De Minimis for Pet Product Imports | JustForPetStore

De Minimis for Pet Product Imports | JustForPetStore

De minimis for pet product imports is gone for practical purposes. U.S. Customs and Border Protection indefinitely suspended the $800 administrative exemption for non-postal shipments on June 24, 2026, and for postal shipments with a new informal entry process from July 24, 2026. Every shipment now needs formal or informal entry, a 10-digit HTSUS number and duty paid. Plan around three things: entry type, classification and records.

What changed, and when did it take effect?

The suspension has two dates because CBP wrote two rules. Executive Order 14324 of July 30, 2025 suspended duty-free de minimis treatment for all countries, and that suspension took effect globally on August 29, 2025. Executive Order 14388 of February 20, 2026 continued it. Per CBP’s own e-commerce guidance, the suspension took effect on the date of publication in the Federal Register for both non-postal and postal shipments, and the new mail informal entry process took effect July 24, 2026.

Then CBP moved the suspension into its regulations. The interim final rule published June 24, 2026 at 91 FR 37789 amends 19 CFR Part 10 to implement an indefinite suspension of the de minimis administrative exemption under 19 U.S.C. 1321(a)(2)(C) for merchandise valued at $800 or less, imported by one person on one day, arriving through any mode other than the international postal network. It was effective on publication. A companion rule at 91 FR 37801 covers the international postal network. You can read the regulatory text at 91 FR 37789.

The practical statement from CBP is short and worth quoting to your supplier: because of the suspension, all entries of merchandise valued at $800 or less arriving through all modes must use formal or informal entry procedures. There is no value threshold under which a commercial pet product shipment simply waves through.

Which shipments are still exempt?

Two narrow categories, and neither helps a restocking order. The exemption for bona fide gifts under 19 U.S.C. 1321(a)(2)(A) is unchanged, and so is the exemption for personal or household articles accompanying travelers under 19 U.S.C. 1321(a)(2)(B). Bona fide gifts are defined at 19 CFR 10.153(a) as articles formerly owned by a donor who gave them outright, in their entirety, to a donee without compensation or promise of compensation.

That definition does more work than it looks like. It excludes articles acquired by purchase, barter or promissory exchange, and it specifically excludes anything said to be a gift in connection with a purchase, such as a so-called bonus article. A supplier who marks a commercial invoice “gift” to move a low-value parcel is not using the exemption, and misdescription on an entry is a compliance problem rather than a shortcut.

What entry type applies to a low-value pet shipment?

Informal or formal, decided by value and by product. CBP’s e-commerce guidance states that informal entry is generally allowed for shipments valued at $2,500 or less, subject to eligibility, while formal entry is required for shipments exceeding $2,500 and for certain types of merchandise such as goods subject to quotas or antidumping and countervailing duties. Shipments sent to the United States from APO, FPO or DPO military addresses are not dutiable, because they remain in the domestic mail stream.

Most independent retailers importing pet toys, coats or bowls will land in the informal band, which is the good news and the bad news: the paperwork is lighter than a formal entry, but it is no longer zero. Work with a licensed customs broker on the first few shipments and ask them to walk you through the entry summary, because the entry is the record that a later audit will start from. CBP’s entry summary overview explains where the process sits in the wider trade workflow.

What data does CBP require for the mail informal entry process?

This is the part that catches small importers out, and it gets stricter on October 22, 2026. Under the new mail informal entry process, merchandise imported by mail valued at $2,500 or less and eligible for informal entry may be entered this way, but effective October 22, 2026 the following are excluded from eligibility: goods for which duty-free treatment is claimed under Chapter 98 of the HTSUS, goods subject to duties under Chapter 98 or Chapter 99, goods for which duty-free treatment is claimed under a free trade agreement, and goods subject to Partner Government Agency requirements. Anything excluded must use another process, such as an Entry Type 13 or a formal entry.

CBP also limits who may file. Entry under the new process is limited to parties with the right to make entry under 19 CFR 143.26(a): the owner or purchaser of the merchandise, or a licensed customs broker properly designated by the owner, purchaser or consignee. The required data set includes filer code, value, bond number, total duty owed, description of merchandise, carrier, country of origin, flight or conveyance number, 10-digit HTSUS classification, tracking number, quantity or weight, arrival port, duty rate and arrival date. Filing is by Excel or CSV spreadsheet emailed to CBP no later than the seventh day of the month following arrival, per CSMS message 69183472. The full list sits in CBP’s e-commerce frequently asked questions.

How does this change your landed cost?

It adds three lines you used to be able to ignore. Duty comes first, and the rate is whatever your 10-digit HTSUS classification carries, which is why classification is now a sourcing decision and not a customs formality. Fees come second: merchandise processing and harbor maintenance charges apply to formally and informally entered goods under CBP’s user fee schedule. Broker and filing costs come third, and they are flat enough to hurt disproportionately on a small parcel.

Model it before you commit to a purchase order. Take one representative SKU, ask your broker for the duty rate against its classification, then build a landed cost per unit that includes product cost, inland freight, ocean or air freight, duty, fees and broker charges. Compare that number to your retail price and your target margin. A line that cleared 55% gross margin when it entered duty-free can fall below 40% once duty, fees and broker charges are loaded, and that difference is the whole decision on whether to reorder.

What should a small importer do this month?

Five moves, in order. First, get a 10-digit HTSUS classification in writing from your supplier for every active SKU, and verify it against a CBP cross ruling before you rely on it. Classification errors are the most common and least forgiving import mistake. Second, consolidate shipments. If you are placing six small orders a month, four consolidated shipments carry meaningfully less broker and filing overhead than twelve parcels, and consolidation is now cheaper than it was under de minimis.

Third, decide your entry strategy with a broker rather than guessing, and ask specifically whether any of your goods are subject to Partner Government Agency requirements, because that exclusion bites from October 22, 2026. Fourth, update your purchase order template so unit cost, freight, duty, fees and broker charges are captured at the line level. Fifth, reprice. Any SKU whose landed cost moved more than a few points needs a new retail price or a new supplier before the next season.

How long do you need to keep the records?

Keep everything, and keep it organized by entry. CBP’s recordkeeping rules generally run five years from the date of entry, and the list is longer than most small importers expect: the commercial invoice, packing list, bill of lading or airway bill, entry summary, classification worksheet, supplier declaration, and any Partner Government Agency documentation. Digital copies are fine as long as you can produce them in a readable form on request.

The reason to be strict is that the record is the defense. When CBP asks why a shipment of pet treats was classified the way it was, the answer is a document, not a memory, and the person who classified it may not be at the company in three years. Build one folder per shipment, name it with the entry number and the date, and file it the week the goods arrive rather than at tax time.

Where does this leave the independent pet retailer?

Better positioned than the drop-shipper who built a model on duty-free parcels, because a store that buys by the carton already has a broker, a freight forwarder and a purchase order process. The adjustment is arithmetic rather than structural. If you are rebuilding assortments around the new cost base, start with categories where a single consolidated shipment covers a full season, such as the dog apparel wall, core dog toys and impulse cat toys.

Test before you commit. Our low-MOQ wholesale program lets you prove a category with a small, consolidated order instead of a container, and contact us for HTSUS codes, landed-cost quotes and consolidated shipping schedules before you place the next purchase order.

Sources: U.S. Customs and Border Protection, E-Commerce Frequently Asked Questions; CBP interim final rule, Indefinite Suspension of the De Minimis Exemption, 91 FR 37789 (June 24, 2026), CBP Dec. 26-12, docket USCBP-2026-0760; companion rule at 91 FR 37801; CBP CSMS message 69183472; Executive Orders 14324 and 14388.