Every cross-border parcel now carries duty.
Every return now carries a refund.
The US, EU, and UK have all moved against the duty-free threshold. 5.8 billion low-value parcels entered the EU in 2025. Every duty paid inbound is potentially recoverable on return. MyCustomsInfo® audits both directions — inbound exposure and returns recovery — across all three jurisdictions from a single engagement.
Three regimes. Three timelines. One direction.
The US closed the door first. The EU follows in July 2026. The UK has confirmed abolition by March 2029. Every low-value parcel that previously entered duty-free now carries a customs liability — and every duty paid inbound becomes a potential refund when the goods cross back.
United States — CLOSED
$800 de minimis abolished 29 August 2025 (Executive Order 14324). Entry Summary (CBP Form 7501) required for all shipments. IEEPA surcharges layer on top of MFN rates (rates subject to change; verify current rates at cbp.gov). Recovery via drawback (19 USC §1313) and Post-Summary Correction (19 CFR Part 190).
European Union — CLOSING
€150 exemption ends 1 July 2026. Interim flat duty €3 per tariff sub-heading. Full IOSS reform follows. 5.8 billion low-value parcels in 2025 (91% from China). Fiscal representative required in most Member States. Recovery via Returned Goods Relief (UCC Art. 203) within 3 years.
United Kingdom — CONFIRMED
£135 threshold to be removed (Autumn Budget 2024). Implementation by March 2029. CDS single window for declarations. Recovery via RGR (Customs Notice 236) within 3 years and UK Customs Duty Drawback (Customs Notice 998). 10-digit commodity code required at item level.
Three audit layers — inbound, reverse, and cross-jurisdiction
De minimis abolition creates obligations in both directions. MyCustomsInfo® audits inbound duty exposure, returns recovery opportunities, and cross-jurisdiction compliance in a single engagement.
Inbound Duty Exposure Audit
We identify every parcel and shipment that previously entered duty-free and now carries a customs liability. Classification accuracy at item level, duty calculation per tariff sub-heading, and DDP pricing impact.
Returns Recovery Audit
We identify every duty paid inbound that is potentially recoverable when goods are returned. Returned Goods Relief (UK/EU), drawback (UK/US), and Post-Summary Correction (US) — matched to original import entries.
Cross-Jurisdiction Compliance
We map compliance obligations across all three jurisdictions: filing requirements, registration deadlines, fiscal representative appointments, and tariff overlay interactions (IEEPA, Section 232).
Six-source methodology across all three jurisdictions
Every audit draws on six independent data sources to build a complete picture of duty exposure and recovery opportunity across US, EU, and UK trade flows.
Customs authority declarations
CDS (UK), ACE (US), ATLAS/national systems (EU) — the primary record of every import entry.
Carrier and logistics manifests
Shipping records, airway bills, and parcel tracking data to verify volumes, weights, and routing.
Commercial invoices and POs
Purchase order and invoice records to verify declared values and match inbound to return shipments.
Tariff schedule databases
HTS (US), UK Trade Tariff, and EU Combined Nomenclature — to verify classification accuracy at 10-digit level.
Client ERP / WMS exports
Transaction-level data from enterprise and warehouse systems to match returns to original import entries.
Regulatory source documents
Executive orders, EU regulations, UK Finance Acts, and implementing guidance — to track threshold changes and recovery windows.
De minimis audit data inventory
To audit both inbound duty exposure and returns recovery opportunity, we need the following from your team. Most clients provide these within five business days.
| Document | Purpose | Typical source |
|---|---|---|
| 12 months of import declarations | Identify all shipments that entered duty-free under de minimis and calculate the new duty exposure | Customs broker or freight forwarder |
| Returns and re-export records | Match returned goods to original import entries for RGR, drawback, and PSC claims | Warehouse / 3PL / returns team |
| Item-level product catalogue | Verify 10-digit commodity code classification accuracy before and after threshold changes | Merchandising or product team |
| Commercial invoices by shipment | Verify declared values and identify potential underdeclaration or DDP pricing gaps | Finance or procurement team |
| Country-of-origin records | Determine which tariff overlays apply (IEEPA, Section 232) on top of standard duty | Supply chain or sourcing team |
| Carrier manifest data | Cross-reference volumes and routing against customs declarations | Logistics or freight provider |
The recovery loop: inbound duty ↔ return refund
Every duty paid on inbound goods is potentially recoverable when those goods are returned. The audit must cover both directions to capture the full financial picture.
| Recovery route | Jurisdiction | Legal basis | Window | Status |
|---|---|---|---|---|
| Returned Goods Relief | UK | Customs Notice 236 | 3 years from export | Active now |
| Returned Goods Relief | EU | UCC Art. 203 | 3 years from export | From 01/07/2026 |
| Customs Duty Drawback | UK | Customs Notice 998 | Per scheme rules | Active now |
| Drawback | US | 19 USC §1313 | 5 years from import | Active since 29/08/2025 |
| Post-Summary Correction | US | 19 CFR Part 190 | 300 days from entry summary | Rolling |
The window matters. RGR claims in the UK and EU must be filed within three years of the original export. US drawback allows five years. In both cases, the audit must match the return to the original entry. The longer you wait, the harder the match becomes — and the greater the risk of expired claims.
