For decades, one of the principles underpinning trade facilitation was that some transactions were too small to justify the cost of scrutinizing them. The United States’ de minimis exemption reflected this, allowing eligible goods valued at US$800 or less to enter duty-free with simplified customs procedures.

What had been a simplified administrative process became the means for a new model of international commerce, making it easier for goods to be sold directly to consumers and shipped individually rather than through conventional wholesale and retail networks. Large Asian e-commerce platforms were among the clearest beneficiaries. The US House Select Committee on the Chinese Communist Party estimated in 2023 that Shein and Temu together accounted for more than 30% of daily US de minimis packages and nearly half of de minimis shipments to the US from China.

This model lowered the cost of cross-border commerce, which widened consumer access to inexpensive goods. Its proliferation also created some backlash. US policymakers have argued that the sheer volume of small parcels made it harder to detect illicit goods and enforce trade rules, creating opportunities for tariff evasion and depriving the government of revenue. The model has also drawn criticism over environmental impacts, labor-related concerns, and competitive pressure on domestic retailers and manufacturers.

As of mid-2025, the US suspended duty-free de minimis treatment for low-value shipments from all countries. That means all shipments that previously qualified for the exemption must now go through a formal or informal customs entry and be assessed for applicable import duties, taxes, and fees, subjecting low-value shipments to more detailed customs information requirements.

In order to efficiently process the enormous volume of low-value international mail under more complex customs procedures, on September 22, 2026, U.S. Customs and Border Protection (CBP) plans to begin testing a system named the Entry Type 13 Test (ET 13). Under the test, eligible international mail shipments valued at US$2,500 or less that qualify for informal entry can be entered electronically through the Automated Commercial Environment (ACE). Customs authorities will receive detailed shipment-level information, including the importer of record, country of origin, merchandise description, tracking number, 10-digit US tariff classification, value, duty rate, and duty owed.

This points toward a model in which the ability to participate in international trade increasingly depends on the ability to make individual transactions legible to governments as structured data.

Visibility is becoming a condition of market access, enabling both control and speed

Under the Entry Type 13 test, participating carriers will be able to transmit the foreign postal tracking number associated with an individual shipment. Where both the carrier and filer participate, CBP can match that number against the tracking number contained in the electronic customs entry, connecting the arrival of a physical parcel to its customs record. In this way, granular information is attached to each individual transaction and made usable by the state, giving every parcel a digital identity alongside its physical one.

There are good reasons why governments want this information. First, borders are enforcement points for rules concerning counterfeit goods, alongside conventional customs functions. Better information can theoretically allow authorities to identify suspicious consignments while allowing legitimate, lower-risk trade to move with less physical intervention.

Second, this information can create supply chain visibility that supports economic security policies. Structured data collected across millions of transactions can provide a granular picture of, among other things, what an economy imports and where products originate. Governments seeking to identify strategic dependencies or enforce restrictions need information about the supply chains they are attempting to regulate. Greater digital visibility is partly what makes more targeted intervention possible.

Along these lines, greater data visibility could allow governments to exercise more effective control while also enabling faster trade. But there is a distinction between a government having the capacity to receive and use this data (or believing it has the capacity to do so) and the global trading system being capable of generating it.

The cost of making trade visible favors scale

While ET 13 will begin as a voluntary test for eligible participants, under the test an individual parcel arriving at the US border must be accompanied by information on its tariff classification, origin, value, and tracking number. That information may have to pass from a buyer, foreign seller, or designated customs broker before reaching ACE. The usefulness of the US system therefore depends partly on the quality and compatibility of the information generated upstream.

A highly digitalized destination country can impose sophisticated information requirements on goods originating in economies with considerably less developed customs and trade infrastructure. A United Nations survey puts global implementation of cross-border paperless trade measures, such as legal recognition of data from foreign trading partners and the use of global digital standards for trade, at only approximately 50% in 2025. If national systems use different data formats and procedures, firms must repeatedly translate commercial information into whatever form each customs administration regime requires.

This matters particularly for smaller businesses. A large e-commerce platform processing millions of transactions can invest in custom software and specialist compliance teams. Once that infrastructure is in place, the marginal cost of generating a customs record for an additional parcel may become extremely small. A small exporter shipping only a few hundred parcels, by contrast, does not enjoy the same economies of scale. Where firms cannot perform these functions themselves, they must purchase services capable of producing this data from customs brokers or other intermediaries. More demanding digital customs requirements could increase the importance of large intermediaries like e-commerce platforms and trade-technology companies capable of converting commercial information into customs-compliant data.

The World Trade Organization has long recognized that such trade costs fall disproportionately on smaller firms, which generally have fewer resources to navigate customs and information requirements. The resulting selection effect could be significant. Some smaller exporters may instead conclude that serving the US market is no longer economical.

Reducing excessive dependence on China (the US administration explicitly framed de minimis reform as part of resetting economic competition with China) ultimately requires expanding the number of firms and economies capable of supplying global markets. Digital commerce can provide small and medium-sized enterprises (SMEs) with a relatively accessible route into exporting. A producer can test demand by selling small quantities directly to foreign consumers without first establishing a physical presence. Successful firms can then learn and expand. If access to major consumer markets increasingly requires sophisticated customs data capabilities before that process can begin, the entry point into international trade may become too costly. The result could be to favor established or large firms that can absorb these costs, while making it harder for smaller firms to enter and for new suppliers to emerge — potentially working against the broader objective of diversifying supply away from China.

The architecture replacing de minimis could reshape trade

The success of the current US test should be judged by more than how efficiently ACE can process ET 13 declarations or how effectively it supports the collection of duties owed. De minimis reduced the administrative cost of low-value trade by requiring governments to know relatively little about each parcel. The emerging model attempts to preserve as much as possible the speed of small-parcel trade while making each transaction considerably more visible.

That changes how ET 13 should be judged. The first test is whether governments can turn more data into better enforcement. Collecting data is useful only if authorities can process it effectively and use it to make better decisions, for example, by improving enforcement against illegal goods and increasing revenue collection.

The second is what it costs to produce that visibility. Those costs may initially fall on exporters, e-commerce platforms, customs brokers, or customs authorities, but some may ultimately be passed on to consumers through higher prices or fewer choices. The effects are also unlikely to be evenly distributed. A system that improves enforcement but raises costs for smaller exporters or diverts trade toward markets with lower information requirements may solve one policy problem while creating others.

The final test is broader still. Does achieving the objectives of the new customs system produce better economic outcomes overall? The system can function exactly as intended — collecting more duties and advancing economic security objectives — and still not produce better economic outcomes. For example, reducing one form of supply chain dependence matters less if higher barriers to entry make it harder for alternative suppliers to emerge in the long run.

The ultimate challenge is to make trade more visible without making legitimate international commerce unnecessarily more expensive or less diverse.