Don't Blame De Minimis, Blame Type 86: The Untold Story of the eCommerce Import Surge
Rethinking the De Minimis Debate
When people discuss the surge of de minimis shipments into the U.S., most point to the 2016 increase of the duty-free threshold to $800. But the real driver wasn’t the dollar limit—it was an operational fix gone wrong: the launch of Type 86.
For e-commerce platforms, sellers, importers, and logistics providers, understanding this story is crucial for navigating the present and planning for the future.
The Old Guard: A System of Control and Compliance
Most look to the expansion of the duty free threshold /de minimis from $200 to $800 as causing a flood of imports. In fact, it was a "test" entry type developed by US customs. It is referred to as "type 86." These new processes were referred to as a test. It combined an manifest type process into brokerage systems. This allowed import of millions of parcels per day to the USA without duty, funding to customs, to any port of entry, using any mode of transport.
Express Consignment as the Standard
Before Type 86, most de minimis shipments flowed through express consignment facilities (ECCFs/ECOs). This system offered:
- Self-Funded Oversight: Express carriers paid a per-HAWB fee, generating billions to fund U.S. Customs operations.
- Integrated Control: Carriers worked directly with CBP on targeting and security.
- A Responsible Party: Bonded, U.S.-based operators ensured accountability.
Limited Alternatives
Other channels—like postal networks, truck manifests, or local port releases—existed but were smaller in scale and lacked strong automation or oversight.
Postal Imports deserve a separate mention. Commercial carriers have been complaining for decades about the postal import advantages. Technically, postal clearance seemed to fall under the Department of State and part of the larger Universal Postal Union (UPU) processes. But, despite some regulatory updates, imports via the USPS were subject to much less oversight.
The Crisis + Quick Fix = Disaster
A Backlog of Manual Releases
With direct-to-consumer e-commerce volumes exploding, CBP faced a flood of manual requests—over 250,000 annually—that legacy systems could no longer handle. That number (250,000) would soon become minuscule as compared to the millions per day following the "type 86 test."
Why Not the Express Model?
Although effective, the express model was seen as too restrictive because it favoured one transportation mode. CBP needed a fast, automated, mode-neutral solution.
The Birth of Type 86
Modeled after the courier manifest system but integrated into the Automated Broker Interface (ABI), Type 86 was designed to automate de minimis entries and even include Partner Government Agency (PGA) data for compliance. In other words, rather than adopting the stricter (19 CFR, Part 128) express processes, customs decided to use a manifest system.
Type 86: An Unintentional Catalyst
Intended Goal
Type 86 was never meant to change policy—it was an emergency fix to streamline automation across modes of transport. In fact, it was referred to as a "test."
Unintended Consequences
- Lost Revenue and Oversight
The per-HAWB fee disappeared, cutting a major source of customs funding. - Weakened Controls
The strict, integrated control of the express system was no longer universal. - Explosive Growth of eCommerce Imports
By broadening access without equivalent oversight: Type 86 triggered massive growth in small-parcel imports with reduced visibility for CBP.
“These packages are still being imported just as an 01 entry with less ultimate consumer information at the individual package level.” — customs veteran
In other words, CBP now has less visibility and data for targeting, making it harder to detect illicit or non-compliant goods.
The Path Forward for eCommerce and Logistics
Lesson Learned
Operational fixes can reshape trade policy in ways no one anticipated. The challenges with de minimis today stem less from the $800 threshold and more from Type 86’s lack of accountability structures.
Building a Smarter Strategy
1. Highlight Compliance
Show how your business prioritizes transparency and provides full data visibility to customs—even for low-value parcels. Build processes using consolidated informal entries.
2. Offer Controlled Solutions
The processes are not so much as demanding as they simply demand more information. You need to where the goods were manufactured, their HS code, value and consignee details. Clearance from there is pretty straightforward.
3. Educate Your Clients
Share the new customs rules and operational realities with your clients. Knowledge is a competitive advantage.
Conclusion: Turning History into Strategy
Type 86 was meant as a quick operational fix, but it became a turning point for global trade. The turning point is back to express or express type processes of consolidating waybills into a single entry.
