By Janson Wang, Founder of ASG Dropshipping · Originally completed August 18, 2026 · Verified and updated September 26, 2026 · 20 min read
Your gross margin sheet has a landed cost number in it. Somebody typed that number in once.
Four dated changes landed between June and September 2026: an existing de minimis suspension got written into regulation, a new Section 301 duty layer took effect, a fee schedule was set for October, and CBP’s own refund guidance carried a new page date. None of those events touched your spreadsheet.
So the number is still there. Whether it’s still true depends on which of three different jobs you’re using it for.
Yes, China fulfillment still works. What doesn’t survive unchanged is a single landed-cost number doing three different jobs at once.
There is no single landed-cost template that resolves every customs, accounting and pricing decision for a China-to-US shipment.
Customs uses one figure — the customs value the law puts on your entry, plus whatever is added or documented as deductible.
Your pricing uses a second — a dated estimate, with its assumptions written down. Your own books use a third — the reconciled cost, built after the fact from actual invoices and payments.
Define the purpose and boundary first, then pick a date to recheck each one.
You don’t have a calculation problem. You have three numbers doing one job’s work.
A Shopify Community thread from March 2025 has a seller stating his own position. He buys from China, Canada and the US.
He ships only to the US. Then: My profit margins are not that great as it is but if I charge more, big box will always win, unless the buyer doesn't notice.
One seller, one thread. Read it as a voice, not a measurement.
He wasn’t asking for a formula — he was asking how much room he had left. That answer moved more than once this year, differently depending on which of the three jobs you’re asking about.
I’m Janson, CEO of ASG Dropshipping. We have run since 2019, with a 200+ team across 4 warehouses in Shenzhen + Dongguan.
Key Takeaways
One landed-cost number can’t do three jobs. Customs valuation, a dated pricing estimate, and your own reconciled operating cost answer different questions and can legitimately produce different figures for the same shipment.June 24, 2026 wrote an existing suspension into regulation — it didn’t start one. De minimis treatment for these parcels was already gone before that date; every qualifying non-postal parcel now needs a formal or informal entry.A new Section 301 layer took effect July 24, 2026, published four days later. It applies to goods entered for consumption on or after that date — not a blanket “already cleared” reading — and its notice carries exceptions we haven’t read line by line.CBP’s refund guidance and the underlying court ruling run on two different clocks. The Supreme Court ruled in February 2026, outside this window. What changed between June and September was CBP’s administrative language on processing claims — not a court deadline, not a promised date for yours.
Direct answer: Four dated events sit between June and September 2026, and they aren’t the same kind of event: one codified an existing rule, one added a new duty layer, one published fee amounts that only take effect later, one changed the wording on a government refund page.
Keeping those four apart is the point of this section.
US import duty changes you have not priced in
Event
What actually happened
Applies to
Status as of September 26, 2026
De minimis suspension written into CBP regulations at 19 CFR 10.151
An existing suspension for qualifying parcels was made indefinite and codified in regulation
Non-postal parcels valued at $800 or less
Currently in force since June 24, 2026
New Section 301 duty layer covering 60 economies, China listed twelfth
A new tariff layer stacked on existing duties, tied to a forced-labor enforcement investigation
Goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time July 24, 2026 (notice published July 28)
Currently in force; annex exceptions not reviewed here
CBP COBRA user fees adjusted for Fiscal Year 2027
New fee amounts published for the fiscal year that starts October 1
Entry-level fees: MPF, informal entry, manual surcharge, express consignment, broker permit
Future — the FY2026 amounts remain the legally required figures through September 30, 2026
CBP’s IEEPA Duty Refunds page updated
The page’s own footer date moved to September 2, 2026, and it states a general processing window for refund claims
Refund claims tied to IEEPA duties collected since February 3, 2025 — a separate, earlier court ruling
Current administrative guidance; the underlying court ruling dates to February 20, 2026, outside this window
Row two is the one that catches people.
The determination was published July 28, but it reaches back to any entry for consumption, or withdrawal from a warehouse for consumption, made four days earlier, on July 24.
A seller who first read the notice on the 28th could already have entries inside the new layer — not because anything “cleared” early, but because the applicability date and the publication date aren’t the same date.
