Customs Bond for Every Entry: What CBP's New Rule Changes
Key takeaways
As of October 2026, not every US entry needs a customs bond. CBP has proposed, not finalized, a bond on every informal entry of $2,500 or less (Entry Types 11 and 13). Comments close December 7, 2026. Formal entries already need a bond.
Does every import now need a bond, what would it cost on a small parcel, and how do you comment?
Brands shipping small orders into the US often ask us:
"We ship small orders straight to US customers. Do we need a bond on each one now?"
"Section 301 raised our duty. Does our bond go up too?"
"We have no US entity. Can our Korean company still clear small shipments in its own name?"
The short answer: no, not every entry needs a customs bond today. On October 8, 2026, CBP published a proposed rule that would require a bond on every informal entry of $2,500 or less. It is a proposal. Comments close December 7, 2026, and there is no final rule yet.
The basics of continuous and single transaction bonds are in our importer of record guide. This post covers what the proposal would change, what a bond costs on a small entry, how Section 301 moves bond size, and what the order on foreign importers does and does not do yet.
1. Who needs a customs bond today?
Formal entries, generally shipments valued above $2,500, need a customs bond. For informal entries, CBP's own proposed rule says "bonding is only required in certain situations." Entry Type 11 (ET11) is the general informal entry for goods valued at $2,500 or less.
Two points from the same document:
- Postal entries: CBP writes that "a bond is already required under the current informal postal entry process." Our de minimis post covers how that process works for parcels from Korea.
- Bondless ET11 entries: from August 1, 2025 to July 31, 2026, about 2.3 million ET11 entries went in without a bond. CBP puts that at 3.31% of its projected ET11 entries for 2026, filed by 68,701 importers (CBP proposed rule).
So most small entries already carry a bond. The proposal is aimed at the 3.31% that do not, and the 68,701 importers who file them.
2. What CBP's proposed rule would change
The proposal, titled "Low-Value Shipments" (FR Doc 2026-20650), would make these changes if CBP finalizes it:
- Bond on every small entry: all ET11 and Entry Type 13 (ET13) filers would need a basic importation and entry bond, either a single transaction bond (STB) or a continuous bond. ET13 is a new electronic informal entry for international mail.
- Earlier filing: the ET11 entry would be due on or before the date of importation. Today it is due within 15 days of arrival.
- Broker as importer: a consignee that is not the owner or buyer, such as a postal operator, freight forwarder or carrier, would have to appoint a licensed customs broker to act as importer of record (IOR).
- Higher penalty floor: liquidated damages (a fixed amount owed when a bond condition is broken) on ET11 and ET13 would be the value of the goods or $1,000, whichever is greater. For restricted goods, the base is three times the value, with the same $1,000 floor.
CBP's cost section also says CBP "could raise the floor to $1,000" for single transaction bonds. That figure is not in the proposed rule text. Treat it as an idea under discussion.
CBP's cost analysis works on the assumption that the rule takes effect "starting in 2027." CBP has set no date. Until CBP publishes a final rule, none of these changes apply.
3. Single transaction bond or continuous customs bond: what each costs on small entries
If the rule is finalized, an ET11 filer with no bond would have to choose one. CBP's proposed rule includes cost estimates built from six broker websites. These are CBP estimates, not surety quotes.
| Single transaction bond (STB) | Continuous bond | |
|---|---|---|
| Covers | One entry | All entries for up to one year, renewed each year |
| Bond amount | Generally no less than entered value plus all duties, taxes and fees (CBP bond guide) | $50,000, or 10% of estimated duties, taxes and fees over the previous 12 months, whichever is greater (CBP bond guide) |
| CBP's premium estimate | $4.917 per $1,000, minimum $54.167 (CBP) | $441.52 a year for a $50,000 bond (CBP) |
| CBP's average premium per ET11 entry | $55.57 (CBP) | $1.95 (CBP) |
| Raising the amount | Only in the 10-day window between entry and entry summary (CBP bond guide) | 15 days to fix it after CBP's written notice of insufficiency (19 CFR 113.13) |
Across all bondless ET11 entries, CBP estimates an average premium of $3.99 per entry.
For example, take a $200 parcel of Korean goods with a 0% MFN duty rate. With Section 301 (section 4 below), it pays 12.5%, or $25 in duty. A single transaction bond would have to cover at least $225 plus fees. At CBP's estimated minimum premium of $54.167, the bond costs more than twice the duty.
On the same CBP estimates, $441.52 for a continuous bond equals about eight single transaction bonds at the minimum premium. For example, a seller filing ten or more small entries a year would pay less in premium with a continuous bond. Your surety's terms will differ. On a small parcel, the bond premium can cost more than the duty.
4. How Section 301 changes the size of a continuous bond
Section 301 raises a continuous bond only when the higher duty lifts 10% of your estimated duties, taxes and fees for the previous 12 months above the $50,000 minimum. Above $50,000, amounts go up in $10,000 steps to $100,000, then in $100,000 steps (CBP bond guide).
The Korea rate works differently from most countries. Under the July 23, 2026 presidential memorandum, a Korean product with an MFN duty below 12.5% gets a Section 301 rate that brings the combined total to 12.5%. If the MFN rate is 12.5% or more, Section 301 is 0%. The rate applies to goods entered on or after 12:01 a.m. Eastern on July 24, 2026 (USTR notice). Our HTS code post shows how to find your MFN rate.
