a fulfillment center, or a store, to the purchase order so your filer doesn’t fall back on a default consignee.
- Match tracking numbers. If you ship by mail, confirm that your filer and your carrier transmit the same package tracking number and sender details.
- Model the cost increase. Build higher shipping and brokerage costs and stricter postal duty collection into the landed cost of your low-value SKUs before the rule is final.
- File comments by Dec. 7. Work with your broker or trade association to document where pre-arrival filing doesn’t fit your sourcing and fulfillment timeline.