The notice states its own exceptions, including handling for goods already in transit, which we have not read line by line — check the annexes against your own HTS codes before assuming this layer applies.
It also covers 60 economies, so this article won’t tell you what moving production elsewhere does for this particular layer.
Takeaway: Write the effective date and the applicability event — entry for consumption, not “clearance,” not “publication” — beside each duty assumption in your sheet.
Direct answer: Since June 24, 2026, a parcel valued at $800 or less arriving outside the international postal network must clear through formal or informal entry.
That entry brings a set of fees a de minimis parcel never carried — and they are not all charged to the same party, and not all of them apply to the same shipment at once.
We covered the declaration mechanics in HS codes, product descriptions and DDP shipping from China . This section is about what the entry does to your cost per order.
Landed cost per order after de minimis ended
Cost line
Who the government charges
Effective
What to check before you add it
Entry filing itself
The importer of record, via the filer
June 24, 2026
Required for non-postal parcels of $800 or less
Merchandise processing fee
The importer of record, ad valorem with a min/max
FY2026 rate through Sept 30; new FY2027 rate October 1
One fee per entry — not stacked with informal/manual fees below
Informal entry fee
The importer of record
New rate October 1, 2026
Three tiers, mutually exclusive — only one applies per entry
Manual entry surcharge
The importer of record
New rate October 1, 2026
Only when handled manually, not automatic
Express consignment fee
Per waybill or bill of lading
New rate October 1, 2026
Carrier/facility fee, separate from the MPF
Customs broker permit user fee
The broker, annually
New rate October 1, 2026
Pass-through is your service agreement, not the fee schedule
Harbor maintenance fee
The importer, on qualifying cargo
Standing rule
Commercial vessel cargo only — air freight doesn’t trigger it
That last row is the one sellers get backwards. The harbor maintenance fee is a port-use fee that, by its own terms, attaches to cargo on a commercial vessel.
The regulation carries exemptions we did not read line by line, so this article won’t tell you who is exempt — only which mode starts the clock.
None of these seven lines is a number you add to every parcel automatically.
Which ones apply, who’s legally on the hook, and whether your broker already folded a line into your quote is worth one direct question, not an assumption.
Here’s what an unexplained fee looks like in practice. Vacek ships Canada to the US through a label platform.
A large retroactive adjustment landed on him, and he wrote: Entry Prep Fee & Disbursement Fees … no idea what they are or are for. That ellipsis is his own.
His dispute was with the label platform, not a customs broker, and his lane isn’t yours — read it as one seller meeting an unexplained line, not as a fee schedule.
Takeaway: Ask your broker three things about each fee line: does it apply to this entry, who is it legally charged to, and is it already inside the quote you were given.
Direct answer: “Landed cost” means three different things depending on who’s asking, and no single template resolves the customs, accounting and pricing decisions on a China-to-US shipment at once.
Define the purpose and boundary first, and most of the apparent contradictions between sources disappear.
You’re asking the right question. The trouble is the phrase gets used for three jobs at once, and most sources you’ll find are only answering one of them.
Job one: customs valuation. What CBP assesses your entry on.
Commerce’s import-tariffs page frames a landed shipment as purchase price, freight, insurance and other fees “up to the port of destination” — a boundary for that page’s own scope, not a claim nothing exists past the port.
CBP’s own valuation guidance is specific about proof: freight and insurance costs deducted from transaction value must be “the actual, as opposed to estimated costs,” identified separately.
That governs one specific filing calculation — not a blanket statement that customs rejects estimates everywhere.
Job two: your pricing estimate. What you charge, before the shipment happens.
A different Commerce page — aimed at US exporters pricing into a foreign market, so its worked example doesn’t transfer here — still gives the right instruction: “Always refer to these landed costs as ‘estimated.’… your customs broker or shipping company may have additional charges.” Not a disclaimer.
An instruction to date the number.
Job three: your reconciled operating cost. What the shipment actually cost, built after the fact from real invoices and payments.
The accounting rule closest to this job — 26 CFR 1.471-3 — adds “transportation or other necessary charges incurred in acquiring possession” to net invoice price.
We probed the text for “duties”: zero hits.
Duties sit under “other necessary charges” as a matter of reading, not a quotation — ask your accountant which side of the related small-business carve-out you’re on.
