T86 Customs Clearance Explained

T86 customs clearance is the filing process for CBP Entry Type 86, which allows low-value shipments worth $800 or less to enter the United States under the Section 321 de minimis exemption with advance electronic data. For e-commerce importers, direct-to-consumer brands, and express carriers handling millions of small parcels, understanding T86 is now essential to keeping goods moving through U.S. ports without delays or compliance failures.

The rise of cross-border e-commerce — driven by platforms like Temu, Shein, and Amazon — has pushed Section 321 shipments past 1 billion parcels per year entering the U.S., according to CBP data. Entry Type 86 was created specifically to bring transparency and security screening to this massive and growing flow of goods.

What Is T86 Customs Clearance?

Entry Type 86: A CBP entry type designed for shipments valued at $800 or less that qualify for the Section 321 de minimis exemption under 19 USC § 1321. It requires electronic submission of advance shipment data — including product description, HTS code, value, country of origin, and consignee — through the Automated Commercial Environment (ACE), giving CBP the information it needs to screen parcels for admissibility, intellectual property violations, and trade law compliance.

Before Entry Type 86 existed, most de minimis shipments entered the country with minimal data. Express carriers submitted manifests with basic information, and CBP had limited visibility into what was actually arriving. As e-commerce import volume exploded — Section 321 shipments grew from roughly 140 million in fiscal year 2016 to over 1 billion in fiscal year 2023 — Congress and CBP recognized the security and revenue risks of clearing goods with so little information.

Entry Type 86 addresses this gap. It does not impose duties or taxes on qualifying shipments. Instead, it creates a structured data submission process that sits between the old informal “manifest clearance” approach and a full formal entry (like Entry Type 11). Think of it as a lightweight customs entry that preserves the duty-free benefit of Section 321 while giving CBP the data it needs.

The legal foundation for T86 clearance rests on two pillars:

• 19 USC § 1321 — establishes the de minimis exemption, authorizing CBP to admit articles free of duty and tax when their aggregate fair retail value does not exceed $800 per person per day.
• 19 CFR § 128.24 — governs the clearance of express shipments and outlines the data requirements for de minimis entries processed through ACE.

If you import low-value goods and want to understand how this fits into the broader customs landscape, browse brokers by specialty to find customs brokers experienced in e-commerce and Section 321 compliance.

How T86 Filing Works: Step by Step

Filing a T86 entry is faster and simpler than a formal consumption entry, but it still follows a defined process. Here is how it works from pre-shipment to release:

Step 1: Determine Eligibility

Before filing, confirm the shipment qualifies for de minimis treatment. The goods must be valued at $800 or less (fair retail value in the country of shipment), must not be subject to antidumping or countervailing duties (AD/CVD), and must not require a license or permit from a partner government agency (PGA) that prohibits Section 321 treatment.

Step 2: Gather Required Data Elements

CBP requires the following data for an Entry Type 86 filing:

• Shipper name and address (foreign supplier)
• Consignee name and address (U.S. recipient)
• Country of origin
• HTS classification (at the 6-digit minimum, though 10-digit is best practice)
• Description of merchandise
• Declared value
• Carrier and tracking information
• Importer of record identifier

Step 3: File the Entry in ACE

The customs broker or filer submits the Entry Type 86 electronically through CBP’s ACE system. Most high-volume filers use automated integration through ABI (Automated Broker Interface) software. The entry should be submitted before the shipment arrives at the U.S. port of entry.

Step 4: CBP Screening and Targeting

CBP’s targeting systems screen the submitted data against risk profiles, intellectual property databases, trade enforcement priorities, and PGA requirements. Most T86 entries clear within minutes. Some are flagged for document review or physical inspection.

Step 5: Release or Hold

If the entry clears targeting, CBP issues a release. The shipment moves to the consignee. If CBP issues a hold, the filer must respond with additional documentation — potentially including a commercial invoice, product photos, or proof of admissibility — before the goods can be released.

Step 6: Record Retention

Under 19 CFR § 163.4, importers and brokers must retain all entry records for five years from the date of entry. This includes the T86 filing, commercial invoices, and any correspondence with CBP.

T86 vs. T11 vs. Section 321 Manifest Clearance

Importers often confuse T86 with other entry types and clearance methods. Here is how they compare:

The key distinction: T86 gives CBP the data it wants while preserving the duty-free treatment importers want. Manifest clearance is simpler but increasingly scrutinized. Formal entries (T11) are required for anything over $800 or goods subject to quotas, AD/CVD orders, or certain PGA regulations.

