Cross-border after de minimis
For years, a whole category of ecommerce business model quietly depended on one customs threshold: shipments under $800 entering the United States duty-free. That exemption was suspended in August 2025 and the suspension was codified in February 2026, alongside a 10% surcharge. If your model assumed duty-free entry, the model changed. Here is what the arithmetic looks like now and what brands are actually doing about it.
What changed, precisely
The de minimis exemption allowed packages valued under $800 to enter the United States without duty. It was suspended on August 29, 2025. In February 2026, the permanent suspension of duty-free de minimis treatment was codified and integrated with a 10% Section 122 surcharge.
The arithmetic is not subtle. A brand shipping 50 orders a day at a $50 average order value now faces a surcharge adding roughly $5.00 in duties per order. That is $250 a day, about $91,000 a year, on a business doing roughly $912,000 in annual revenue at that volume. For a brand running 15% net margin, a $5 per order cost increase consumes a large share of the margin on every order.
There is no clever workaround for a structural change of this kind. There are, however, genuinely different fulfillment architectures, and the difference between them is now worth real money.
The structural point: de minimis made it economically rational to hold inventory outside the United States and ship individual parcels in. Removing it inverts that logic. When every parcel carries duty, consolidating the customs event into one bulk import and fulfilling domestically becomes the cheaper architecture for most brands.
The three architectures, compared
| Model | How customs works | Delivery speed | Returns |
|---|---|---|---|
| Parcel-by-parcel from abroad | A customs event per order, duty per shipment | Slow, variable | Hardest |
| Consolidated import, then domestic fulfillment | One customs event per bulk shipment | Domestic transit | Easiest |
| Hybrid: forward-stock the movers | Bulk import for top SKUs, direct ship the long tail | Mixed | Mixed |
Industry commentary through 2026 has converged on the middle and bottom rows. Brands that stay competitive are rethinking fulfillment architecture to balance cost, speed, and regulatory complexity, and in-country enablement or forward stocking is the most cited approach.
The part that gets underestimated: returns
Reverse logistics complexity roughly doubles for cross-border returns. When a US customer returns a product to a foreign warehouse, the return faces customs and duties processes in reverse. Many brands respond by simply writing off low-value returns, which is a rational decision that also means eating the full cost of the goods.
Given that returns average roughly 20% of ecommerce orders, an architecture that makes returns unworkable is an architecture with a 20% problem. A domestic returns address changes that from a customs exercise into an ordinary returns processing question, which is a solved problem with known costs.
What forward stocking actually requires
“Hold inventory in the US” is easy to say and is a real operational commitment. Four things it demands:
A demand forecast you trust. Forward stocking means committing inventory to a location before you have the orders. Get it wrong on the high side and you are paying storage on product in the wrong country; wrong on the low side and you stock out with your inventory an ocean away. Sales velocity, seasonality, and subscription renewals feed the restock alerts we build for exactly this, so peak season is a plan instead of a surprise.
Clean product data, including customs fields. Country of origin and HS code per SKU are no longer optional metadata. Neither are weights and dimensions, without which nothing can be rated. We reject incomplete SKU masters during onboarding for this reason, which is occasionally annoying and always cheaper than the alternative.
Inventory visibility across locations. Two pools of stock in two countries is genuinely harder than one, and it fails specifically when your systems disagree about what is where. Inventory services exist to keep one authoritative count.
A domestic parcel strategy. Once your inventory is stateside, your cost problem becomes an ordinary domestic parcel problem: zones, dimensional weight, accessorials, carrier mix. That is the well-understood part, and where the carrier landscape shift starts to matter to you.
How we would approach the decision
Strategic planning is part of the partnership rather than a separate engagement, and this is a good example of what that means in practice. The question is not “should you forward stock” in the abstract. It is: at your order volume, average order value, return rate, and SKU count, does consolidating the customs event pay for the inventory commitment it requires?
That is arithmetic, and it needs your actual numbers rather than a general principle. We sit down with your numbers and look at whether this partnership is actually moving them: volume, cost per order, delivery performance, the things you would measure us on anyway. For a brand weighing a cross-border restructure, the honest output is sometimes that your current volume does not justify the change yet, and that is a useful answer to get early.
What we would not do is tell you the regulatory environment is settled. It is not, and copy that pretends otherwise ages badly. What is durable is the shape of the response: fewer customs events, cleaner product data, inventory closer to the customer, and returns that do not require a customs broker.
The bottom line
De minimis was a subsidy for a specific fulfillment architecture, and it is gone. A 10% surcharge on a $50 order is $5, and $5 an order is a business model question rather than a shipping question.
The brands adapting well are consolidating the customs event, forward stocking the SKUs that earn it, and fixing their product data as a precondition rather than a project. The brands struggling are the ones still hoping the rules revert.
Related reading
What a return actually costs you
Roughly 20% of orders come back at $25 to $30 each. Why a domestic returns address changes the math.
Read →What a 3PL transition actually looks like
If restructuring means moving providers, this is the plan and the five dependencies that set its pace.
Read →Run the cross-border math with us
Book a discovery call and bring your order volume, average order value, return rate, and SKU count. In thirty minutes we will work through whether consolidating your customs event and stocking domestically pays for itself at your scale. If it does not yet, we will say so.
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