A fourth voice: a carrier’s framing (FedEx: product, shipping, customs, risk, overhead) buckets the same costs a fifth way — undated, from a company that sells the freight, and it does name payment processing under “overhead,” so that’s not something only ASG accounts for.
One line most outside sources skip: a returns reserve.
A US return crosses no border back, and duty already paid doesn’t travel back with the product — an operating-cost line, not a customs or tax requirement, worth sourcing from your own last four quarters.
Takeaway: Before you compare a landed-cost number with anyone else’s — a competitor’s, a carrier’s, a government page’s — ask which of the three jobs it’s answering.
Numbers built for different jobs aren’t wrong when they disagree.
Direct answer: Three official sources, read on the same day, showed three different relationships between “when I looked” and “what’s true now.” None was wrong for its own moment — which is exactly why a landed-cost figure needs a recheck date attached to it, not just a source.
The tariff schedule tells you how fast the ground moves.
USITC’s own release endpoint named 2026 HTS Revision 16 on August 17, 2026 — sixteen revisions in the first seven and a half months of the year.
A revision number has a property a duty rate doesn’t: it only goes up. Log it each quarter; any increase means your HTS assumptions need a re-read.
A government fee page can correctly show last year’s number while a newer one is already published.
On August 17, 2026, CBP’s customs broker fees page listed the annual broker permit fee as $185.38, “as of October 1, 2025.” Separately, the Federal Register notice published July 31, 2026 had already set the Fiscal Year 2027 figure at $190.88, starting October 1.
Both are correct at once: $185.38 stays the legal amount through September 30, and $190.88 takes over the next day.
A page showing this year’s number isn’t behind — it just isn’t showing next year’s yet.
CBP is also on record about its own lookup tool’s limits: its duty rates page says the USITC database gives “an approximate idea,” and states plainly: CBP makes the final determination of what the correct rate of duty is, not the importer. For one high-volume product, a Binding Ruling ends in a number CBP stands behind for the facts submitted — fact-specific, and it can change.
Timing for the rest of your pipeline: customs clearance time from China to the USA .
Takeaway: Every time you look something up, record two dates: the day you looked, and the page’s own last-modified date.
A gap between them isn’t an error — it’s the reason to check again next quarter.
Direct answer: Three separate things are true here, and they run on different clocks. A federal court ruled a set of tariffs unlawful.
CBP is running an administrative process to handle refund claims from that ruling.
Your own claim’s status depends on facts specific to you — who was importer of record, whether a broker is authorized to act for you, and what account CBP has on file.
None of the three tells you a date for the other two.
On February 20, 2026, the Supreme Court ruled in Learning Resources, Inc. v. Trump that tariffs imposed under IEEPA and collected since February 3, 2025 were unlawful.
CBP’s own filing on the matter, dated July 8, 2026, puts a scale on it: an estimated $166 billion in IEEPA duties assessed from February 3, 2025 to February 24, 2026, across over 53 million entry summaries.
Refunds run to the Importer of Record through a CAPE Declaration filed in the ACE Portal, paid by ACH transfer.
That July 8 filing also contains a sentence worth separating from everything around it: the CIT “has not set a timeframe to date.” That’s about the court’s own compliance deadline, while the order stays suspended “to the extent that it requires immediate compliance.” It’s a statement about litigation procedure, not about whether CBP has published administrative guidance on refund-processing time — different questions, different bodies.
CBP’s own IEEPA Duty Refunds page — a September 2, 2026 footer date — answers the administrative question: valid IEEPA refunds are generally issued within 60 - 90 days following acceptance of the CAPE Declaration, unless a compliance concern requires further CBP review. A general window for accepted declarations, not a guarantee for any specific claim; the compliance-review clause means one can run longer.
This article did not independently verify when CBP first published guidance in that range — only that this page carries it as of the date shown.
CBP also states: Most small businesses do not have an ACE account and instead enlist the assistance of a licensed customs broker... They will continue to be able, and are expected, to use their customs brokers for the IEEPA refunds process and CAPE. A broker acting for you doesn’t remove the underlying checks — an eligible entry, an active ACE account on file, and who CBP’s records name as Importer of Record.
Paying the duty isn’t, by itself, proof of that role.
