by Ariful | Oct 8, 2026 | Australia Updates
TITLE: ATO Credit Card Ban, Client-to-Agent Linking Expansion and the 28 October BAS Deadline
ATO credit card ban creates political uncertainty
The ATO plans to stop accepting direct credit card payments from 1 December 2026. The final day for a direct credit card payment is 30 November 2026.
The decision has triggered public disagreement between Labor frontbenchers.
Housing Minister Clare O’Neil said the government had “some real concerns about what the ATO is proposing to do here” and wanted the ATO to return to discussions with business. Small Business Minister Anne Aly also urged the ATO to continue talking with small businesses.
However, Assistant Minister Andrew Charlton said that “the government supports the ATO’s decision”. He argued that the 98% of taxpayers who do not pay by credit card should not subsidise those who do.
Treasurer Jim Chalmers said the ATO is an independent authority and made the decision itself. He also said the government insisted on a transition period.
The conflicting messages have increased uncertainty for Australian businesses. You can read the latest political response in the ABC News report and the Sydney Morning Herald coverage.
Small businesses are calling for the ban to be reconsidered
The Australian Chamber of Commerce and Industry has called for one clear outcome across government. Chief executive Andrew McKellar said the 5% of small businesses affected represents approximately a quarter of a million businesses.
Independent MPs Kate Chaney and Allegra Spender, along with Independent Senator David Pocock, have also called for the decision to be reconsidered or reversed.
The Housing Industry Association has urged the government and the ATO to reverse the ban. It warned that removing credit card payments could worsen cash-flow pressures for home builders.
The ATO says credit card payments represented 2.3% of all payments collected in 2024–25. More than 60% of credit card payments by value came from privately owned and wealthy groups, public entities and multinationals. Around 5% of small businesses and just over 2% of individual taxpayers used credit cards to pay tax during that period.
These figures explain the ATO’s position. However, usage statistics do not show why a business used a credit card. Some businesses may have used cards for convenience, while others may have been bridging a short-term gap between paying suppliers and receiving customer receipts.
The ATO’s official announcement confirms the planned change.
Cash-flow pressure makes the timing important
The decision comes as some Australian businesses are already experiencing increased financial pressure.
An Australian National Audit Office report found that small businesses owed $35.9 billion in collectable tax debt in 2024–25. This was $19.4 billion higher than in 2018–19.
Financial Counselling Australia reported a 21% increase in cases handled by its small business debt helpline during 2025. Almost two-thirds involved ATO debt.
The Reserve Bank of Australia’s October 2026 Financial Stability Review also identified growing cash-flow pressures, particularly for smaller businesses and businesses operating in construction, hospitality and retail.
This matters for ecommerce brands, digital businesses, agencies and other growing companies because tax liabilities often become payable before customers settle invoices. A quarterly BAS, PAYG withholding amount or income tax instalment can therefore create a timing problem even when the business remains commercially viable.
Build your alternative ATO payment plan now
Do not wait until November to discover that your payment process depends on a credit card.
Use this checklist to prepare:
- List every upcoming ATO liability. Include BAS, GST, PAYG withholding, PAYG instalments, superannuation-related obligations and income tax.
- Match each liability to a permitted payment method. Debit cards, BPAY, bank transfers and direct debit remain available.
- Review your bank payment limits. This will help you avoid a failed transfer when a large liability becomes due.
- Check existing payment plans. Confirm the repayment amount, due dates and available account balance.
- Contact the ATO early if cash flow is tight. Early contact gives you more time to discuss an ATO payment arrangement.
- Update your internal approval process. Make sure someone is responsible for releasing payments before each due date.
- Record all payment confirmations. This protects your business if a payment is delayed or incorrectly allocated.
The ATO’s payment guidance explains the available payment methods.
ATO payment plans can provide breathing space, but general interest charges continue to accrue. Also remember that ATO interest incurred from 1 July 2025 is no longer tax deductible.
