4.4 Entry Types, Informal Entry, and In-Bond Transit

4.4 Entry Types, Informal Entry, and In-Bond Transit

Quick Answer: The Automated Commercial Environment (ACE) classifies all importations into standardized two-digit Entry Type Codes, distinguishing between formal consumption entries (Type 01 Free/Dutiable, Type 02 Quota, Type 03 AD/CVD), bonded regimes (Type 21 Warehouse, Type 23 Temporary Importation under Bond), and informal entries (Type 11). Under 19 U.S.C. § 1498 and 19 CFR Part 143, Informal Entry is generally authorized for commercial consignments valued at $2,500 or less; however, commercial goods subject to Antidumping/Countervailing Duty (AD/CVD) orders or quantitative quotas strictly require Formal Entry regardless of value. The Section 321 $800 de minimis exemption (19 U.S.C. § 1321(a)(2)(C)) is currently suspended for all countries and is not available as of September 2026. Finally, In-Bond Transportation (19 CFR Part 18) allows un-entered goods to transit under bond via Immediate Transportation (IT - 30 days to arrive) or Transportation and Exportation (T&E - 15 days to export) using electronic CBP Form 7512.

The Taxonomy of ACE Entry Types

Every customs entry summary transmitted to CBP must declare a specific two-digit Entry Type Code in Block 2 of CBP Form 7501. This code governs duty calculation formulas, partner government agency message set requirements, bond sufficiency underwriting, and post-summary liquidation schedules:

The first digit identifies the general category (0 = consumption, 1 = informal, 2 = warehouse) and the second digit identifies the specific processing type within that category. The authoritative list is printed in the Block 2 instructions to CBP Form 7501:

HIGH-FREQUENCY TRAP: Within the warehouse-withdrawal series, the second digit tracks the same revenue characteristic as the consumption series — 1 for plain consumption, 2 for quota/visa, 4 for AD/CVD, 8 for the combination. There is no entry type for "withdrawal for exportation" or "withdrawal for transportation": a withdrawal for export or for in-bond movement to another port is filed on CBP Form 7512 as an in-bond transaction, not as an entry summary type. Distractors that label 32 as "withdrawal for exportation" or 34 as "withdrawal for transportation" are testing exactly this.

Two further Block 2 conventions are worth memorizing because they appear in Practical Exercise sets:

• Surety code (Block 4 current / Block 4 legacy): 999 for U.S. Government importations and entry types not requiring surety; 998 where cash or Government securities are deposited in lieu of surety.
• Bond type: 0 for U.S. Government or entry types not requiring a bond; 8 for a continuous bond; 9 for a single transaction bond.

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Informal Entry: Statutory Framework and Non-Discretionary Exceptions

Under Section 498 of the Tariff Act of 1930 (19 U.S.C. § 1498) and 19 CFR Part 143, Subpart C, CBP authorizes simplified entry procedures for commercial importations of limited financial value. The standard statutory ceiling for Informal Entry is $2,500 or less (19 CFR 143.21).

Operational Advantages of Informal Entry

1. Simplified Documentation: Filers may use an informal electronic ACE entry summary (Type 11) or paper CBP Form 368A (Customs Collection Receipt).
2. Customs Broker Optional: An individual or commercial importer may clear goods directly without retaining a licensed customs broker.
3. Reduced Merchandise Processing Fee (MPF): Informal entries carry fixed, nominal MPF amounts (e.g., $2.53 for automated filings, $7.17 for manual CBP filings, or $10.76 for manual non-CBP filings) rather than the standard 0.3464% ad valorem rate applicable to formal entries under 19 CFR 24.23.