Four roles worth keeping separate: the Importer of Record confirms identity and responsibility.
A broker can advise and submit a CAPE Declaration, but only under that authorization — it doesn’t make the broker the recipient. CBP makes the actual determination.
Your accountant handles how a refund lands in your books, a separate question from whether it arrives.
A “DDP” label tells you who paid a leg of freight, not who is Importer of Record — don’t use it to decide who’s owed a refund.
Our overview of how tariffs work in dropshipping covers who’s usually the importer of record on a China-to-US parcel.
The New York Fed’s July 8, 2026 post confirms the ruling happened, from a separate institution; the dollar figure belongs to CBP’s filing alone.
Takeaway: Ask your broker two questions this week: were any of my entries since February 3, 2025 assessed under IEEPA, and am I the importer of record on them.
CBP’s general processing window describes accepted claims — it isn’t a promised date for yours.
Direct answer: There’s a real case for not rebuilding your pricing today — survey data shows firms passing tariff costs through slowly, and a rebuild costs staff hours.
That’s a pricing decision. It’s separate from whether you actually know your current cost, and a few sellers’ own threads show what happens when the two get treated as the same problem.
The New York Fed’s Regional Business Surveys of May 2026 found district firms paying tariffs directly split three ways: a large share had more price increases still to come, a smaller share had already passed costs through in full, and some planned increases more than six months out — for two reasons: fixed-price contracts that can’t reopen early, and a deliberate gradual approach.
Read the population first: service firms and manufacturers in one Federal Reserve district, not Shopify sellers, describing plans rather than results.
The Cleveland Fed separately found a relationship between expected cost and price growth on costs in general — both surveys sit inside the same Federal Reserve System, so count them as two surveys, not two confirmations.
You can watch the pricing side of that trade-off in seller threads.
One merchant wrote in April 2025: The ever changing tariffs has really left us with no choice but adding a tariff to every US order. But instead of passing on the entire duties to the customers ... we like to just add a flat rate duties of $15 to each order to maintain a competitive price and absorb any outstanding amount as revenue loss. A different seller named the same competitive fear directly: Another option is including the Trump tariffs in the price, but then I worry about our prices appearing to be higher than those who take a different approach. The tooling underneath that decision isn’t stable either — one merchant reported in May 2026 that the app he had been relying on to apply tariffs at checkout was no longer working for him.
Now watch what happens when a seller tries to verify the number instead of just displaying one. The same thread that carried the flat-fee post also carries two more replies.
One: would love to know this too. These tariffs suck. Cants [sic] sustain business and store like this unless the consumer pays for some of it. Another, describing what platform support offered: I just chatted with tech support and they said I could edit my tax rate by overriding that but it would just look like the taxes went way up and I want it to be transparent that this is a different fee. They had no other solutions. Neither reply answers where the number comes from — one restates the frustration, the other relabels a tax field.
A checkout setting can make a charge visible to a customer. It can’t tell you whether the charge is right.
Takeaway: Decide your price on purpose, on your own schedule. Decide your cost on the schedule below, regardless of what you do with your price.
A stale cost figure and a stable price aren’t the same thing, even when they sit in the same spreadsheet.
Direct answer: Six things, checked on a schedule, tell you when your landed-cost model is stale.
This is our own operating recommendation, not an official requirement: review the full set quarterly, and rerun the relevant row immediately whenever your product, origin, HTS code, carrier route, or a fee notice changes.
Checking your cost is a different decision from changing your price — keep them separate.
The good news: every input below is published somewhere. The bad news: no agency publishes the order to check them in — that part is a cadence, and nobody hands you one.
A recheck routine, plus how to test one shipment
What to check
Where
How often
How you prove it moved
Tariff schedule revision number
USITC current-release endpoint
Quarterly, and after any notice affecting your goods
Revision number is higher than your last logged value
Your own HTS codes against the current schedule
Current HTS schedule, plus the Federal Register notice covering your goods
Quarterly, and on any product or origin change
A code, note or annex reference that differs from your file
Entry-level fee amounts
The Federal Register user fee notice, or your broker
Once a year before October 1, and whenever a new notice publishes
The fiscal year printed on the notice you’re holding
What your broker actually billed
Your own entry summaries and broker invoices
Every shipment cycle
A fee line that wasn’t in your model
Returns rate feeding your reserve
Your own order data
Quarterly
The trailing four-quarter figure changed
CBP’s IEEPA refund guidance
CBP’s IEEPA Duty Refunds page footer
Quarterly, and whenever your broker writes
The footer date differs from the last one you logged
A single-shipment reconciliation, step by step
Run this on one order the next time a number looks off. It won’t hand you a company-wide percentage, but it will tell you whether that one shipment’s cost moved, and why.