The new compliance load
Abolishing de minimis does not just mean duty. It means a new layer of compliance obligations that most e-commerce supply chains were never built to handle.
Fiscal representation
Non-EU businesses must appoint a fiscal representative in most EU Member States to handle customs and VAT obligations.
Item-level data
Every parcel requires a full customs declaration with item-level detail: description, value, origin, weight, and commodity code.
HTS / CN classification
Each item must be classified to a 10-digit commodity code. Misclassification creates both duty exposure and recovery risk.
Quarterly duty returns
Some recovery routes (notably UK drawback) require periodic duty returns. Missing a quarter means missing recoverable duty.
DDP pricing adjustment
Delivered Duty Paid pricing models must now absorb or pass through new duty costs. Failure to adjust creates margin erosion.
RGR workflow
Claiming Returned Goods Relief requires matching the return shipment to the original import entry. Without clean data, the claim fails.
Who this audit is for
If your business moves goods across borders and has been relying on de minimis exemptions, the landscape has changed. Here is how it affects you.
Marketplaces
Deemed importer obligations under the EU reform mean marketplaces are now directly liable for customs duty on goods sold through their platforms.
E-commerce retailers
DDP pricing models built on duty-free thresholds are no longer viable. Every shipment now carries a duty cost that must be absorbed, passed through, or recovered on return.
3PLs and fulfilment providers
Logistics providers handling returns are now sitting on recoverable duty. The data required to file RGR or drawback claims lives in your systems.
Customs agents and brokers
The volume of declarations is about to increase dramatically. Agents need classification accuracy, entry matching, and recovery workflow support at scale.
What MyCustomsInfo® does — and does not do
What we do
- Audit inbound duty exposure across US, EU, and UK trade flows
- Identify returns recovery opportunities via RGR, drawback, and PSC
- Verify item-level classification accuracy at 10-digit commodity code
- Match return shipments to original import entries
- Model financial impact of threshold abolition on DDP pricing
- Track compliance deadlines across all three jurisdictions
What we do not do
- We do not file customs entries, drawback claims, or RGR applications
- We do not broker or clear goods through customs
- We do not act as a fiscal representative in any jurisdiction
- We do not prepare or submit Entry Summaries (CBP Form 7501)
- We do not provide legal, tax, or VAT advice
We identify. Your broker acts. This boundary is non-negotiable under 19 USC §1641 and ensures our audit outputs remain independent across all jurisdictions.
What you receive
Inbound duty exposure report
Complete mapping of all shipments now carrying duty post-de minimis, with duty calculation per tariff sub-heading and jurisdiction.
Returns recovery register
Every recoverable duty matched to its recovery route (RGR, drawback, PSC) with filing window and documentation requirements.
Classification accuracy audit
Item-level review of commodity code accuracy across all three jurisdictions with reclassification recommendations.
DDP pricing impact model
Financial modelling of how threshold abolition affects Delivered Duty Paid pricing across your product range.
Compliance calendar
All filing deadlines, registration dates, recovery windows, and claim expiry dates mapped across US, EU, and UK.
Tariff overlay analysis
Identification of IEEPA and Section 232 interactions on goods that previously entered duty-free.
De minimis audit pricing framework
Scoped to your parcel volumes, number of jurisdictions, product catalogue size, returns rate, and complexity of tariff overlays. Cross-jurisdiction audits covering US, EU, and UK are priced as a single engagement.
The EU deadline is 01 July 2026. The audit should start now.
Whether you are already paying duty on US shipments, preparing for the EU threshold change, or planning for the UK abolition — the sooner the audit starts, the more you recover.
Prefer to see a sample audit first? Request a sample under NDA
De minimis compliance questions
Related compliance services
IEEPA surcharges now apply on top of standard duty for goods that previously entered duty-free.
Section 232 ComplianceSection 232 tariffs compound with de minimis abolition for metal-containing goods.
UK/EU Customs AuditOrigin, valuation, and classification audit for UK and EU trade flows.
US Customs AuditFull US audit scope covering ACE entries, tariff overlays, and recovery routes.
CBAM ComplianceEU and UK Carbon Border Adjustment Mechanism compliance from a single platform.
US Regulatory Notice. CustomsPlus® Limited, which operates MyCustomsInfo®, is not a licensed customs broker under 19 USC §1641. We do not file, prepare, or submit customs entries, drawback claims, or post-summary corrections to US Customs and Border Protection. All US filing is performed by the importer’s licensed customs broker.
Data sources. Executive Order 14324 (US); European Commission customs reform proposals (EU); UK Autumn Budget 2024; European Commission DG TAXUD Impact Assessment 2025; UK Trade Tariff; Union Customs Code (Regulation (EU) No 952/2013); 19 USC §1313; 19 CFR Part 190.
Disclaimer. This page is provided for informational purposes only and does not constitute legal, tax, or customs advice.