Other funding options may include a bank overdraft, business loan or another short-term facility. Some third-party payment platforms may also accept a credit card and pay the ATO on your behalf for a fee. Check the provider’s terms, total cost and payment timing carefully before relying on this option.
Client-to-agent linking will expand to sole traders
The ATO is expanding its client-to-agent linking process to individuals and sole traders.
The current process generally applies to entities with an ABN, excluding sole traders. This includes companies, trusts, partnerships and self-managed superannuation funds.
Under the expanded process, the registered tax or BAS agent will initiate the linking request. The client will then authorise that request through ATO online services or the ATO app.
The agent will not be able to access the relevant information or act on the client’s behalf until the authorisation is completed.
A pilot is expected to begin in March 2027, ahead of full implementation in November 2027. The change is designed to strengthen security and provide greater transparency over who is authorised to access taxpayer information.
The process may apply when you:
- appoint a new registered tax or BAS agent;
- change from one agent to another; or
- give an existing agent authority over an additional obligation.
There is nothing most sole traders need to do immediately. Wait for your registered agent to contact you with instructions. The SB Group’s explanation of the expansion provides further detail.
by Ariful | Oct 8, 2026 | US Updates
## CBP’s Low-Value Shipments Proposal: What International Sellers Need to Know
U.S. Customs and Border Protection (CBP) has proposed significant changes for low-value imports. The proposal affects international sellers shipping goods into the United States, including Amazon, eBay, Etsy and Shopify sellers.
On 8 October 2026, CBP published its **Low-Value Shipments** Notice of Proposed Rulemaking in the Federal Register. The proposal is document 2026-20650, under docket USCBP-2026-0298.
The public comment deadline is **7 December 2026**.
This is a proposed rule, not a final rule. However, you should start preparing now. The changes could affect your U.S. importer of record arrangements, customs broker processes, landed costs, postal fulfilment and shipment records.
## Understand what CBP is proposing
The proposal would change how goods valued at **$2,500 or less** enter the United States.
The main changes include:
– Requiring most informal Entry Type 11 filings to be submitted electronically.
– Moving the filing deadline to **on or before the date of importation**.
– Requiring the final deliver-to party to be identified when different from the ultimate consignee.
– Allowing certain Chapter 99, Subchapters III and IV goods valued between $251 and $2,500 to use informal entry procedures.
– Establishing **Entry Type 13** for eligible international mail shipments valued at $2,500 or less.
– Requiring additional postal data, including the shipper or sender and tracking number.
– Requiring a single transaction bond or continuous basic importation and entry bond for Entry Types 11 and 13.
– Introducing a proposed minimum liquidated damages amount of $1,000 for specified bond breaches.
– Treating unentered international mail shipments as voluntarily abandoned after 15 days.
You can read the full [CBP proposed rule in the Federal Register](https://www.federalregister.gov/documents/2026/10/08/2026-20650/low-value-shipments).
## Do not confuse the proposal with an immediate new deadline
The date of **7 December 2026** is the deadline for submitting comments. It is not the date on which every proposed requirement automatically becomes law.
CBP must review comments before deciding whether to finalise, amend or withdraw the proposal. The final rule may also contain different implementation dates.
You should therefore separate your response into two parts:
1. **Prepare operationally** for the proposed requirements.
2. **Submit comments** if the changes would create material cost, timing or data problems for your business.
Entry Type 13 is already being tested in the international mail environment. The proposed rule would turn the process into a formal regulatory pathway for eligible postal shipments.
## See why low-value shipments are changing
The U.S. de minimis environment has already changed. Duty-free de minimis treatment for imports from all countries has been suspended since 29 August 2025. It is also scheduled to terminate on 1 July 2027 under the One Big Beautiful Bill Act.
As a result, shipments that previously moved through the de minimis exemption are shifting into informal entry procedures.
This matters because a low-value shipment is no longer necessarily a low-compliance shipment. CBP wants more information before or at the time goods arrive. That information helps CBP assess:
– Customs value.
– Tariff classification.
– Country of origin.
– Applicable duties and trade measures.
– The importer of record.
– The final recipient.