Map the order to the package, with identifying details removed. Pull the Shopify order and the matching package number; strip customer name, address and payment details before this goes anywhere near a spreadsheet you’ll share.Identify the importer of record and the broker of record. They may not be the party who paid Shopify. If you don’t know who your IOR is on this lane, that’s the first gap to close.Check the product description, origin and classification actually filed. Confirm the HTS code and country of origin on the entry match what you believe the product is — a wrong classification changes every downstream fee.Record what Shopify collected from the customer at checkout, if anything was collected for duties or import fees on that order.Pull the entry summary and the broker’s invoice for that shipment. These carry the actual MPF, any informal-entry or manual-processing fee, and any express-consignment charge that applied.Compare the two, and write down the variance and its basis. Not “the numbers don’t match” — the specific line that differs, and why: a fee that wasn’t in your model, a classification that changed, a rate that moved.
Every run of this ends in one of four states, and all four are legitimate answers: confirmed change (you found the specific line and the reason), no change (you checked and nothing moved), not applicable (this shipment is out of scope — a different Incoterm or entry type, for example), or UNKNOWN (you couldn’t get one of the records above — log what’s missing and who you asked, rather than guessing a number to fill the gap).
If your problem is timing rather than classification, our note on how long customs can hold a package covers what causes the wait.
One boundary on our own side: ASG doesn’t give tax, legal or customs advice, and neither does this article.
Within an agreed service, what we can supply is documentation on the fulfillment side. Your broker rules on classification; your accountant rules on your books.
This routine only works if someone owns it and the paperwork stays re-readable next quarter.
Takeaway: Put the six-row check on your calendar as a recurring quarterly task with an owner’s name on it, and run the single-shipment walkthrough the moment a number looks wrong.
An unowned routine is a document, not a routine.
Rebuilding a landed cost model, and your current supplier won’t give you itemized shipment costs? Talk to our team about what documentation we can provide within your service agreement — we’ll tell you plainly what’s in scope and what isn’t.
Is a landed cost figure ever “final”?
Not for pricing.
The government’s own instruction is to call an estimate “estimated,” since duties, taxes and broker charges can change after you write it down — an instruction to date the figure, not a disclaimer.
Your reconciled cost, built from actual invoices after the shipment, is a different number.
What’s the difference between landed cost and customs value?
Different readers.
Customs value is what your entry gets assessed on, and CBP restricts which freight and insurance figures may be deducted from it — actual costs only, identified separately.
Landed cost is your own management number, with no fixed boundary.
Does customs reject any estimated cost, anywhere in the process?
No — that overstates a narrower rule. CBP requires actual, separately identified freight and insurance costs specifically for deducting them from transaction value.
Your own pricing estimate is still expected to be an estimate.
Who makes the final call on my duty rate?
CBP does — not you, not a database. The USITC lookup gives an approximate idea only.
For one high-volume product, a Binding Ruling ends in a number CBP stands behind — though it’s fact-specific and can change if the facts or rules do.
Is the de minimis exemption coming back?
No.
The suspension for qualifying non-postal parcels of $800 or less is now written into regulation as indefinite; June 24, 2026 codified an existing suspension rather than starting a new one.
Does moving production out of China avoid the July 2026 Section 301 layer?
This article can’t answer that for your product. The notice covers 60 economies, lists China as the twelfth determination, and carries annex conditions we haven’t read line by line.
Check your own HTS codes first.
Do I need my own CBP account to get an IEEPA refund?
Not necessarily — most small businesses use a broker instead of holding their own ACE account.
But that doesn’t settle who’s entitled to the refund: that depends on who CBP’s records show as importer of record, not who paid the duty or which shipping term was used.
Does a domestic return get my duty back automatically?
No. A return that stays inside the US doesn’t unwind the duty already paid on that entry.
