• Deanna Clark-Esposito

Customs Rules on Imports to Domestic Warehouses and Fulfillment Centers



Administrative Exemptions codified in the U.S. import regulations enables U.S. Customs and Border Protection (CBP) to admit certain merchandise duty- and tax-free if it is imported by "one person on one day" and has a total fair retail value in the country of shipment of $800 or less, herein referenced as Section 321 privileges. In a recent administrative ruling, CBP has recognized fulfillment centers and domestic warehouses as an acceptable definition of "one person" or the purpose of Section 321 privileges.


CBP has stated that it is actively taking steps with trade partners to educate eligible entities as well as identify those who are in violation of Section 321 regulations. CBP warns that it may take enforcement action against repeat and egregious violators through placing holds on ineligible shipments, requiring formal entry or revoking this privilege altogether.


CBP has offered the following guidance for facilitating compliance depending on the status of the entity:


Domestic Warehouse and Fulfillment Center Consignees who receive over $800

of unsold merchandise in one day can coordinate with merchandise owners to help

ensure their shipments comply with Section 321 regulations.


Merchandise Owners may qualify for Section 321 provided the total value of their

shipments do not exceed $800 in one day, and their identity (first and last name or

name of company) is presented to CBP via the manifest or Entry Type 86 filing.


Shippers and Carriers should refer to CBP’s Customs Automated Manifest Interface Requirements (CAMIR) and Customs and Trade Automated Interface Requirements

(CATAIR) updates to ensure the merchandise owner’s identity is presented

appropriately to CBP.

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