– Whether the goods require additional government agency clearance.
For international sellers, the practical shift is clear: your shipping data must be complete before the parcel reaches the United States.
## Recalculate your landed costs
The proposal could increase the cost of each low-value shipment. Your landed cost model may need to include:
– Customs duty.
– Section 122 or other applicable duties where relevant.
– Merchandise processing charges and other customs fees.
– Customs broker fees.
– Single transaction or continuous bond costs.
– Postal or carrier handling charges.
– Returns, storage and delay costs.
– U.S. state sales tax obligations where applicable.
For example, assume a UK seller sends a $600 product to a U.S. customer through a non-postal carrier.
A simplified estimate might look like this:
– Customs value: $600.
– Illustrative duty rate of 12%: $72.
– Broker handling fee: $30.
– Other carrier or processing charges: $18.
– Estimated customs-related cost before sales tax: $120.
The seller may therefore need to absorb or recover an additional **$120**, rather than treating the $600 product price as the complete delivery cost.
The duty rate in this example is illustrative only. The actual result depends on classification, origin, trade remedies and the shipment route. Do not use a flat percentage for every product.
State sales tax is a separate issue. Customs duty does not replace sales tax registration, collection or reporting obligations. Marketplace facilitator rules may cause Amazon, eBay or another platform to collect tax, but you still need records that reconcile platform reports, customer locations and returns.
## Prepare for Entry Type 13 postal data
Entry Type 13 is designed for eligible international mail shipments valued at $2,500 or less.
In addition to the information generally required for Entry Type 11, the proposed process would require:
– Shipper or sender identity and address.
– Postal tracking number.
– Product description.
– Country of origin.
– HTSUS classification.
– Quantity and weight where relevant.
– Customs value.
– Duty calculation.
– Importer of record details.
– Consignee and final deliver-to information where applicable.
The carrier would also need to provide the matching tracking number on the inward manifest.
This creates a data-matching requirement. The tracking number in your seller or fulfilment system must match the number transmitted by the foreign postal operator and carrier.
A mismatch could cause delays, manual review or difficulty proving that the correct shipment was entered.
## Protect your postal fulfilment process
The proposal would require eligible mail shipments to be entered on or before the date of importation. If a shipment remains unentered in CBP custody for 15 days, it could be deemed voluntarily abandoned.
That may lead to destruction or return through U.S. Postal Service procedures.
This is particularly important if you use:
– Royal Mail or other national postal operators.
– International fulfilment centres.
– Low-cost postal delivery from the UK, EU, Canada or Australia.
– Direct-to-consumer Shopify fulfilment.
– Marketplace orders shipped individually from overseas.
Review your service-level agreements now. Confirm who is responsible for:
– Preparing the customs entry.
– Acting as importer of record.
– Supplying the HTSUS code.
– Paying duties and fees.
– Obtaining a bond.
– Monitoring customs holds.
– Responding before the 15-day period expires.
Do not assume that your marketplace or postal carrier automatically accepts responsibility for every customs requirement.
## Review your U.S. importer of record structure
The proposal is especially relevant to sellers who ship into the United States without a permanent U.S. establishment. If you do not have a U.S. entity, your customs broker, carrier or another party may currently act as importer of record on your behalf.
The proposed bond requirements for Entry Types 11 and 13 could change how those arrangements work in practice. A continuous basic importation and entry bond, or a single transaction bond, would need to be in place for the relevant shipments.
You should review:
– Who is named as importer of record on your current shipments.
– Whether that party is willing and able to obtain the required bond.
– Whether the importer of record has sufficient information to file on or before the date of importation.
– How duty and fee liability is allocated between you, your broker and your customer.
– What happens if a shipment is held, abandoned or returned.
If your broker or carrier currently absorbs these responsibilities as part of a bundled service, confirm whether that will continue under the proposed rules. Bundled arrangements can obscure who is legally responsible when something goes wrong.
## Check your product data and classification
Accurate product data becomes more important under the proposal. CBP will receive more shipment-level information, and mismatches between declared data and the physical goods could trigger delays or penalties.