Separate paths exist for goods re-exported, destroyed, or qualifying for drawback — each with its own conditions, worth checking with your broker.
Does air freight trigger the harbor maintenance fee?
No. The fee attaches to cargo on a commercial vessel; air freight doesn’t meet that condition.
Exemptions exist that we haven’t read in full, so treat this as the trigger rule only.
Running the recheck and finding gaps in your own numbers? Send us one recent shipment — with account numbers and customer details removed — and we’ll tell you which landed-cost lines we can document from our own records, and which ones your current setup leaves blank. Start there .
Janson Wang is the founder of ASG Dropshipping. ASG has run since 2019 and works with 5,000+ sellers.
We run a 200+ team across 4 warehouses in Shenzhen + Dongguan, with 2,300+ verified factories, shipping to 200+ countries. Those figures are current as of September 2026.
Federal Register — Indefinite Suspension of the De Minimis Exemption — effective June 24, 2026Federal Register — Notice of Actions in Section 301 Investigations — effective July 24, published July 28Federal Register — Court-Ordered Refunds Under IEEPA Worksheet — $166 billion, 53 million entriesCBP — IEEPA Duty Refunds — 60–90 day window; page dated September 2, 2026Federal Register — Customs User Fees Adjusted for Fiscal Year 2027 — $190.88 broker fee, October 1, 2026USITC — Harmonized Tariff Schedule current release endpoint — Revision 16 on August 17, 2026International Trade Administration — Import Tariffs & Fees Overview — costs up to the port of destinationInternational Trade Administration — Determine Total Export Price — always call it “estimated”eCFR — 26 CFR 1.471-3 Inventories at cost — necessary charges test; duties not namedeCFR — 19 CFR 24.24 Harbor maintenance fee — vessel cargo onlyCBP — Customs Broker Fees — $185.38, as of October 1, 2025CBP — Determining Duty Rates — CBP makes the final determinationCBP — Proper Deductions of Freight and Other Costs From Customs Value — actual, not estimated, costsFedEx — What Is Landed Cost and How To Calculate It — carrier’s five-bucket framingFederal Reserve Bank of New York — More Tariff Pass-Through Is in the Pipeline — May 2026 surveyFederal Reserve Bank of Cleveland — SORCE Insights: The Relationship between Costs and Prices — cost/price pass-throughShopify Community — Impact to dropshipping platform from tariffs — the intro’s seller quoteShopify Community — How to add a fixed amount of tariffs — the flat $15 lineShopify Community — I’m curious how people are addressing tariffs — competitive-price fearShopify Community — Shipstation adjustment charges, post 5 — Vacek’s unexplained fee
Six ASG figures appear above (team size, warehouses, factories, sellers, countries, start year), from internal records, stated as of September 2026 — ask us for current figures rather than quoting these later.
Every US policy date, fee figure and quotation comes from the sources listed.
This revision did not verify the exact date CBP’s general refund-processing language first appeared; it verifies only that the cited page carries it as of the date shown.
Two scope notes on the outside evidence.
The pass-through findings cited in the wait-argument section describe service firms and manufacturers surveyed by Federal Reserve banks, not Shopify DTC sellers, and they describe plans rather than results.
The seller quotations are individual posts from 2025 and 2026, dated as shown, and most predate the 2026 policy events above; none of them ships the exact China-to-US lane every reader is on.
Read them for the shape of the problem, not as a sample of this article’s reader.
A landed-cost number without a recheck date isn’t a number. It’s a memory of one.
Nothing in this year’s changes makes the number harder to calculate.
What changed is how many different clocks are now running against it at once — a new duty layer, a fee schedule waiting for October, a court case working through an administrative process on its own timeline, and a page footer that can move without anyone telling you.
None of that gets solved by a better formula. It gets solved by knowing which of your three landed-cost jobs you’re checking, and when you last checked it.
You don’t need a customs department to do this. You need a short list of what to check, a date next to each one, and somebody whose name is on the task.
This article describes published rules, dated official pages and survey findings, as verified through September 26, 2026. It is not tax, legal or customs advice, and it is not a prediction about refund timing, future rates, or the outcome of any specific claim. Your product, your codes, your entries and your broker’s records change the answer.