Absolute Bars to Informal Entry (19 CFR 143.22)

A classic CBLE exam trap tests the strict legal limitations on informal entry. Under 19 CFR 143.22, informal entry is strictly prohibited, and a Formal Entry (Type 01, 02, or 03) is mandatory, for the following categories regardless of how low the shipment value is:

• Antidumping and Countervailing Duty Merchandise: Any commercial shipment subject to an AD or CVD order must be filed under Formal Entry Type 03, even if valued at only $50 or $100.
• Quota Merchandise: Commercial goods subject to absolute quotas or tariff-rate quotas must be entered formally under Entry Type 02 to track quota fill rates.
• Merchandise Exceeding $2,500: Shipments valued at $2,501 or more must enter under formal entry.
• Trade Remedies and Special Sanctions: Goods subject to trade restrictions requiring specialized partner government agency certifications or import licensing.

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Section 321 De Minimis: Suspended for All Countries

Section 321 of the Tariff Act of 1930, as amended (19 U.S.C. § 1321(a)(2)(C)), authorizes the Secretary to admit, free of duty and tax and without formal entry, merchandise imported by one person on one day having an aggregate fair retail value in the country of shipment not exceeding $800. The implementing regulations are 19 CFR 10.151 through 10.153. For a decade this was the busiest administrative exemption in U.S. customs practice, carrying billions of e-commerce parcels annually.

CURRENT STATUS — READ THIS BEFORE ANSWERING ANY DE MINIMIS QUESTION: The duty-free de minimis exemption is suspended. Executive Order 14324 suspended duty-free de minimis treatment for all countries effective August 29, 2025, building on the earlier suspension for China and Hong Kong, and Executive Order 14388 continued the suspension in February 2026 including for shipments moving through the international postal network. CBP then published two concurrent interim final rules making the suspension indefinite by regulation — effective June 24, 2026 for merchandise arriving through all modes other than the international postal network, and July 24, 2026 for mail, together with a new postal informal entry process. As of September 2026 the $800 administrative exemption is therefore not available, and commercial shipments valued at $800 or less owe applicable duties, taxes, and fees and require an entry.

Why the Statutory Rules Still Matter for the Exam

The CBLE is an open-book examination keyed to a designated edition of 19 CFR, and 19 U.S.C. § 1321 and 19 CFR 10.151–10.153 remain on the books. Candidates therefore need to know both layers:

1. The statutory architecture, because questions are frequently written from the regulatory text; and
2. The current suspension, because a question asking what duty is owed on a $500 parcel today has a different answer than the same question asked in 2024.

The Statutory Architecture (19 CFR 10.151–10.153)

• One person, one day: the $800 ceiling applies to the aggregate fair retail value of all shipments imported by one person on one day. Three parcels of $300 each arriving for the same consignee on the same day aggregate to $900 and, even before the suspension, disqualified the entire day's importation.
• Anti-structuring (19 CFR 10.153): a single commercial order may not be split into multiple parcels to stay under the ceiling. CBP aggregates shipments consolidated for, or addressed to, a single ultimate recipient.
• Categorical exclusions: the exemption never reached alcoholic beverages, perfume containing alcohol, cigars and cigarettes, goods subject to AD/CVD orders, quota merchandise, or merchandise requiring a partner government agency admissibility determination that the administrative exemption cannot satisfy.

Practical Consequence for Low-Value Shipments Today

With de minimis unavailable, low-value commercial shipments move through the ordinary entry framework: informal entry (Entry Type 11) for shipments at or below the $2,500 informal ceiling where no categorical bar applies, or formal entry where 19 CFR 143.22 requires it. Informal entries carry the fixed informal-entry merchandise processing fee rather than the ad valorem rate, and mail shipments move under the postal informal entry process established by the June 2026 interim final rules.

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In-Bond Transportation System (19 CFR Part 18)

The U.S. in-bond transit system, governed by 19 CFR Part 18, permits imported merchandise to be moved under customs custody from one U.S. port to another port, or transited across the United States for foreign exportation, without the immediate appraisement of goods or payment of customs duties. In-bond movements are electronically declared using CBP Form 7512 (Transportation Entry and Manifest of Goods Subject to CBP Inspection and Permit) or the ACE Electronic In-Bond message set.

