China Mail to the U.S.: Entry Type 13 and CPSC Checks

CPSC announced its mail-specific eFiling guidance on September 1. Its document library also lists a refreshed HTS guidance document dated September 14. Expeditors reported on Entry Type 13 implementation support on September 11. These are current operational signals, not evidence of search volume or a rise in violations.

The July edition of this guide focused on the postal rule’s initial effective date. This update adds the mail certificate deadline, a parcel-to-certificate handoff and release controls for changed labels and mixed product versions.

CBP’s postal interim final rule generally took effect July 24, 2026, with its de minimis suspension provision effective June 24. The rule gives October 22 as the compliance date for two specified formal-entry provisions, 19 CFR 145.12(a)(2)(v) and (vi). The former July comment deadline has passed.

CBP’s published schedule sets September 22 for the Entry Type 13 test in ACE production. CPSC separately identifies October 22 for eFiling required certificates for mail shipments, using a Full or Reference Message Set.

Plan against the applicable entry timing, not just the day a warehouse prints a label. If transit may cross the October date, ask the broker how the shipment will be handled and have the required evidence ready before dispatch.

No. CBP describes a voluntary test for qualifying international mail valued at $2,500 or less. It includes a temporary path for certain PGA-data and additional-duty shipments; AD/CVD and quota shipments remain excluded. Participation does not remove other product or customs obligations.

Do not read the CPSC mail announcement as permission to put every shipment into Entry Type 13. Have the broker confirm eligibility, who may make entry, the required bond and any formal-entry alternative. Keep the certificate requirement and entry-type selection as separate decisions.

Name the responsible importer and broker before instructing the supplier to dispatch. Record who supplies product facts, who approves certificate coverage, who transmits the filing and who handles rejection or correction messages.

CPSC assigns certificate responsibility to the importer under its applicable definition. CBP’s test notice separately sets out who has the right to make an Entry Type 13 filing. A consolidator’s promise to “handle customs” does not document these roles for the buyer.

Use a brief handoff record with the responsible parties, agreed entry path, shipment reference, approved data version and open issues. Ask for acknowledgment that the broker has the required data; do not describe this acknowledgment as customs clearance.

Build the file around a stable parcel reference. Beside it, record the foreign-post tracking number, SKU and version, quantity, invoice line, actual product description, origin evidence and the broker-approved classification and value instructions.

Keep the importer’s Full Message Set data or Reference Message Set identifiers in the same controlled handoff. CPSC’s FAQ describes both methods. The product identifiers must resolve to the goods inside the parcel, not merely to a supplier’s catalogue image.

At the warehouse, compare the approved register with sampled goods, product markings, retail packaging, warnings and shipping labels. Record what was accessible and sampled. Keep the final file, photographs and corrections together so the entry owner can see which version was approved.

No. CPSC’s September HTS guidance says its list does not cover every code where an electronic certificate may be required. Product-specific certification scope needs a separate decision; an absent flag is not evidence of an exemption.

Ask the qualified compliance owner to review the actual product’s function, intended users, materials and features. A light-up cup, for example, needs a description that preserves its battery feature. A generic “plastic cup” description can hide information the reviewer needs.

Record the guidance version checked and the reason for the scope decision. Do not alter descriptions, values, age labels or routing to avoid review. If supplier evidence changes, reopen the affected decision before release.

A changed tracking label, mixed product versions, a substituted component or a certificate reference that no longer resolves to the goods should trigger a hold on the affected scope. These are buyer control triggers, not automatic legal findings.

For relabeling, preserve the old-to-new tracking map, photograph the replacement label and get the updated file acknowledged. For product changes, ask the importer and qualified technical reviewer what evidence must be replaced or supplemented.

If cleared and held parcels share a sack, pallet or pickup instruction, separate them before handoff. Give the forwarder or postal consolidator an explicit list of parcels authorized to move.