Tariffs and Landed Cost: What Changed for Importers in 2026

5

The $800 duty-free threshold that shaped a decade of ecommerce sourcing is gone, and the 2026 rulemaking made its absence permanent rather than provisional. That is the change importers need to price into their cost of goods sold, and most have not, because the shift arrived in stages across eighteen months rather than as a single event with a headline.

The sequence below covers what changed, what it now requires of you operationally, and why your landed cost model is probably still running on 2024 assumptions.

The chronology

Executive Order 14324, signed July 30, 2025, suspended duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for all countries. It took effect August 29, 2025. Executive Order 14388, signed February 20, 2026, continued that suspension.

On June 24, 2026, US Customs and Border Protection issued interim final rules indefinitely suspending the de minimis exemption across all modes of importation and establishing a new informal entry and bonding process for international mail shipments.

Separately, the One Big Beautiful Bill Act, Public Law 119-21, at section 70531(b)(3), statutorily eliminates the de minimis basis effective July 1, 2027. That is the detail that changes the strategic calculus. Executive orders can be reversed by a subsequent administration. A statutory repeal cannot, absent new legislation.

The practical reading: anyone still treating the suspension as a temporary policy fluctuation to be waited out is planning against a scenario the statute has already closed.

What the rules require now

CBP’s own E-Commerce Frequently Asked Questions, last updated July 17, 2026, set out the operational detail. The suspension applies to merchandise valued at $800 or less arriving via all modes, including the international postal network, unless specifically excepted under separate authority.

Formal or informal entry procedures now apply to shipments that previously moved duty-free. Informal entry is generally allowed for shipments valued at $2,500 or less, subject to eligibility. Formal entry is required above $2,500 and for merchandise subject to quotas or antidumping and countervailing duties.

The new mail informal entry process took effect July 24, 2026. It requires a basic importation and entry bond, single transaction or continuous, containing the conditions in 19 C.F.R. 113.62, activity code 1, effective and on file in ACE eBond before any activity occurs under it. Duty payment must be transmitted via Pay.gov no later than the seventh day of the month following arrival, on the same deadline as the International Mail Duty worksheet. Shipments arriving without the required data or bond are not released from CBP custody.

A further narrowing lands soon. Effective October 22, 2026, merchandise claiming Chapter 98 duty-free treatment, merchandise subject to Chapter 98 or 99 duties, merchandise claiming free trade agreement duty-free treatment, and merchandise subject to Partner Government Agency requirements are excluded from the new mail informal entry process and must use another entry type.

Two carve-outs survive. Exemptions for bona fide gifts under 19 U.S.C. 1321(a)(2)(A) and for personal or household articles accompanying travelers under 19 U.S.C. 1321(a)(2)(B) are unchanged. CBP is explicit that a bonus article given in conjunction with a purchase is not a bona fide gift, which forecloses a workaround somebody was always going to try.

On fees, mail shipments remain exempt from the Merchandise Processing Fee, except items sent through Inbound Express Mail service. CBP is also running a voluntary Entry Type 13 Test for electronic informal mail entry filed in the Automated Commercial Environment.

Why this hits landed cost harder than the duty rate suggests

The instinct is to model the change as a duty percentage added to unit cost. That understates it, because the compliance overhead is not proportional to shipment value.

Under de minimis, a $600 shipment carried effectively no entry cost. Now the same shipment carries duty at its Harmonized Tariff Schedule classification rate, a bond obligation, entry filing, and either broker fees or internal labour to produce a ten-digit HTSUS classification, country of origin, quantity and weight, and duty calculation. Those costs are largely fixed per shipment.

The result is a strong penalty on small, frequent shipments and a mild one on large, infrequent ones. A brand that moved to weekly air freight of small quantities to hold down working capital has just had its per-unit cost structure inverted relative to a competitor consolidating into monthly ocean containers.

That is a sourcing strategy question, not an accounting one, and it is worth modelling explicitly rather than discovering through a year of margin compression.

The accounting consequence nobody budgets for

Landed cost is unit price plus inbound freight plus duties and tariffs plus customs brokerage plus any prep or inspection cost. Every one of those components except the first has moved for importers since August 2025, and duties in particular moved from zero to a real number on a category of shipment that previously carried none.

If your cost of goods sold is calculated as a percentage of revenue, or as an average landed cost set at some point in the past, your reported margin is currently wrong and wrong in a flattering direction. Under the accrual method, cost of goods sold should reflect the actual landed cost of the specific units that shipped. A duty paid in March on inventory that sells in August belongs in August’s cost of goods sold, allocated to those units.

This is where the operational and accounting problems intersect. Allocating duty to units requires the duty amount to be captured at the shipment level and then pushed down to the SKUs in that shipment, weighted appropriately. Purchase order systems that track only unit price cannot do it. Landed cost allocation at the item level is a specific capability, available in some inventory-aware accounting platforms including ConnectBooks and in the higher tiers of general ledger products, and absent from most settlement reconciliation tools entirely. Sellers who assumed their sync tool handled cost of goods sold often find it handles revenue and fees only.

What to do about it

Four things, in order.

Reprice your landed cost model with current duty rates. Not last year’s, and not an average. Rate depends on HTSUS classification and country of origin, and both need to be right at the SKU level. If you have never classified your own products and have been relying on a supplier’s declaration, that is an exposure as much as a cost problem.

Move duty into cost of goods sold rather than operating expense. Duty is a cost of acquiring inventory and belongs in the inventory value, which means it flows to cost of goods sold when the unit sells. Booking it as a period expense at the time of payment misstates both inventory on the balance sheet and margin in the month of import.

Model shipment consolidation. Run the arithmetic on your current shipping cadence against a consolidated one, including the working capital cost of holding more inventory. For many importers the answer has flipped since 2024.

Get professional help on classification and entry. This piece describes how the rules work in general terms. It is not customs or legal advice, and nobody should file an entry based on a blog post. CBP’s guidance is the primary source and a licensed customs broker is the person who should be reading it on your behalf.

The position

The de minimis era subsidised a specific business model: small, frequent, low-value cross-border shipments direct to consumers or into US fulfilment. That subsidy has been withdrawn by executive action, extended by rulemaking, and scheduled for statutory elimination on July 1, 2027. Brands built on it need a different cost structure, not a better tariff engineering scheme.

The importers who handle this well over the next eighteen months will be the ones whose cost of goods sold reflects reality at the unit level, because they will see the change in their own numbers as it happens rather than in an annual review. The ones running on estimated landed cost will find out when the year closes, and by then the pricing decisions made on wrong margin data will already be a year old.