Review your product catalogue for:
– Correct HTSUS classification for each product.
– Accurate country of origin.
– Consistent product descriptions across sales, fulfilment and customs records.
– Declared values that reflect the actual transaction value.
– Any goods subject to additional government agency requirements, such as FDA, FCC or CPSC rules.
Errors that previously went unnoticed in a high-volume, low-value postal stream may become more visible when entries are filed electronically with more detailed data.
## Understand the bond and liquidated damages exposure
The proposal would require a single transaction bond or continuous basic importation and entry bond for Entry Types 11 and 13. It also introduces a proposed minimum liquidated damages amount of **$1,000** for specified bond breaches.
Liquidated damages are not the same as duties. They are a separate financial exposure that can arise when bond conditions are breached, for example through failure to file, failure to pay or incorrect entry data.
For sellers shipping many low-value parcels, even a modest number of breaches could create meaningful exposure. This is another reason to confirm exactly who holds the bond and who is responsible for compliance under your current arrangements.
## Practical steps to take before 7 December 2026
You do not need to wait for the final rule to act. Consider the following steps:
1. **Map your current shipment flows.** Identify which orders move by postal versus non-postal carriers, and which fall under $2,500.
2. **Confirm your importer of record.** Establish in writing who acts as importer of record and who holds the bond.
3. **Audit your product data.** Check HTSUS codes, origin and descriptions for your top-selling products.
4. **Recalculate landed costs.** Update your pricing and margin models for duty, broker fees, bond costs and handling charges.
5. **Review carrier and broker agreements.** Clarify responsibility for filing, bonds, holds and the 15-day abandonment rule.
6. **Check your tracking data flow.** Make sure the tracking number in your system will match the number transmitted by the postal operator or carrier.
7. **Decide whether to comment.** If the proposal creates material cost or operational problems for your business, consider submitting a comment before the deadline.
## Key dates to note
| Date | Event |
|—|—|
| 29 August 2025 | Duty-free de minimis treatment suspended for imports from all countries |
| 8 October 2026 | CBP publishes Low-Value Shipments Notice of Proposed Rulemaking |
| 7 December 2026 | Public comment deadline |
| 1 July 2027 | Scheduled termination of de minimis under the One Big Beautiful Bill Act |
## Final thoughts
CBP’s Low-Value Shipments proposal is a structural change to how goods valued at $2,500 or less enter the United States. It does not take effect immediately, but the direction of travel is clear: more data, earlier filing, formal entry procedures and bond requirements for shipments that previously moved with minimal friction.
International sellers should use the period before the comment deadline to confirm their importer of record arrangements, audit their product and tracking data, and update their landed cost models. Waiting until a final rule is published may leave too little time to adjust carrier contracts, bond arrangements and pricing.
by Ariful | Oct 7, 2026 | European VAT
Deadlines and changes to track
- 7 November 2026: The next quarterly update is due for the existing UK MTD for Income Tax cohort above £50,000.
- 23 October 2026: Consultation closes on Bulgaria’s draft VAT Act amendment proposing clearance invoicing and pre-filled VAT returns.
- 30 October 2026: UAE businesses with annual revenue of at least AED 50 million must appoint an Accredited Service Provider for e-invoicing.
- 28 October 2026: UK Autumn Budget. The government has ruled out increasing the main VAT rate.
- 1 January 2027: UAE mandatory e-invoicing begins for businesses in the first implementation group.
- 1 January 2027: The EU deemed-supplier rule extends to certain B2B goods supplied through marketplaces by non-EU-established sellers.
- 6 April 2027: UK MTD for Income Tax expands to qualifying sole-trader businesses above £30,000.
- 6 October 2027: Spain’s approved B2B e-invoicing mandate begins for businesses with turnover above €8 million.
- 1 July 2030: ViDA digital reporting begins for intra-EU B2B supplies, subject to national implementation.
- April 2029: The United Kingdom is planning mandatory e-invoicing.
