Importing from China in 2027: De Minimis, Duty and Documents

By David Stan, Brands Manager at China Clothing Manufacturer. Published October 2026.

The single most important thing to know about importing from China in 2026 is that the rule most guides describe no longer exists. The $800 de minimis exemption, which let low-value shipments enter the United States duty-free, is gone.

It ended for China and Hong Kong on 2 May 2025, and was then suspended for every country worldwide, fully implemented by CBP on 29 August 2025 (US Customs and Border Protection). CBP has since collected over $1 billion in duties on more than 246 million low-value shipments (CBP).

If your import plan assumes small parcels arrive duty-free, it is a plan built on a rule that was withdrawn. This guide covers what replaced it, how duty actually stacks, which freight mode suits which shipment, and the documents without which nothing clears. Importing into Great Britain instead? Read our guide to importing clothing from China to the UK.

What Happened to the $800 De Minimis Exemption?

It was suspended, in two stages, and the second stage covered the whole world. Business models built on shipping individual parcels below a value threshold no longer work as they did, and any landed cost model still assuming duty-free entry is modelling a regime that has gone.

For China and Hong Kong the change took effect on 2 May 2025. Goods valued at or under $800 that would previously have entered duty-free became subject to all applicable duties. Postal items became subject to a separate duty, set as a percentage of value or a flat per-item charge, and those rates were revised several times during 2025 (Federal Register, 2025).

The broader suspension followed. CBP fully implemented worldwide elimination on 29 August 2025, and a Federal Register notice of 24 June 2026 made the suspension indefinite for merchandise arriving through all modes other than the international postal network. A companion rule published the same day did the same for mail shipments and set up a new postal entry process.

What it means in practice

Three things change for a small importer. Every shipment now needs a customs entry, which means classification and paperwork rather than a parcel arriving. Duty applies from the first dollar, so the landed cost of a sample order is materially higher than it was. And enforcement tightened: CBP reports seizures of unsafe and non-compliant low-value goods up 82% since the change.

What Has Changed at the Border Since the Rule Ended?

Volume and scrutiny both. CBP reports collecting over $1 billion in duties on more than 246 million low-value shipments since the phase-out began in May 2025, and seizures of unsafe and non-compliant low-value goods up 82% (CBP). The scrutiny extends to product compliance, not only to duty collection.

For an importer the practical effect is that small shipments now behave like large ones. They need a classification, they need a description that supports it, and they get looked at. The informal route that many first-time importers relied on has closed.

How Does Duty Actually Stack?

Duty on Chinese apparel is not a single rate. Several layers apply to the same goods, and the total depends on how the garment is classified rather than on anything you negotiate with a supplier. That makes classification accuracy a commercial decision rather than an administrative one, because it sets the largest cost line in most apparel imports.

Because classification drives the largest cost line in most apparel imports, and because the layers have changed repeatedly, the full treatment lives on its own page. See tariffs, HTS codes and duty layers on Chinese imports for how apparel is classified, how origin is determined, who actually pays, and how to build a landed cost model you can plan against.

The point worth carrying into the rest of this guide: duty is frequently a larger line than the freight. An import plan built around shipping cost while treating duty as a rounding error has optimised the smaller number.

Which Incoterm Should You Ask For?

The Incoterm decides where the supplier's responsibility ends and yours begins, and it is the reason two quotes for the same goods can differ by thirty percent and both be honest. Comparing prices quoted on different terms is comparing different products, and normalising them is the first thing to do with any set of quotations.

Structural guidance. Confirm terms and responsibilities in writing on every order.

Ask everyone for FOB. It is the only term that isolates the factory price, so comparing two FOB quotes compares two factories. Comparing two DDP quotes compares two freight forwarders and tells you nothing about who makes the better garment.

EXW is rarely the bargain it looks like

Ex-works quotes come back lowest, which is why they are tempting. What they exclude is export clearance, inland haulage to the port and terminal handling at origin, all of which you then arrange in a country where you probably have no relationships. Unless you already have a forwarder in China, an EXW price is a number you cannot actually execute against.

The DDP question nobody asks

Under DDP the supplier arranges clearance, which means someone is filing an entry on your behalf. Ask who the importer of record is on that filing. If it is you, the classification and the liability are yours regardless of who arranged it.

Which Freight Mode Suits Your Shipment?

Four options, and the fixed costs matter more than the rate per kilo on small shipments. Documentation, terminal handling, customs entry and delivery are broadly the same whether the shipment is two cubic metres or twelve, which is what makes small ocean consignments expensive per unit.

Courier is fast, simple and expensive per kilo, but it bundles clearance into the service. For samples and very small orders it is usually still correct.

Air freight beats courier on rate at moderate weight, then adds brokerage, handling and destination charges that do not shrink with the shipment.

Sea LCL, less than container load, is cheap per kilo and slow, and carries port fees, deconsolidation and brokerage regardless of volume. On a small consignment those fixed charges can exceed the freight itself.

Sea FCL, a full container, is cheapest per unit and irrelevant until you can fill one.

What Documents Do You Need?

Five, and the clearance process reads all of them together. A shipment missing one sits at the port accruing storage charges while everyone emails about it. The requirement that causes most delays is not any single document but consistency: carton counts, descriptions and values must agree across all of them. Consistency is also a legal exposure rather than an administrative one, and CBP publishes what a new importer is expected to file, including the Importer Security Filing on ocean shipments (CBP).

