Last updated: May 15, 2025
Key Takeaways
- The 'One Person, One Day' statutory limit (19 CFR § 10.151) applies to the aggregate value of shipments received by one ultimate consignee on a single day.
- Consignee normalization (deduping) is required to identify 'structuring,' where identical buyers use slight data variations to evade duties.
- Automated logic must cross-reference Name, Address, Phone, and Email to create a 'Canonical Identity' before calculating daily totals.
1. Overview
The Section 321 De Minimis exemption allows for the duty-free entry of shipments valued at $800 or less. However, this privilege is strictly bounded by the "One Person, One Day" statute defined in 19 CFR § 10.151. With the explosion of high-volume e-commerce, the risk of "structuring"—artificially splitting shipments or using data inconsistencies to bypass this limit—has become a primary enforcement target for US Customs and Border Protection (CBP).
This protocol establishes a standardized audit methodology for logistics providers and self-filing importers. It defines the "Reasonable Care" standards required to normalize (clean) consignee data, identify duplicate entities across a daily manifest, and aggregate values to prevent illegal Type 86 or Section 321 releases.
2. Key Concepts
Effective auditing requires a precise understanding of the legal definitions governing de minimis entries.
Regulatory Definitions
- One Person, One Day (19 CFR § 10.151): The aggregate fair retail value in the country of shipment of articles imported by one person on one day must not exceed $800. If the aggregate exceeds this amount, none of the shipments qualify for Section 321.
- Structuring: The intentional act of splitting a single order or shipment into multiple smaller shipments, or manipulating consignee data (e.g., spelling variations), to keep individual house bills under $800 and evade duty.
Data Integrity Concepts
- Ultimate Consignee: The true party of interest. In e-commerce, this is the individual buyer, not the freight forwarder or fulfillment center.
- Canonical Identity: The normalized, standardized version of a consignee's data (e.g., converting "123 Main Street, Apt 1" and "123 Main St #1" to a single unique ID) used for aggregation calculations.
3. Core Principles: The Deduping Logic Matrix
To detect structuring, the audit logic must move beyond exact string matching. The following matrix defines the confidence levels for identifying unique individuals.
| Match Criteria | Risk/Confidence Level | Audit Action |
|---|---|---|
| Exact Match (Name + Address + Phone) | High (100%) | Auto-Aggregate. If sum > $800, flag for Type 01 Entry. |
| Address Normalization Match (e.g., "St." vs "Street") | High (95%) | Auto-Aggregate. Requires address standardization logic prior to matching. |
| Fuzzy Name + Exact Address ("J. Doe" vs "John Doe") | Medium-High (80%) | Flag as potential duplicate. Aggregate values. If > $800, hold for manual review. |
| Same Phone/Email + Different Name | Medium (60%) | High risk of "family structuring" or corporate account abuse. Flag for review. |
4. Common Issues & Solutions
Data inconsistency is the primary hurdle in automated compliance.
| Issue | Cause | Solution |
|---|---|---|
| Address Syntax Noise | Raw data often varies (e.g., "Suite 400", "Ste 400"). | Implement a Normalization Pre-Processor that maps suffixes to standard abbreviations (e.g., AVE, ST, RD) before hashing. |
| Freight Forwarder Masking | Multiple distinct buyers use the same freight forwarder address. | Allowed, IF the ultimate consignee name is unique. If the address matches a known forwarder, the Name field becomes the primary unique key. |
5. Quick Reference: Thresholds
Keep these hard limits in mind during the pre-filing review.
- $800 USD — The daily aggregate limit per ultimate consignee.
- 23:59:59 — The "One Day" is defined by the date of arrival at the first port of entry.
6. Interactive Tool
Use the Daily Manifest Aggregation Auditor below to simulate how different data inputs are normalized and aggregated. Input sample manifest lines to see if the system detects the "Structuring" attempt.
Structuring Detection Tool
Daily Manifest Aggregation Auditor
Input multiple shipment lines to test how normalization logic detects aggregate value violations and structuring attempts.
Applies 19 CFR § 10.151 "One Person, One Day" deduping logic
Audit Results
Submit manifest lines to run the "One Person, One Day" aggregation audit.
Heuristic preview only; not a substitute for CBP rulings or legal review.
7. Implementation Guide: The Daily Audit SOP
This Standard Operating Procedure outlines the daily workflow for compliance officers or automated agents.
Step 1: Data Ingestion & Sanitization
- Mandatory Fields: Reject any manifest line missing Name, Address Line 1, City, State, Zip, or Value.
- Sanitization: Remove all non-alphanumeric characters (commas, periods) from the address string. Convert all text to UPPERCASE.
Step 2: Identity Hashing & Aggregation
- Generate Hash: Create a unique ID for each line item using the logic:
HASH(Normalized_Address + Normalized_Name). - Sum Values: Group all shipments by this Hash and sum the declared values.
Step 3: Exception Handling
- Green Lane (Sum <= $800): Release for Type 86 transmission.
- Red Lane (Sum > $800): Hold the shipment. File as Type 01 Formal Entry (paying duties on the total) or Type 11 Informal Entry if eligible.
Frequently Asked Questions
What is the definition of 'One Person' under Section 321?
Per CBP regulations, 'one person' applies to the Ultimate Consignee and includes individuals, partnerships, corporations, and associations. It is the party legally responsible for the duties if the de minimis threshold is exceeded.
Does a slight address change (e.g., 'St.' vs 'Street') reset the $800 limit?
No. CBP expects carriers and brokers to exercise 'reasonable care.' Failing to aggregate shipments due to minor data syntax differences is considered a compliance failure and potential negligence.