1. Map Europe’s e-invoicing systems before your data is tested
Europe is not adopting one single e-invoicing model. It is developing three broad families of invoice control.
Family one: true clearance
Under a clearance model, the tax authority or its authorised platform validates the invoice before it is legally issued or recognised.
Examples include:
- Italy’s SdI system.
- Poland’s KSeF.
- Greece’s myDATA MARK.
- Romania’s RO e-Factura.
- Serbia’s SEF.
- Türkiye’s e-Fatura.
- Albania’s developing system.
- Moldova, where e-invoicing went live on 1 October 2026.
- North Macedonia, which is planning a system from 1 April 2027.
This model makes invoice status, transaction timing and data accuracy operational issues. A billing error may not simply require a credit note. It could prevent the invoice from being accepted at all.
Family two: reporting alongside invoice exchange
In this model, businesses exchange structured invoices through certified providers or Peppol. Transaction information is then reported at or shortly after issuance.
Key developments include:
- France’s system went live for larger businesses on 1 September 2026. Small and medium-sized businesses are expected to join from 1 September 2027.
- Slovakia is moving to structured e-invoicing from 1 January 2027.
- Croatia’s Fiscalisation 2.0 has applied since 1 January 2026.
- Belgium has proposed dual-sided e-reporting from 1 January 2028.
- Hungary is developing its digital reporting model.
- Spain approved its B2B mandate on 5 October 2026. Businesses above €8 million turnover must comply from 6 October 2027. Other businesses are expected to follow from 6 October 2028.
Family three: structured invoice exchange only
Here, businesses must exchange structured invoices, but the invoice data is not necessarily transmitted to the authority for every transaction.
Important dates include:
- Germany: issuance for businesses above €800,000 turnover from 1 January 2027 and for all businesses from 1 January 2028.
- Slovenia and Luxembourg: expected from 2028.
- Norway: expected from 2027.
- Portugal: qualified electronic signatures on PDF invoices from 1 January 2027.
- United Kingdom: mandatory e-invoicing planned from April 2029.
Bulgaria has also published a draft VAT Act amendment. It proposes a clearance model from 1 January 2028, penalties from 1 July 2028, and the replacement of VAT ledgers with pre-filled VAT returns. The consultation remains open until 23 October 2026.
Prepare for the ViDA timetable
The European Union’s VAT in the Digital Age framework is based on:
The legal framework has been in force since 14 April 2025.
From 1 July 2030, intra-EU B2B supplies will require an EN 16931-compliant electronic invoice issued within 10 days. The supplier and customer will also have near-real-time reporting obligations. Recapitulative statements will eventually be abolished.
National systems that were already operating before 2024 must converge with the EU model by 1 January 2035.
Action point: Build a country-by-country e-invoicing register now. Record the transaction type, invoice format, transmission channel, reporting deadline, correction process and evidence-retention period. This will reduce the risk of applying the right process in one country to the wrong process in another.
2. Treat pre-filled VAT returns as a control, not an answer
Pre-filled VAT returns are developing across Europe, but they do not all work in the same way.
Current examples include:
- Spain’s Pre303, which assists with Form 303.
- Greece’s myDATA system, which pre-fills editable amounts.
- Italy’s precompiled VAT documents for limited eligible taxpayers, with the trial extended into 2027.
- Portugal’s provisional return for a restricted resident population. It excludes areas such as imports, exports, reverse charge, cash accounting and special schemes.
- Romania’s RO e-TVA, which creates a post-deadline comparison statement rather than a tax claim title.
- Slovenia’s partially pre-filled return, operating since July 2025.
- Hungary’s eVAT/eÁFA, expected to become mandatory from 2027.
- Poland’s proposed opt-in e-VAT draft return, targeted for the fourth quarter of 2029.
- Serbia’s planned pre-filled model, targeted for 2027.
The central warning is simple: reported does not mean legally correct.
Authority data may not determine:
- Partial exemption.
- Business or private use.
- Fixed-establishment outcomes.
- Capital-goods adjustments.
- Bad-debt relief.
- Chain transactions.
- Import VAT recovery.