For shipments that exceed the $800 threshold or involve regulated commodities, you will need a licensed customs broker to file a formal entry. Search all CBP-licensed customs brokers to find one near your port of entry.

Regulatory and Legislative Landscape

T86 customs clearance exists in a regulatory environment that is changing fast. Several developments are reshaping how de minimis shipments are handled:

The $800 De Minimis Threshold. The current $800 threshold was set by the Trade Facilitation and Trade Enforcement Act of 2015, which raised it from $200. This single change dramatically expanded the volume of shipments eligible for duty-free entry. In fiscal year 2023, CBP processed over 1 billion Section 321 shipments — roughly 4 million per day.

Proposed Legislative Changes. Multiple bills have been introduced in Congress to restrict or eliminate the de minimis exemption for shipments from certain countries (particularly China). The Import Security and Fairness Act and the De Minimis Reciprocity Act both propose lowering or removing the $800 threshold for goods from non-market economies. As of this writing, no bill has passed, but importers should track these developments closely.

CBP’s Advance Data Pilot. CBP launched the Entry Type 86 test in 2019 and has expanded it as part of its broader e-commerce strategy. The agency’s Trade Strategy 2025+ explicitly calls for enhanced data collection on de minimis shipments to combat intellectual property theft, fentanyl trafficking, and forced labor violations.

Executive Orders on Trade. Recent executive actions targeting imports from China have increased scrutiny on Section 321 shipments. In September 2024, the White House announced new restrictions on textile and apparel shipments claiming de minimis treatment, signaling that T86 data requirements may expand further.

Forced Labor Enforcement. The Uyghur Forced Labor Prevention Act (UFLPA) applies to all imports, including de minimis shipments. CBP has stated that goods subject to UFLPA rebuttable presumptions do not qualify for Section 321 treatment, even if valued under $800. Importers filing T86 entries for goods with any nexus to the Xinjiang region face elevated risk.

For importers navigating these shifting regulations, working with a customs broker who specializes in compliance is not optional — it is risk management. Browse brokers by U.S. port of entry to find specialists near where your goods arrive.

Real-World Scenarios: When T86 Matters

Scenario 1: DTC E-Commerce Brand Shipping from China

A U.S.-based e-commerce brand sells consumer electronics accessories priced at $15–$40. Products ship directly from a Chinese fulfillment center to individual U.S. consumers. Each parcel is valued well under $800. The brand’s logistics partner files T86 entries for every shipment, providing HTS codes, values, and consignee data. This ensures smooth clearance at the express hub in Louisville, KY (SDF), where CBP processes millions of e-commerce parcels annually.

Without T86 filing, these shipments would rely on manifest clearance — a method CBP is actively discouraging for high-volume shippers. The brand avoids delays by using the structured T86 process.

Scenario 2: Amazon FBA Seller Consolidating Inventory

An Amazon seller imports 500 units of a product in a single ocean shipment destined for an Amazon fulfillment center. The total value is $12,000. This shipment does not qualify for T86 — it exceeds $800 and is a consolidated commercial shipment, not individual parcels to individual consumers. The seller needs a formal Entry Type 11 with a customs bond, HTS classification, and full entry summary.

This is a common misunderstanding: T86 applies to individual parcels valued under $800, not to bulk shipments split into per-unit values. The $800 threshold applies to the aggregate shipment value per consignee per day.

Scenario 3: Pharmaceutical Samples Shipped via Express Carrier

A pharmaceutical company receives 20 sample vials from a European supplier, valued at $300 total. Despite the low value, pharmaceutical products regulated by the FDA require prior notice and may need an FDA entry filing. These goods are generally ineligible for Section 321 de minimis treatment because of PGA requirements. The company must file a formal entry with FDA data, even though the shipment is under $800.

Understanding which goods are excluded from T86 eligibility is critical. Learn more about agencies involved in customs clearance to understand how partner government agencies affect your entry type options.

Common Mistakes and Misconceptions

Mistake 1: Splitting shipments to stay under $800. Deliberately breaking a large shipment into multiple parcels to claim de minimis treatment is called “splitting” and it violates CBP regulations. CBP aggregates shipments from the same shipper to the same consignee on the same day. Penalties for evasion under 19 USC § 1592 can reach up to four times the value of the merchandise.

