Type 86 Entry in 2026: Requirements After the De Minimis Reset
Type 86 is the streamlined low-value entry process in ACE. After the May 2025 Section 321 China suspension and 2026 framework changes, here is what Type 86 currently allows, the value threshold, the filer rules, and the duty math.
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Open calculatorType 86 Entry in 2026: Requirements After the De Minimis Reset
Type 86 is the ACE entry type that mid-sized importers and express consignment operators use for low-value shipments. The pilot ran from 2019 through early 2025 as the streamlined channel for Section 321 de minimis. After the May 2 2025 executive order ended Section 321 eligibility for Chinese and Hong Kong origin goods, Type 86 evolved into the default low-value formal channel: same speed, no duty exemption.
This guide covers the current scope, the filing flow in ACE, the documentation requirements, the duty math, and the cases where Type 86 still saves time and money versus a full formal entry.
What Type 86 actually is
Type 86 sits in the ACE entry type list as a "Section 321 low value shipment" channel. The 2019 pilot framework allowed:
- Goods valued at or below the de minimis threshold (800 USD per recipient per day).
- Streamlined manifest data: HTS code, country of origin, shipper, consignee, value.
- No bond, no entry summary CBP 7501, no broker required.
- Automated duty assessment if applicable (most de minimis entries paid no duty).
- Available 24/7 in ACE with near-instant clearance.
The 2025 to 2026 changes did not abolish Type 86. They removed the duty exemption for Chinese-origin shipments and tightened the manifest data requirements. The Type 86 channel itself remains the most efficient low-value path for any origin.
Current scope (as of June 2026)
| Origin | Type 86 eligible? | Duty owed? |
|---|---|---|
| Non-China non-HK at or below 800 USD | Yes | None (Section 321 still applies) |
| Non-China non-HK 800 to 2500 USD | Yes | Standard MFN plus Section 122 |
| China or HK at any value | Yes (no de minimis) | Full stack: MFN, Section 301, Section 122, Section 232 derivative |
| Above 2500 USD | No, formal entry required | Full stack |
| Above 250 USD textile, footwear, leather (restricted) | Formal entry usually required | Full stack |
The 2500 USD threshold is the formal entry trigger for most goods. Specific product categories with lower thresholds include:
- Textiles and apparel above 250 USD typically require formal entry due to visa and quota requirements.
- Restricted PGA goods (food, drug, regulated chemicals) often default to formal entry regardless of value.
- Restricted commodities under EAR or ITAR controls require formal entry.
Filing flow in ACE
The Type 86 filing happens in ACE Cargo Release. The flow:
- The manifest is filed with CBP before arrival (24 hours for ocean, 4 hours for air per ACE rules).
- The filer submits the Type 86 entry referencing the manifest. Required fields:
- HTS code at 10-digit specificity per line.
- Country of origin per line.
- Value in USD per line.
- Importer of record number.
- Consignee name and address.
- ACE returns a status code: released, held for examination, or held for further documentation.
- Duty is assessed and paid via ACS or PMS at the time of release.
- The shipment is released for delivery once duty is paid and the held status (if any) is cleared.
A clean Type 86 cycle from manifest to release runs 15 minutes to a few hours. A held entry can take days.
Worked example: Chinese consumer electronics under Type 86
A US distributor imports 500 USD of HTS 8517.62 from a Chinese ODM. The shipment was Section 321 de minimis before May 2025; now it is Type 86 with full duty.
| Charge | Rate | Base | Amount (USD) |
|---|---|---|---|
| MFN duty | 0 percent | 500 | 0 |
| Section 301 List 4A | 7.5 percent | 500 | 37.50 |
| Section 122 | 10 percent | 500 | 50 |
| MPF (minimum 2.62, max 614.35) | minimum 2.62 | per entry | 2.62 |
| Total duty | 90.12 |
Effective rate 25.0 percent. on a former duty-free shipment. The distributor either absorbs, passes through, or substitutes the source country.
Worked example: Vietnamese furniture under Type 86
700 USD of Vietnamese-origin HTS 9401.61 furniture (one armchair). Under the 800 USD threshold, Section 321 still applies to non-China origins.
| Charge | Rate | Base | Amount (USD) |
|---|---|---|---|
| All duties (Section 321 de minimis) | 0 | 700 | 0 |
| Total duty | 0 |
Section 321 is intact for Vietnam. The same furniture from China would now pay 19 percent or more.