- Reverse-charge treatment.
- Marketplace and fulfilment movements.
Use the authority’s draft as a control input. Do not accept it without review.
Run a three-way reconciliation:
- Compare your ERP or accounting result with your digital-reporting submissions.
- Compare both against the authority-prepared view.
- Investigate every material difference and retain evidence of the conclusion.
Protect the purchase side. An input invoice missing from a pre-filled draft does not automatically mean that the VAT is non-deductible. Check the original invoice, the tax point, the supplier data and the relevant local
by Ariful | Oct 7, 2026 | Australia Updates
TITLE: ATO Credit Card Ban, Family Tax Benefit Recoveries and Payday Super: What Australian Businesses Need to Know
ATO refuses to reverse its credit card payment ban
The ATO has confirmed that it will stop accepting direct credit card payments after 30 November 2026. From 1 December 2026, businesses and individuals will need to use another payment method.
The decision follows the RBA’s removal of card surcharging from 1 October 2026. The RBA confirmed that eftpos, Mastercard and Visa introduced no-surcharge rules for credit, debit and prepaid card transactions from that date.
The ATO held a crisis meeting with business groups on 7 October after strong criticism from the Australian Chamber of Commerce and Industry, COSBOA, the Australian Retail Council and Master Builders. According to the ABC’s report on the meeting, the ATO did not agree to reverse its decision.
Taxation Commissioner Rob Heferen said merchant fees were estimated at almost $200 million a year. He said absorbing the cost was “not tenable” because it would reduce revenue available for government services.
Business groups argue that this creates a double standard. Australian businesses must generally absorb card acceptance costs in their overall prices, while the ATO has chosen to withdraw the payment option instead.
The ATO says:
- Credit card payments represent only 2.3% of payments made to the ATO.
- More than 60% of credit card payments by value come from privately owned and wealthy groups, public entities and multinational businesses.
- About 5% of small businesses use credit cards to pay tax.
Other organisations have also announced similar changes, including StrataPay, some private schools, local councils and rental payment platforms.
The ATO’s official statement confirms the transition period. You can continue using a credit card directly with the ATO until 30 November, but you should not leave the change until the final day.
Switch your payment process before 1 December
Review your payment arrangements now. This is particularly important if your business uses a credit card to manage BAS, GST, income tax or other ATO obligations.
Available alternatives include:
- BPAY
- Direct debit
- EFT or bank transfer
- Debit card payments
- Australia Post payment services
- An ATO payment plan where you cannot pay the full amount on time
If you have an existing payment plan linked to a credit card, contact the ATO and change the payment method before the next instalment. Doing this early will reduce the risk of a failed payment, default or unnecessary recovery action.
The RBA’s card surcharge FAQ explains that businesses can still offer discounts for particular payment methods. However, they should review payment displays with their payment service provider and follow applicable Australian consumer law requirements.
Automated debt recovery will be tightened for vulnerable taxpayers
The government is changing an automated debt-recovery process that applied tax refunds to Family Tax Benefit overpayments without first assessing whether the recipient was experiencing financial hardship.
The issue affects several agencies, including:
- The ATO
- Services Australia
- The Department of Social Services
An internal review found a jurisdictional error because affected recipients were not told that they could appeal on hardship grounds. The concern is that an automated system recovered debts without properly considering individual circumstances, repayment arrangements or hardship protections.
The Administrative Review Tribunal previously identified a systemic issue with automated offsets of tax refunds against family assistance debts. The Tribunal’s notice raised concerns about the way the process operated and whether relevant circumstances were being considered.
New objective exclusion criteria are being developed. These criteria are expected to prevent recovery from vulnerable individuals who meet recognised hardship conditions. The agencies have also published interim guidance and contact channels.
However, there is currently no confirmed date for the underlying system changes.
If your tax refund has been used to repay a Family Tax Benefit debt, do not assume that the automated decision cannot be reviewed. The ATO has acknowledged the systemic issue and provides a process for affected taxpayers to request reconsideration.
You should:
- Check the notice explaining how your refund was applied.
