What triggers an Entry Type 86 suspension?

Common triggers include 'structuring' (splitting shipments to evade the $800 limit), using vague descriptions (e.g., 'Parts'), and failing to file correct PGA data.

How do I become a Qualified Party for postal shipments?

You must submit CBP Form 5106 to bondquestions@cbp.dhs.gov, secure a Basic Importation Bond (Type 1), and receive approval via CSMS.

CBP Entry Type 86 Suspension Triggers & Reinstatement SOP

1. Overview

The regulatory landscape for low-value imports into the United States has undergone a catastrophic shift following the issuance of Executive Order 14324. This order suspended the universal duty-free de minimis treatment under Section 321, effectively dismantling the "Entry Type 86" expedited clearance model for non-postal shipments. Importers and brokers must now navigate a bifurcated system: formal/informal entry with full duties for express carriers, and a temporary "specific duty" regime ($80-$200 per item) for international mail handled by "Qualified Parties."

In response to intensified CBP enforcement—marked by the suspension of major brokers for compliance failures—this protocol introduces the "Section 321 Structuring Risk Validator." This algorithmic defense strategy is designed to proactively detect "structuring" (splitting shipments to evade limits) and "vague descriptions" before data reaches CBP's Automated Commercial Environment (ACE), thereby protecting the filer's license and operational status.

2. Key Concepts

Understanding the new enforcement paradigm requires mastering the specific regulatory mechanisms triggered by the Executive Order and CBP's technical blocks.

Regulatory Framework

Executive Order 14324: Suspends Section 321(a)(2)(C) duty-free treatment for all countries. Establishes a temporary specific duty ($80-$200) for postal items based on the origin country's IEEPA tariff rate.
Entry Type 86 Blockade: CBP has hard-coded ACE to reject all Type 86 transactions. Non-postal shipments must now use Entry Type 01 (Formal) or Type 11 (Informal), triggering Merchandise Processing Fees (MPF).

Enforcement Mechanisms

Structuring (1P1D): The statutory "One Person, One Day" limit ($800). CBP uses network analysis to detect entities splitting shipments across multiple manifests to evade this cap.
Qualified Party (QP): A new legal designation allowing private entities (brokers/forwarders) to assume liability for collecting and remitting duties on international mail, effectively privatizing USPS customs functions.

Compliance Risks

Vague Descriptions: A "Zero Tolerance" policy effective Nov 12, 2025. Generic terms like "Parts" or "Daily Necessities" trigger immediate rejection and potential suspension.
Remedial Action Plan (RAP): The mandatory, detailed operational audit document required by CBP to reinstate a suspended broker's filing privileges.

3. Core Principles

The "Section 321 Structuring Risk Validator" operates on two primary logic gates designed to mirror CBP's own targeting systems.

Principle	Description	Application
Fuzzy Matching / Entity Resolution	Utilizing algorithms (e.g., Levenshtein distance) to detect identical consignees despite slight address variations (e.g., "123 Main St" vs. "123 Main Street, Apt 1").	Aggregates value across all "fuzzy" matches for a single day. If the total exceeds $800, the shipment cluster is blocked internally to prevent a "Structuring" violation in ACE.
Description Hygiene Filtering	A hard-block dictionary based on CSMS #62263081 that identifies prohibited generic terms (e.g., "Accessories", "Gifts", "Consolidated").	Prevents the transmission of "bad data" that triggers CBP's automated "Hard Reject" protocols, preserving the broker's compliance scorecard.

4. Common Issues & Solutions

Failure to adapt to the EO 14324 environment typically manifests in two ways: immediate cargo stagnation or broker license suspension.

Issue	Cause	Solution
Structuring Suspension	Broker transmits multiple shipments for the same ultimate consignee on one day that cumulatively exceed $800, detected by CBP's targeters.	Deploy the "Validator" to pre-screen manifests at T-24 hours. Aggregate values based on normalized address tokens (stripping noise characters) before filing.
PGA "Type Mismatch" Rejections	Attempting to file FDA or EPA regulated goods (e.g., toothbrushes, electronics) under a now-restricted or inappropriate entry type.	Implement HTS-based logic stops. Flag Chapter 90 (Medical) or Chapter 85 (Electronics) items for manual review to ensure Entry Type 01/11 compliance.

5. Quick Reference

Critical metrics and codes for the current enforcement regime.

$80 / $160 / $200 — The three tiers of specific duty per item for postal shipments, determined by the origin country's IEEPA status.
CBP Form 5106 — The "Create/Update Importer Identity Form" required to register an entity as a Qualified Party (QP).
CSMS \#62263081 — The definitive CBP source listing unacceptable cargo descriptions that trigger automatic rejection.

6. Interactive Tool

The Section 321 Structuring Risk Validator is a conceptual AI agent designed to integrate with ABI software. It ingests manifest data (CAMIR/IATA XML) and applies the "Fuzzy Matching" and "Description Hygiene" principles outlined above.

Acting as a firewall, it provides a "Stop List" of high-risk shipments to the analyst, preventing them from being transmitted to CBP. This "pre-filing defense" is the only reliable method to avoid the patterns that lead to suspension.

Entry Type 86 Suspension Simulator

Section 321 Structuring Risk Validator

Paste a mini manifest snapshot to identify 1P1D structuring patterns and vague descriptions that could trigger an Entry Type 86 suspension.

Mirrors the Section 321 structuring & description hygiene gates

Mini-Agent Insight

Submit a shipment snapshot to see how the Entry Type 86 suspension logic would treat it.

Demo output only; not a substitute for CBP rulings or legal review.

7. Implementation Guide

Whether preparing for QP status or recovering from a suspension, strict adherence to this SOP is required.

Phase 1: Remedial Action Plan (RAP) Protocol

Root Cause Analysis (RCA): Document the specific gap (e.g., API lacked name normalization) that allowed violations. Do not admit to knowing fraud; focus on system limitations.
Corrective Actions: Immediately offboard non-compliant clients and implement "Hard Blocks" for prohibited descriptions.
Preventive Systems: Document the deployment of the "Validator" and engage external counsel for quarterly audits to demonstrate "Reasonable Care."

Phase 2: Qualified Party Setup

Bonding: Secure an Activity Code 1 (Continuous Bond) with a limit sufficient to cover 10% of the projected annual specific duty liability.
Application: Submit CBP Form 5106 and technical capability confirmation to bondquestions@cbp.dhs.gov and await CSMS confirmation.

8. Additional Resources

Executive Order 14324: "Suspending Duty-Free De Minimis Treatment for All Countries" - The legal basis for the current crisis.
19 U.S.C. § 1321: The statutory basis for Section 321 administrative exemptions and the "One Person, One Day" rule.
CSMS \#62263081: CBP's official guidance on Unacceptable vs. Acceptable Cargo Descriptions.