2026 Import Compliance Checklist, What to Review Before January 1

Introduction

December is when small issues become expensive problems, missed documents, expired bonds, weak vendor paperwork, and system changes that catch teams off guard in January. This checklist focuses on three areas that have real operational impact right now: low value shipments (Section 321), recordkeeping, and forced labor due diligence, plus key ACE items that can affect filing and cash flow.

1) Confirm your plan for low value shipments, Section 321 has changed

If your supply chain uses direct to consumer shipments, samples, or small parcels, you need to re check your process.

CBP issued guidance that, effective 12:01 am on August 29, 2025, goods of all countries are no longer eligible for duty free de minimis treatment under 19 U.S.C. 1321(a)(2)(C). The same guidance states ACE will reject Section 321 manifest filings via EDI, remove the option to file Section 321 manifests in the truck manifest trade portal, and reject entry type 86 cargo release EDI transactions. GovDelivery

Reuters also reported this policy change and described the transition structure and impacts on shippers and consumers. Reuters+1

Action items

• Identify every lane that used Section 321 or type 86, including marketing samples and warranty replacements
• Ensure your teams know when to file a formal entry vs an informal entry, and when duty, taxes, and fees apply GovDelivery
• Review who is paying duties and brokerage fees, you, your customer, or your supplier, then update contracts and landed cost models
• Make sure your commercial invoice data is complete, accurate value, correct country of origin, correct HTS, and reasonable description, because you can no longer assume a duty free path exists

2) Tighten your recordkeeping, because CBP can audit years later

Recordkeeping is not a best practice, it is a regulatory requirement, and it is the backbone of defending classification, valuation, origin, and admissibility decisions.

CBP recordkeeping requirements are in 19 CFR Part 163. eCFR

There is also a voluntary Recordkeeping Compliance Program in 19 CFR 163.12, which explains potential benefits for certified recordkeepers in certain situations. eCFR+1

Action items

• Confirm your retention period and where records live, broker files, ERP, email, shared drives, vendor portals
• Make sure you can produce entry records quickly when demanded, including supporting documents used to make the entry correct, not just the CBP forms
• Standardize naming conventions and folder structures by entry number, PO, SKU, supplier, and year
• Run a spot check, pick 10 entries from mid year and see if you can rebuild the full story in under 30 minutes

3) Strengthen forced labor screening and supplier proof

Forced labor enforcement risk continues to be a major compliance issue, with detentions, exclusions, and supply chain disruptions for importers who cannot prove admissibility.

CBP maintains ongoing information and guidance for forced labor enforcement under UFLPA, including importer expectations about documentation and evidence. Customs and Border Protection

DHS published 2025 updates to the UFLPA strategy, outlining how enforcement priorities evolve. Department of Homeland Security

Action items

• Map your supply chain beyond tier 1 suppliers for high risk products, know the source of raw materials and inputs
• Create a documentation packet template suppliers must complete, then require it for new POs
• Keep evidence tied to specific shipments and lots, generic statements do not hold up well in real detentions
• If you have a detention playbook, test it, who gathers documents, who responds, and how fast

4) Watch ACE changes that can affect workflows and timing

ACE enhancements and schedule shifts matter because they can change how you file, how you see data, and how you manage payments and refunds.

A December 11, 2025 trade report summarized CBP schedule updates for ACE, including items affecting detentions data integration timing, in bond modernization timing, export manifest functionality timing, and a change in timing for an ACE portal permission related to ACH refund information. Sandler, Travis & Rosenberg, P.A.

Action items

• Confirm your ACE portal account access is current and least privilege, remove former employees and vendors
• If you expect refunds, verify you have a process for bank information control and internal approvals Sandler, Travis & Rosenberg, P.A.
• Ask your broker what system changes could impact your filings in the next two quarters, then schedule a short internal review

A simple 2026 readiness checklist you can assign this week

1. List every shipment type you run, formal, informal, mail, courier, ocean, air
2. Flag all flows that depended on Section 321 or type 86, update SOPs GovDelivery
3. Validate HTS classification for your top 50 items by duty spend and by volume
4. Re check valuation rules, assists, tooling, royalties, freight, and discounts
5. Confirm origin logic and supporting documents for items with preference claims
6. Confirm recordkeeping completeness for a sample of entries, fix gaps eCFR
7. Update forced labor due diligence packets and detention response roles Department of Homeland Security+1
8. Review ACE user access and refund controls Sandler, Travis & Rosenberg, P.A.

How S.J. Stile Associates can help

• Entry strategy and cost modeling after de minimis changes
• HTS classification, valuation, origin, and documentation reviews
• Recordkeeping and audit readiness support
• Forced labor due diligence workflows and shipment level evidence organization
• Day to day brokerage and escalation support across NY, Miami, Los Angeles

Contact: www.stileintl.com | 516 394 2100

Frequently Asked Questions

Does this mean every package is now duty free under 800 dollars is gone?

CBP guidance states de minimis duty free treatment under 19 U.S.C. 1321(a)(2)(C) was suspended effective August 29, 2025, and filings tied to Section 321 and entry type 86 were impacted in ACE. GovDelivery

What should I do if my business relied on type 86 or Section 321 processes?

Move immediately to an appropriate formal or informal entry process, and update your invoice data quality, HTS, origin, and payment responsibilities with suppliers and customers. GovDelivery

How long can CBP come back and ask for import records?

Recordkeeping requirements and procedures are in 19 CFR Part 163. Your retention and production obligations should be aligned to that regulation and your specific record types. eCFR

Is there any benefit to joining a CBP recordkeeping program?

19 CFR 163.12 describes a voluntary Recordkeeping Compliance Program and explains potential alternatives in certain penalty situations for certified recordkeepers. eCFR+1

What is one forced labor step I can do quickly before January?

Pick your highest risk product line, map the supply chain beyond tier 1, and require a shipment level evidence packet that ties materials and production to the specific goods imported. Department of Homeland Security+1

References

• CBP CSMS bulletin on suspension of duty free de minimis treatment, August 28, 2025 GovDelivery
• Reuters reporting on ending the de minimis exemption, August 29, 2025 Reuters+1
• 19 CFR Part 163 recordkeeping regulation, eCFR eCFR
• 19 CFR 163.12 Recordkeeping Compliance Program, eCFR and Cornell eCFR+1
• DHS page on 2025 updates to the UFLPA strategy Department of Homeland Security
• CBP UFLPA enforcement FAQ page Customs and Border Protection

Sandler Travis and Rosenberg summary of CBP ACE schedule updates, December 11, 2025 Sandler, Travis & Rosenberg, P.A.

Final Call to Action:

Ready to take control of your shipping costs?

Let’s talk. Contact Stile Associates for a free consultation and let our experts audit your current process, to help you streamline your operations, stay compliant, and save money.

Choose Stile, Your Smartest Move in Global Trade

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Since 1968, we’ve been delivering peace of mind and performance. Let’s take your logistics to the next level together.

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