- Contact the ATO if the offset caused serious financial hardship.
- Contact Services Australia about the underlying Family Tax Benefit debt.
- Provide evidence of essential living costs, repayment arrangements or an agreed repayment pause.
- Keep copies of all notices, call records and supporting documents.
The ATO’s guidance on tax support and financial difficulty explains the available contact and support options.
Expect greater transparency from 10 December
From 10 December 2026, new automated decision-making transparency rules will require relevant Australian government agencies and other covered entities to disclose qualifying automated decision-making practices in their privacy policies.
The rules apply where a computer program makes, or substantially contributes to, a decision that may significantly affect an individual’s rights or interests and uses personal information.
Agencies will need to explain the types of:
- Personal information used
- Decisions made solely by automated systems
- Decisions where automated processing substantially supports a human decision
This deadline is especially relevant to organisations reviewing automated eligibility, debt, enforcement and service systems.
Payday Super creates a new payment-control test for employers
Payday Super began on 1 July 2026. Ten weeks into the new regime, employers should be checking whether payroll and clearing-house processes are consistently meeting the new timing requirements.
For ordinary contributions, super must reach the employee’s nominated fund within 7 business days of payday. For a new employee or the first contribution to a particular fund, the initial contribution may have up to 20 business days.
The contribution must be calculated on qualifying earnings at the current 12% super guarantee rate.
by Ariful | Oct 7, 2026 | US Updates
TITLE: CPSC eFiling for Mail Shipments: What Changes on 22 October 2026
What changes for mail shipments on 22 October 2026?
From 22 October 2026, international sellers sending CPSC-regulated consumer products to the United States by mail must follow a new electronic entry process.
The shipment must use CBP’s new Entry Type 13 or a formal entry, and the relevant Certificate of Compliance data must be transmitted through the Automated Commercial Environment (ACE).
This change affects ecommerce brands, digital businesses with physical products, fast-growing SMEs, and non-US owners of US entities. Direct-to-consumer sellers shipping by post or courier are firmly in scope.
Key dates to add to your compliance calendar
Use this checklist to prepare your US-bound shipments and filings:
- 8 July 2026: CPSC eFiling became mandatory for most imported, CPSC-regulated consumer products.
- 22 October 2026: CPSC eFiling will also apply to qualifying mail shipments. Covered goods must use Entry Type 13 or a formal entry, with certificate data sent through ACE.
- 15 October 2026: Final extended deadline for calendar-year 2025 Form 5472 filings for eligible foreign-owned, single-member US LLCs that filed Form 7004 on time. There is no second extension.
- 1 July 2027: The suspended $800 de minimis exemption is scheduled for permanent statutory repeal.
Do not treat the October date as a paperwork change that only affects customs brokers. The importer of record remains responsible for accurate and complete compliance data.
Before this change, international postal shipments could use the old postal informal entry process. That process relied on a bond and an Excel spreadsheet rather than a standard electronic entry in ACE.
From 22 October 2026, CPSC-regulated mail shipments will need to follow the new process. CBP’s Entry Type 13 is the electronic informal entry route for eligible mail shipments. Goods that do not qualify for Entry Type 13 may require a formal entry instead.
CPSC’s official guidance for mail shipments confirms that importers and brokers must transmit either a Full or Reference PGA Message Set through ACE.
The requirement applies to regulated products regardless of shipment value. There is no value threshold and no de minimis exemption for CPSC certificate eFiling.
That means you cannot assume that a product is outside the rules because it is:
- Worth less than $800.
- Sent directly to an individual US consumer.
- Shipped by post or courier.
- Fulfilled through a marketplace.
- Part of a small or occasional order.
The marketplace does not carry the importer’s compliance risk. The importer of record does.
Understand the two CPSC eFiling routes
You and your customs broker will generally use one of two filing routes.
1. Full PGA Message Set
With the Full PGA Message Set, you provide the required Certificate of Compliance data to your customs broker. The broker then transmits the information through ACE with the Entry Type 13 or other applicable entry.
