The loophole is closed. The inspectors never showed up.
Summary
Customs has collected over $1 billion in duties on 246 million packages since the de minimis exemption started closing — but the agency's own staffing model says it was already 4,836 officers short of what it needed to handle the volume.
How the loophole got this big
De minimis shipments didn't creep up — they flooded in. 's own trade statistics show the volume nearly doubling in three years: from 410.5 million packages in fiscal 2018 to 771.5 million in fiscal 2021, per CBP's Section 321 de minimis statistics. By fiscal 2024, was processing an average of 3.8 million de minimis shipments a day — every single day — according to the agency's own "On a Typical Day" release. Run that daily rate across the year and it lands north of 1.3 billion packages, almost all of them arriving with no duty owed and, in practice, no one looking inside the box.
View data as table
| FY 2018 | 410,551,603 | CBP, Section 321 statistics |
|---|---|---|
| FY 2019 | 503,120,599 | CBP, Section 321 statistics |
| FY 2020 | 636,744,478 | CBP, Section 321 statistics |
| FY 2021 | 771,494,078 | CBP, Section 321 statistics |
| FY 2024 | ~1,387,000,000 | 3.8M/day annualized, CBP "Typical Day" FY2024 |
The bill comes due
Starting May 2, 2025, low-value shipments from China and Hong Kong lost duty-free treatment; by August 29, 2025, eliminated the exemption worldwide. The payoff was immediate: says it collected over $1 billion in duties on more than 246 million low-cost shipments in the roughly seven and a half months between the start of the phase-out and mid-December 2025 — "a record amount of revenue that had previously gone uncollected," in the agency's own words. Seizures of unsafe and noncompliant low-value goods rose 82% over the same stretch. The June 2026 rule closes what was left of the gap: nearly every remaining non-postal low-value shipment now has to clear formal or informal entry, the same paperwork a container ship files, not the automated pass-through a $30 phone case used to get.
The officers who aren't there
None of that new workload shows up in the agency's staffing math, because the math predates it. 's own Port of Entry Workload Staffing Model — an internal tool, not an outside advocacy estimate — took fiscal 2022 volumes (before the de minimis crackdown even began) and calculated that ports of entry needed 30,273 officers. At the end of fiscal 2022, had 25,437 on board: fully staffed against its old allocation, and 4,836 officers short of what its own model said the job required.
View data as table
| CBPOs on board, end of FY 2022 | 25,437 | 100% of FY2022 allocated staffing |
|---|---|---|
| FY 2023 Workload Staffing Model recommendation | 30,273 | gap: 4,836 officers |
That gap was calculated before every de minimis package became a formal entry instead of a free pass. Nobody has published an updated staffing model that accounts for the new workload — the last public one is still running on 2022 numbers. The revenue line moved first. The people who have to process the paperwork behind it haven't.
The takeaway
- The money is real and it's landing fast. Over $1 billion in duties on 246 million-plus packages in about seven months — revenue that simply didn't exist under the old $800 exemption.
- The workforce math was already broken before this started. 's own FY2023 staffing model, based on pre-crackdown volumes, said the agency was 4,836 officers short. That gap has not been publicly recalculated for a world where every low-value package needs a real entry.
- Enforcement capacity and enforcement policy moved on different clocks. The rule that ends de minimis took effect in June 2026. The staffing plan built to handle its paperwork is still dated 2023.
Figures on shipment volume, duties collected, and staffing come from three separate / releases with three different reference periods (FY2018–21, FY2024, and FY2022–23, respectively); none of them has been updated to reflect the post-suspension workload described in this piece.
Sources
- U.S. Customs and Border Protection, Office of Trade — Section 321 De Minimis Shipments, Fiscal Year 2018 to 2021 Statistics (Pub. No. 2036-1022, Oct. 2022), the source for FY2018–FY2021 shipment-volume totals. cbp.gov
- U.S. Customs and Border Protection — On a Typical Day in Fiscal Year 2024, ..., the official source for the 3.8 million de minimis shipments processed per day. cbp.gov
- U.S. Customs and Border Protection, national media release — collects $1 billion since end of de minimis loophole (Dec. 17, 2025), the source for duties collected, shipment count since May 2025, and the 82% rise in seizures. cbp.gov
- Federal Register — Indefinite Suspension of the De Minimis Exemption for Merchandise Arriving Through All Modes Other Than the International Postal Network, 91 FR 37789 (interim final rule, effective June 24, 2026), the source for the current rule and its effective date. federalregister.gov
- U.S. Department of Homeland Security / — U.S. Customs and Border Protection Port of Entry Workload Staffing Model, Fiscal Year 2023 Report to Congress (Aug. 21, 2023), the source for officer staffing levels and the workload model's recommended staffing. dhs.gov
Comments
Always open. Logged-in readers can annotate paragraphs in place.
For two decades, any package worth $800 or less could cross the U.S. border duty-free and largely unexamined — a rule called "de minimis" that turned a customs post into a conveyor belt. The government spent 2025 and 2026 dismantling it: first for China and Hong Kong, then everywhere, then, as of a June 24, 2026 interim final rule, indefinitely, for every mode of arrival except the international mail. Every one of those packages now needs an actual customs entry. The agency that has to file it was already thousands of officers short before the rule existed.