The Three Core In-Bond Movement Types

                                  ┌────────────────────────────────┐
                                  │     In-Bond Movement Modes     │
                                  └───────────────┬────────────────┘
                                                  │
         ┌────────────────────────────────────────┼────────────────────────────────────────┐
         ▼                                        ▼                                        ▼
┌─────────────────────────┐              ┌─────────────────────────┐              ┌─────────────────────────┐
│ Immediate Transportation│              │   Transportation and    │              │  Immediate Exportation  │
│     Without Appraisement│              │       Exportation       │              │          (IE)           │
│        (IT - Code 61)   │              │      (T&E - Code 62)    │              │      (IE - Code 63)     │
├─────────────────────────┤              ├─────────────────────────┤              ├─────────────────────────┤
│ • Origin Port to Inland │              │ • Port of Arrival to    │              │ • Exported directly     │
│   Destination Port      │              │   Foreign Export Port   │              │   from Arrival Port     │
│ • Enters U.S. commerce  │              │ • Transits across U.S.  │              │ • No inland transit     │
│   at destination port   │              │ • Does NOT enter U.S.   │              │ • Unclaimed, rejected,  │
│ • Delivered within      │              │   commerce              │              │   or transshipment cargo│
│   30 CALENDAR DAYS      │              │ • Exported within       │              │ • Exported within       │
│   (19 CFR 18.1)         │              │   15 CALENDAR DAYS      │              │   15 CALENDAR DAYS      │
└─────────────────────────┘              └─────────────────────────┘              └─────────────────────────┘

1. Immediate Transportation Without Appraisement (IT — Code 61): Merchandise arrives at a U.S. port of arrival (e.g., Port of Long Beach), is laden onto a bonded carrier, and moves under bond to an interior port of destination (e.g., Chicago). Formal entry (Form 3461/7501) is filed and duties are paid at the Chicago port of destination.
2. Transportation and Exportation (T&E — Code 62): Merchandise arrives at a U.S. port (e.g., Seattle), transits through U.S. territory under bond, and exits through another port (e.g., Blaine, WA or Miami, FL) for immediate export to a foreign country (e.g., Canada or South America). The goods never enter U.S. domestic consumption.
3. Immediate Exportation (IE — Code 63): Merchandise arrives at a U.S. port and is exported directly from the same port without transiting inland (e.g., refused entry, canceled orders, or foreign cargo transshipped to connecting vessels).

Critical Operational Timeframes (19 CFR 18.1)

• IT Movement Deadline: Under 19 CFR 18.1, merchandise moving under an IT must be delivered to the port of destination within thirty (30) calendar days from the date the in-bond movement is authorized by CBP.
• T&E and IE Export Deadline: Under 19 CFR 18.1 and 18.24, merchandise transiting under a T&E or IE must be exported within fifteen (15) calendar days from the date of arrival at the port of exportation, with total transit not to exceed 30 calendar days.
• In-Bond Arrival Notification: The bonded carrier must report arrival of the in-bond merchandise at the destination port via ACE within two (2) business days of physical arrival.

Bonded Carrier Liability, Sealing, and Diversion (19 CFR 18.4, 18.5)

• Customs Bond: In-bond movements must be backed by an active Activity Code 2 (Custodian of Bonded Merchandise) or Activity Code 3 (International Carrier) customs bond. If goods are stolen, lost, or unaccounted for during transit, the bonded carrier is liable for full customs duties and liquidated damages.
• High-Security Seals (19 CFR 18.4): All conveyances containing in-bond cargo must be secured with high-security seals meeting ISO 17712 commercial standards. Seals may only be broken by CBP officers or authorized bonded warehouse personnel.
• Diversions (19 CFR 18.5): If an in-bond shipment is to be diverted to a port other than the destination port named on the original CBP Form 7512, the bonded carrier or filer must submit an electronic diversion request through ACE prior to the diversion of the cargo.