Caspian Weekly Digest - October 13, 2026

Weekly Digest

CBP Proposes New Low-Value Import Rules

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The Bottom Line

The low-value shipment rule from CBP was published October 8. It's for anything $2,500 or less, which is mostly coming in as informal entries since de minimis was suspended. Every informal entry would need a bond and brokers would be the importer of record when the consignee isn't the owner. Comments are due December 7.

Russia tariffs under the Graham law are due October 18, and we still don't know who or how much. On IEEPA, the trade court certified a class last week. If you paid those duties and never sued, you're in, and that could be your way to get refunds on the old liquidated stuff.

De Minimis

CBP Proposes Changes to Low-Value Entries

CBP's proposed rule is for shipments worth $2,500 or less, which used to come in under the $800 de minimis exemption and are going through informal entry since the suspension. Comments are due December 7.

De minimis has been suspended since last year and ends for good on July 1, 2027. CBP says the informal entry process wasn't built for this many packages. CBP projects about 103 million low-value shipments a year.

What the Rule Says

Every informal entry needs a bond, single transaction or continuous, and the minimum for a breach is $1,000.

Filing would be due by arrival instead of within 15 days after.

Brokers would have to be the importer of record on their own bond any time the consignee isn't the owner, like USPS or a forwarder.

Unfiled mail is considered abandoned after 15 days and USPS gets to decide whether to destroy it or return it.

CBP can also make a whole importer or product category or manufacturer file formal.

The one good part is that the $250 cap on Chapter 99 goods goes away so Section 232 items up to $2,500 can go informal again.

What We Expect

We think brokers turn away whole categories like supplements and cosmetics and food gifts. Sureties are in the same spot and will probably charge more for bonds on tiny entries or ask for collateral or just not write them. That's fine for Amazon and Temu since they can cover this with their own bonds, but an Etsy seller can't. Consumers end up paying more in clearance fees and bond surcharges and storage fees and at checkout, and some will lose the package if it's abandoned. There will be scam texts asking people to pay their customs bond too.

What It Opens Up

That opens the door for new tools. Someone's going to build TurboTax for customs, an app that files your Type 13 with the bond built in. More goods will probably come in through bonded warehouses and FTZs and ship from there. Reach out to Caspian to talk about how to automate classification, entry and audit on your low-value shipments.

Source: Federal Register

IEEPA Refunds

Trade Court Certifies IEEPA Refund Class Action

On October 8 the CIT certified a class in Freestyle World v. CBP. Paid IEEPA, didn't sue? You're in.

CBP only reliquidates finally liquidated entries for people with their own case, so an order for the class would let everyone else claim those refunds.

Conference with the judge is October 13. The schedule, including the government's answer date, is due October 22.

Section 122 already lost at the CIT and is on appeal, and the forced labor 301 case got argued there September 30. If either one goes the importers' way, same question comes up: what about everybody who didn't sue? This case is probably how the court answers it.

Why It Matters

If you paid IEEPA on entries that are already finally liquidated and you never sued, this case is probably your only way to get that money back.

Source: Court of International Trade

Chromium trioxide. Commerce's final determination is that chromium trioxide from India and Turkey is being sold below fair value. India's is also subsidized. If the ITC finds injury there will be antidumping and countervailing orders and you'll post cash deposits. It's mostly used in chrome plating and metal finishing. (Federal Register: India, Turkey)

Diesel fuel. The President signed an order on October 5 that defers the federal diesel excise tax through December 31. It also waives the penalty for using dyed diesel on the highway. It's mostly for truckers and farmers but if you ship by truck your fuel costs should go down once Treasury puts out the details. (Federal Register)

What We're Watching

Russia tariffs. The Graham law gives the President until October 18 to put tariffs of up to 500% on Russian goods and up to 100% on countries that buy Russian oil and gas. China, India and Turkey are the biggest buyers. The President picks the countries and the rates and can waive them. Then on October 9 he announced a deal for Russia to ship diesel to the U.S. It's pretty hard to slap a 100% tariff on India for buying Russian fuel the same month we started lining up Russian diesel for ourselves, so we think the tariffs on buyers just got less likely.

Dates That Matter

Oct 13: Court conference in the IEEPA class action
Oct 18: Deadline for the President to act on tariffs under the Graham law targeting Russia and buyers of Russian energy
Oct 22: Proposed schedule due in the IEEPA class action, including when the government answers
Dec 7: Comments due on CBP's proposed low-value shipment rule
Dec 31: Current end date for the diesel excise tax deferral

What To Do Now

Review Your Low-Value and Mail Shipments
Pull your shipments of $2,500 or less, mail first, and see how they're filed now. If electronic filing or a bond would add work or cost for your team you have until December 7 to tell CBP.

Pull Your Finally Liquidated IEEPA Entries
Nobody wants to be digging through ACE the week the judge rules, so get your list of finally liquidated IEEPA entries and amounts together now.

Check Your Exposure to Russia Tariffs
If you source from China, India or Turkey pull the products and entries the Graham law tariffs would cover. The rate could be up to 100% on top of what you pay now.

Reach Out to Caspian to Understand Your Impact