This route requires the seller, manufacturer, supplier, or importer to have the necessary information available before the shipment is entered.
2. Reference PGA Message Set
With the Reference PGA Message Set, you first enter the certificate information in the CPSC Product Registry before the goods arrive in the United States.
You then give your customs broker the relevant Certificate Identifiers, including:
- Certifier ID.
- Product ID.
- Version ID.
The broker uses these identifiers to submit the reference data in ACE.
Both routes can work. The important point is that the importer of record must ensure the information is accurate, even when the broker performs the transmission.
Prepare the required certificate data before dispatch
CPSC eFiling is not just a request for a certificate number. The required data covers key product and testing details, including:
- Product identification.
- The certifying party.
- Applicable product safety rules or standards.
- Date and place of manufacture.
- Most recent test date and test location.
- Contact details for the test-record holder.
- Certificate identifiers where the Reference PGA Message Set is used.
Your product may require a Children’s Product Certificate or a General Certificate of Conformity, depending on the applicable safety requirements.
Start with the manufacturer or supplier. Ask them to confirm:
- Whether the product is subject to a CPSC safety rule, ban, standard, or other applicable requirement.
- Whether a current Certificate of Compliance exists.
- Whether the certificate covers the exact product model, batch, and manufacturing location.
- Whether the testing information is current and complete.
- Whether the certificate data can be provided in time for the broker’s ACE transmission.
Do not rely on a generic supplier statement that a product is “certified”. The certificate must relate to the product actually being imported.
Check the HTS code, but do not rely on the list alone
CPSC guidance identifies approximately 600 HTS codes that are likely to require a certificate or that are treated as high risk.
The list is useful for screening your catalogue. It is not exhaustive and does not decide the legal obligation by itself.
A product may require CPSC eFiling even if its HTS code does not appear on the list. Equally, an HTS code on the list does not automatically mean that every product classified under it needs a certificate.
For each product, you should:
- Confirm the correct 10-digit HTS classification.
- Check whether the product falls under a CPSC mandatory standard or prohibition.
- Review the relevant CPSC eFiling and certificate guidance.
- Confirm whether a CPC, GCC, or other compliance document is required.
- Record the decision and supporting information in your product compliance files.
This review is particularly important for ecommerce sellers with large catalogues, product bundles, private-label goods, or frequent supplier changes.
Follow this action plan as a direct-to-consumer seller
If you ship products directly to US consumers, complete these four checks now.
1. Verify your HTS codes
Review every product that may be regulated by CPSC. Confirm the correct HTS code and compare it with the CPSC guidance list.
This will help you identify products likely to be flagged in ACE and reduce avoidable holds.
2. Confirm certificate status with your supplier
Ask the manufacturer or supplier for the current Certificate of Compliance and supporting testing information.
Check the product identity, applicable safety rules, manufacture details, test date, test location, and contact information. Doing this before dispatch prevents missing data from delaying the shipment.
3. Confirm the filing route with your customs broker
Ask your broker whether they will use the Full PGA Message Set or the Reference PGA Message Set.
Also confirm:
- Who creates or maintains the Product Registry record.
- Which party supplies the certificate data.
- When the broker needs the information.
- How corrections or updated certificate versions will be handled.
4. Build the certificate data into your shipping process
Add CPSC certificate checks to your pre-dispatch workflow. Treat missing certificate data in the same way as a missing commercial invoice or shipping label.
Document who is responsible for the certificate, where it is stored, and how it is passed to the broker.
What this means for international sellers
The 22 October 2026 change closes the gap between postal mail shipments and other entry types. CPSC-regulated consumer products sent by mail will now require electronic entry and certificate data in ACE, regardless of value.
For direct-to-consumer sellers, the practical risks are shipment holds, CBP delays, and rework at the border. In most cases, these are avoidable if the certificate data is accurate, complete, and available before the goods leave the origin country.
The importer of record remains responsible throughout. Work with your supplier and customs broker now so that the certificate data, HTS classification, and filing route are confirmed well before 22 October 2026.