Worked example: Bulk Vietnamese furniture above the threshold
10,000 USD of the same Vietnamese furniture, ten units per shipment, 1,000 USD per unit. Above the 800 USD informal threshold per recipient per day, so Section 321 does not apply. Either formal entry or Type 86 if value per shipment is under 2,500 USD.
Most importers split-ship or file formal entry. The Type 86 advantage at this scale is process speed only.
| Charge | Rate | Base | Amount (USD) |
|---|---|---|---|
| MFN duty | 0 percent | 10,000 | 0 |
| Section 122 | 10 percent | 10,000 | 1,000 |
| MPF | 0.3464 percent | 10,000 | 34.64 |
| Total duty | 1,034.64 |
Documentation pitfalls
The most common Type 86 rejections in 2026:
- HTS code provided at 6-digit or 8-digit specificity. ACE requires 10-digit.
- Country of origin missing or set to country of export when transformation happened elsewhere.
- Value declared in shipper currency without USD conversion.
- Multi-line entry filed with aggregated value instead of per-line values.
- PGA flag missing for FDA, USDA, or CPSC product.
CBP holds the entry until corrected. Held entries pay storage and delay charges at the port and the carrier. A clean filing is materially cheaper than a fast resubmit.
When Type 86 still saves money
- High-volume low-value e-commerce out of non-China origins where the 800 USD Section 321 cap is the binding constraint. Type 86 vs formal entry for the band 800 to 2500 USD saves 20 to 60 USD per shipment in broker fees and bond amortization.
- Test shipments and product samples. The 10-day round-trip on Type 86 vs the 30-day on a full formal entry is the time savings.
- Multi-country production: a 1,500 USD shipment from a Mexican supplier with a single line. Type 86 is straightforward and skips the broker.
When Type 86 does NOT save money:
- Multi-line shipments with 5+ HTS lines.
- PGA-regulated product needing FDA Prior Notice or USDA APHIS clearance.
- Anything above the 2,500 USD formal entry trigger.
- Shipments where the importer is on a CBP examination flag list.
Run your Type 86 entry now
The LandedFees calculator computes the same duty stack that ACE will apply on Type 86 filing. Plug in the HTS, origin, and value, and see the per-shipment duty before filing. Useful for shipment-splitting decisions and for sourcing comparisons.
Section 122 status as of June 20 2026
The May 7 2026 Court of International Trade ruling in Oregon v. United States (consolidated with Burlap and Barrel v. United States) struck down the Section 122 proclamation. The Federal Circuit issued an administrative stay on May 12 2026, so CBP is still collecting the duty pending appeal. Importers paying now should preserve protest rights and refund claims in case the government loses on the merits. The underlying Section 122 authority sunsets July 24 2026 under the statutory 150-day ceiling, regardless of the appeal outcome, unless Congress extends or a fresh proclamation restarts the clock.
Citations
- CBP Type 86 program page: https://www.cbp.gov/trade/programs-administration/entry-summary/type-86-test
- 19 USC 1321 (de minimis statutory basis): https://www.law.cornell.edu/uscode/text/19/1321
- Executive Order Section 321 China suspension May 2 2025: Federal Register
- ACE entry summary user guide: https://www.cbp.gov/sites/default/files/assets/documents/2024-Feb/ACE_Entry_Summary_Business_Process_Document.pdf
Frequently asked questions
What is Type 86?
An informal entry type in the Automated Commercial Environment (ACE) for low-value shipments. Originally launched in 2019 as a pilot for Section 321 de minimis shipments. Now the standard streamlined channel for formal-equivalent low-value entries, including Chinese-origin shipments that no longer qualify for de minimis.
What is the current value threshold?
Up to the formal entry threshold, currently 2,500 USD for most goods, though some categories (textiles, restricted goods) have lower thresholds. Type 86 covers the band between informal de minimis (Section 321 800 USD for non-China origins) and formal entry.
Who can file Type 86?
Any ACE-portal-enabled filer: licensed customs brokers, self-filers with the right ACE permissions, or the express consignment operators. Most small importers file via their broker; large e-com operators self-file through ACE.
Does Type 86 still mean duty-free?
No, not since May 2025. Type 86 is a process channel, not a duty exemption. Duty owed at the entry (Section 122, Section 301, Section 232, MFN, ADCVD as applicable) is paid at filing. The Type 86 advantage is speed and reduced documentation, not duty relief.
What documents are required for Type 86?
HTS code at full 10-digit specificity, country of origin, manifest reference, value in USD, importer of record. No bond required for most entries. Commercial invoice retained by the filer for audit. PGA flags as applicable (FDA, USDA, CPSC, etc).
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