Mistake 2: Assuming all goods under $800 qualify. Goods subject to AD/CVD orders, quota restrictions, or PGA holds (FDA, USDA, EPA, CPSC, TTB) may be excluded from de minimis treatment regardless of value. Always check the Harmonized Tariff Schedule and the AD/CVD orders database before filing.

Mistake 3: Filing without an HTS code. Some filers submit T86 entries with vague product descriptions and no HTS classification. CBP’s targeting systems rely on HTS data to screen for restricted goods. Missing or incorrect HTS codes increase the chance of a hold and can delay clearance by days.

Mistake 4: Ignoring record retention. T86 entries may feel informal, but they carry the same record-keeping obligations as formal entries. Under 19 CFR § 163.4, you must retain all supporting documents — invoices, packing lists, filing records — for five years. CBP can audit de minimis entries.

Mistake 5: Confusing “duty-free” with “regulation-free.” De minimis treatment waives duties and taxes. It does not waive product safety standards, intellectual property laws, labeling requirements, or trade sanctions. Goods cleared via T86 are still subject to seizure if they violate U.S. law.

Tools and Resources for T86 Compliance

Working with the right tools — and the right broker — reduces errors and speeds up clearance. Here are the essential resources:

• CBP ACE Portal — The system where T86 entries are filed. Filers need an ACE account and ABI connection. Access ACE at cbp.gov.
• HTS Search (hts.usitc.gov) — Use this to find the correct tariff classification for your goods. Accurate HTS codes are required even for T86 filings. Search the HTS.
• CBP Binding Rulings — If you are unsure about classification or admissibility, search CBP’s CROSS database for prior rulings on similar goods. Browse rulings.
• AD/CVD Orders Database — Check whether your product is subject to antidumping or countervailing duties, which would disqualify it from de minimis treatment. Check AD/CVD orders.
• NCBFAA — The National Customs Brokers & Forwarders Association of America provides guidance, training, and advocacy updates on de minimis and e-commerce entry processes. Visit ncbfaa.org.
• CustomsBrokerIndex.com — Find a licensed customs broker with experience in e-commerce and Section 321 entries. Search by state or by specialty.

For importers using 3PL providers with customs clearance and warehousing, confirm that your 3PL’s customs broker is filing T86 entries correctly. The importer of record is ultimately responsible for compliance, not the logistics provider.

Frequently Asked Questions

What is T86 customs clearance?

T86 customs clearance is a CBP entry type that allows importers to file advance electronic data for low-value shipments valued at $800 or less that qualify for Section 321 de minimis exemption. It provides a formal tracking mechanism for duty-free e-commerce parcels entering the United States, giving CBP the data it needs to screen shipments while preserving duty-free treatment. The filing is submitted through ACE and typically processes within minutes.

How does the T86 filing process work?

A licensed customs broker or the importer’s agent files an Entry Type 86 in CBP’s ACE system before the shipment arrives. The filing includes the shipper’s name and address, consignee details, HTS classification, declared value, and country of origin. CBP screens the data electronically through automated targeting systems and either releases the shipment or flags it for additional review or inspection.

Who needs to file a T86 entry?

Any importer, e-commerce marketplace, fulfillment center, or express carrier that clears de minimis shipments valued at $800 or less through a formal CBP entry process should use T86. It is especially critical for high-volume e-commerce importers shipping directly to U.S. consumers from overseas warehouses. CBP is increasingly requiring advance data on de minimis shipments that previously cleared with minimal manifest information.

How much does a T86 filing cost?

T86 filing fees typically range from $2 to $10 per entry when handled by a customs broker, depending on volume commitments and the broker’s pricing structure. High-volume shippers filing thousands of entries per day can negotiate rates at the lower end. Unlike formal entries, T86 shipments are exempt from the Merchandise Processing Fee (MPF) and Harbor Maintenance Fee (HMF), which saves an additional 0.3464% of value and 0.125% of value respectively.

What is the most common mistake importers make with T86 entries?

The most common mistake is assuming every shipment under $800 automatically qualifies for T86 clearance. Certain goods — including those subject to antidumping or countervailing duties, FDA-regulated products requiring prior notice, items covered by the Uyghur Forced Labor Prevention Act, and products on restricted lists — are ineligible for de minimis treatment regardless of value. Filing a T86 for ineligible goods can result in holds, seizures, penalties under 19 USC § 1592, and loss of trade privileges.