• Commercial invoice. Value, currency, Incoterm, and a description specific enough to classify. "Garments" is not a description.
• Packing list. Cartons, weights, dimensions, and what is in each carton.
• Bill of lading or air waybill. The transport document and, for sea freight, the document of title.
• Certificate of origin where required. Origin follows the goods, not the label on them.
• Product-specific compliance documents. Fibre content, care labelling, and any testing your market requires.

The invoice description is where most delays start. A classification cannot be checked against a vague description, and a shipment that cannot be classified does not clear.

The set must agree with itself. Most customs holds come from a discrepancy between documents rather than from anything inside one of them.

Who Is Responsible When It Goes Wrong?

You are, and this surprises brands more than it should. The importer of record is legally responsible for the accuracy of the entry: the classification, the declared value and the duty paid. Appointing a broker does not move that responsibility, because the broker files on your instructions rather than assuming the liability themselves. CBP is explicit that using a customs broker does not move the liability: the importer of record remains ultimately responsible for the entry documentation and for all duties, taxes and fees (CBP).

That responsibility does not transfer because the supplier arranged the shipping, or because a forwarder filed the paperwork, or because someone else chose the HTS code. If the classification is wrong, the liability is yours.

Two practical consequences. Use a licensed customs broker and give them a real product description rather than asking them to guess. And keep your records, because entries can be reviewed after the fact and the documentation is what you will be asked for.

Do You Need a Customs Broker?

For anything beyond a courier sample, yes, and not because the paperwork is mysterious. A licensed broker files entries daily, knows how apparel classification actually works, and carries professional responsibility for the advice they give. What they do not carry is the liability for the entry itself, which stays with you as importer of record whatever the arrangement.

Apparel is genuinely difficult to classify. The code turns on fibre content, on knit versus woven construction, sometimes on gender and garment type, and on details such as whether the garment has a pocket or a particular closure. A plausible-sounding code taken from a search result is not a correct one, and the error tends to surface on review rather than at the border.

What a broker needs from you is a real description. Give them "ladies knitted top, 95% cotton 5% elastane, short sleeve, single jersey" rather than "t-shirts", and the classification becomes straightforward.

What it costs against what it prevents

Brokerage is a modest fee per entry. A misclassification found later means back duty and interest on every entry filed under the wrong code, and the exposure grows the longer the error runs. The arithmetic is not close.

What Goes Wrong Most Often?

Five failures, all preventable before the goods ship, and all of them cheaper to fix at origin than at destination. Each originates in something agreed vaguely or assumed rather than in anything going wrong during transit, which is why they respond to documentation rather than to a better freight partner.

Assuming de minimis still applies. The most expensive assumption in importing right now, and it appears in guides written before May 2025 that are still online.

Under-declaring value. Suppliers sometimes offer it as a favour. It is customs fraud, the liability is the importer's, and the saving is trivial against the consequence.

Classifying by guess. Apparel classification turns on fibre content, construction, gender and sometimes knit versus woven. A plausible-sounding code is not a correct one.

Budgeting freight without the fixed costs. The quoted rate is rarely the bill. Port fees, brokerage, handling and destination charges are separate lines.

Ignoring the calendar. Chinese New Year closes factories for roughly two to four weeks with reduced output either side, and the two Canton Fair windows take sales teams out of the office (China Import and Export Fair).

Conclusion

Importing from China got more administrative in 2025 and 2026, and most of the change is in the part that used to be invisible. Small shipments no longer slip through, every parcel clears on its merits, and duty applies from the first dollar.

The practical response is not complicated. Get the classification right, get every quote on FOB so you can compare factories rather than forwarders, and price freight including the fixed costs rather than the headline rate.

And keep in mind who carries the liability. The supplier arranges, the forwarder files, the broker advises. The importer of record is responsible, and on your goods that is you.

One final point about the sources. Tariff positions in 2026 are moving, the Supreme Court held in February 2026 that IEEPA does not authorise the tariffs imposed under it in 2025 (Supreme Court of the United States), and two separate Section 301 actions are routinely reported as one. Verify against the primary schedules rather than trusting any summary, including this one.

Frequently Asked Questions

Editorial note: all company names, certification marks and trademarks referenced here are the property of their respective owners. MOQ, cost and lead-time figures are market ranges compiled from the published sources listed below, not quotes from any individual factory, and they vary by product, fabric and season. Tariff figures were correct at the date of publication and the 2026 position is still moving. Always verify your own HTS classification and confirm terms directly with the factory before committing.

Sources

• US Customs and Border Protection: Tips for new importers and exporters, including importer-of-record responsibility.
• US Customs and Border Protection: fact sheet on suspension of duty-free de minimis treatment.
• US Customs and Border Protection: duties collected and shipment volumes since the de minimis phase-out.
• Federal Register (2026): indefinite suspension of the de minimis exemption for non-postal modes.
• Federal Register (2026): indefinite suspension of the de minimis exemption for mail shipments and new postal entry process.
• Supreme Court of the United States (2026): Learning Resources, Inc. v. Trump, on tariffs under IEEPA.
• Federal Register (2025): additional duties on low-value imports from China.
• Federal Register (2026): Section 301 forced-labour actions, 12.5% rate effective 24 July 2026.
• Federal Register (2026): second four-year review of the China technology-transfer Section 301 action.
• Office of the United States Trade Representative: Section 301 tariff actions and exclusion process.
• US Customs and Border Protection: trade remedies and duty administration.
• China Import and Export Fair (Canton Fair): fair dates and phase structure.
• Sheng Lu, FASH455, University of Delaware (2025): WTO-based trade analysis.

Related Reading

• Clothing Suppliers in China: How to Find and Vet a Factory
• China Sourcing Agent vs Working Direct With the Factory