Two limits:
- Section 232 goods: Korea's Ministry of Trade says autos, steel, semiconductors and other Section 232 items, and certain raw materials, are not charged this duty (MOTIE release). See our Section 232 post.
- Open probe: the same release says a separate Section 301 investigation into overcapacity is still in progress. It may change the rate.
For example, a brand enters $8,000,000 of goods a year on formal entries, with a 4% MFN rate. Counting duty alone, its duty was $320,000. Ten percent is $32,000, so the bond stays at the $50,000 floor. At the 12.5% combined rate, the duty is $1,000,000, and the bond becomes $100,000.
Small parcels are different. Under CBP's bond guide (February 2024), ET11 entries are not included in the continuous bond computation. Duty on direct parcels does not grow your continuous bond today. The final rule could change that. Formal-entry duty drives the continuous bond; ET11 duty does not, for now.
5. Foreign importers of record: what EO 14411 orders, and what is in force
Executive Order 14411, signed June 3, 2026, directs limits on foreign IORs. Its definition of a foreign IOR covers a company that is not organized in the US, not located in the US, not controlled by US citizens or permanent residents, or without significant US real property.
What the order directs:
- Informal entry: CBP is to "promptly" bar foreign IORs from filing informal entries. No date is set.
- Formal entry: a foreign IOR "may not rely on a continuous bond" except as CBP permits. It must be validated in CTPAT (CBP's supply chain security program) or use a CTPAT-validated broker.
- 180 days: steps on IOR asset and bond rules, good standing, an IOR registry and vetting are due within 180 days, which by our count is November 30, 2026.
As of October 25, 2026, we found no rule that puts the foreign IOR limits into effect. CBP's Strengthening Customs Enforcement page, updated October 15, lists none. The October 8 proposal does not single out foreign IORs either.
Two things have moved. Since September 18, 2026, CBP can void an IOR number at once for inaccurate Form 5106 data (CBP notice). CBP has also told CTPAT-validated brokers they will need to vet foreign clients before doing customs business for them (CTPAT alert).
A US subsidiary of a Korean parent can still fall inside the definition. The foreign IOR limits are ordered, not in force, so ask a licensed broker how they would apply to your setup.
6. How to comment on CBP's proposed rule
Comments on the proposal must be received on or before December 7, 2026 (Federal Register).
- Go to regulations.gov and search for docket USCBP-2026-0298.
- Say which entry types you file, how many small entries you make a year, and what a bond on each would cost you.
- Submit before the deadline and keep the confirmation.
CBP says comments "may be posted without change," including any personal information you provide. Leave out anything you would not want published.
Four checks before your next shipment
1. Which of your entries are ET11 informal entries, and do they carry a bond today?
2. If every ET11 entry needed a bond, would a continuous bond cost less than a single transaction bond on each?
3. Has Section 301 lifted 10% of your estimated duties, taxes and fees above $50,000?
4. Does your company, or your US subsidiary, meet the foreign IOR definition in EO 14411?
Wrap-up
Formal entries need a bond today, and most small entries already have one. CBP's proposal would close the gap for the rest, move the ET11 deadline earlier and raise the penalty floor. The foreign IOR limits are still directives. This post summarizes the rules and is not legal advice. Check your own entries with a licensed customs broker.
From its warehouse in Fullerton, California, LinkONE supports Korea-US ocean and air freight, along with US customs clearance and import compliance consulting.
In the end, the bond rule is still a proposal, which makes now the time to count your small entries and decide which bond fits them.
Frequently Asked Questions
Can you import into the US without a customs bond?
Yes, for some informal entries today. Formal entries need a bond, and CBP says bonding on informal entries is "only required in certain situations" (CBP proposed rule). From August 2025 to July 2026, about 2.3 million ET11 entries, 3.31% of CBP's 2026 projection, went in without a bond, filed by 68,701 importers (CBP proposed rule).
Is CBP's new customs bond rule in effect?
No. CBP published it as a proposed rule on October 8, 2026, and comments close December 7, 2026 (docket USCBP-2026-0298, Federal Register). CBP's cost analysis assumes the rule would take effect in 2027, but no final rule has been published.
How much is a continuous customs bond?
The minimum is $50,000, or 10% of estimated duties, taxes and fees over the previous 12 months, whichever is greater (CBP bond guide). CBP estimates the premium on a $50,000 continuous bond at $441.52 a year, based on broker websites (CBP proposed rule). Your surety's price may differ.
Does the Section 301 tariff raise my customs bond?
It can. A continuous bond rises when 10% of your estimated duties, taxes and fees passes $50,000 (CBP bond guide), and Section 301 brings Korean goods with an MFN rate below 12.5% to a 12.5% combined rate (presidential memorandum). ET11 entries are left out of the continuous bond computation under the same February 2024 guide. A single transaction bond covers entered value plus duties, so it rises entry by entry.
Can a Korean company be its own importer of record for small shipments?
As of October 25, 2026, no rule bars it. Executive Order 14411 directs CBP to bar foreign IORs from informal entry and to limit their use of continuous bonds, but we found no rule that puts this into effect. Check with a licensed customs broker before your first shipment.
Sources
- Federal Register, "Low-Value Shipments," proposed rule, FR Doc 2026-20650 (October 8, 2026)
- CBP, A Guide for the Public: How CBP Sets Bond Amounts (February 2024)
- The White House, Executive Order 14411, Strengthening Customs Enforcement (June 3, 2026)
- The White House, Presidential Memorandum on Section 301 actions (July 23, 2026)
Fees and rules in this post are as of October 2026.
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