The End of the ‘Simple Import’

A common concern we hear from importers today is that they are just importing apples, or some other ‘simple’ import. It’s a lament we have heard many times: Importers who once had their goods sail through Customs quickly and easily now find themselves facing what seems like a dramatic uptick in documentation and regulatory requirements. This increase in regulatory concern often feels disproportionate to the entry value and sophistication of the goods being imported, leaving it out of step with what was once considered by the importer as ‘simple.’ 

Apples are anything but anymore in the eyes of Customs.

To a business unfamiliar with the realities of importing into the US currently, it may be tempting to think that your broker has become overly invested in what seems like tedious minutiae. You might be tempted to question why, if your imports haven’t changed, you are being asked to provide more and more information on those imports. The answer is simple: your imports may not have changed, but everything else has, and the work involved has skyrocketed.

So, how did we get here? How has this division between the complexity of a good from the effort required to process it grown so wide? And now that we’re here, is there even such a thing as an uncomplicated good anymore? Let’s find out together as we mourn the end of the simple import and see what kind of new shape it may still have in the future.

What Happened? 

Why is this the case? Maybe it’s just US Customs policies and advanced detection technologies, or maybe it comes from a more political place, like the most recent surge of trade actions and shifting trade priorities. In the end, it’s all correct to a certain extent; there are many different factors at play. What it boils down to is that, from our perspective, at the holistic and ideological level, we are seeing the endgame of a slow structural shift towards a much more rigorous Customs and Border Protection (CBP). Seemingly, industry by industry, and commodity by commodity, Customs has become characterized by more scrutiny and a need for greater detail. Whether it’s a new tariff or Partner Government Agency (PGA) requirements, or an increase in the number of audits, as an organization, it is more exacting in its demands and consistently stricter in its enforcement than ever before. 

Add to that using increasingly sophisticated detection apparatus to ensure that importers are in strict compliance, and it’s as far from ‘simple’ at Customs as it has ever been outside of a major incident. 

Of course, it is beyond the purview of this blog to wade into the political or speculate on the reasoning behind this apparent change, but what is currently undeniable is that increased scrutiny and compliance requirements for importers are more thorough at every level. From our perspective as brokers and Trade Advisors, we have entered an era where a significantly greater focus is being placed on gathering complete information and determining the veracity of that information before goods are permitted to cross. Ultimately, a more rigorous effort has been made at nearly every level to tighten the belt on imports into the country, with greater onus than ever being placed on the importer to prove that their goods are up to the level. 

Let’s take a look at some of the key examples that indicate this overall change in priority at Customs.

The End of De Minimis

Arguably, the quintessential example of the end of the simple import is the suspension of the de minimus exemption. For importers not in the know, or who never benefited from de minimus, the $800-or-less exemption on imported goods and its effect on importers, particularly those in e-commerce, were significant. While it was in effect, any goods that qualified for de minimis were exempt from duty and tax upon entry into the US. 

For many businesses, the suspension of this exception was a significant blow to the way they have done things for nearly 100 years. But beyond the financial blow, this ending represented a sweeping increase in regulatory complexity for importers - particularly those engaging in e-commerce. Goods that once required a fraction of the documentation now require a formal or informal entry with complete details for all their shipments, and the work associated with those imports has, as a result, increased by a significant magnitude not only for the importers but for the brokers they employ. 

Not only are these importers struggling to come to grips with what exactly they now need in terms of documentation in a post-de minimis suspension world, but the goods themselves are now being scrutinized at the Customs level in the same way that much larger shipments were adding to the time, focus, and complexity of the import.

There’s more to it even than that, though, as now nothing falls beneath the notice of Customs, a factor that will come into play momentarily. However, this is perhaps the most direct example of the end of the simple shipment; the amount of paperwork and consideration required has, seemingly overnight, increased at a level that left many businesses reeling, but other things have been slowly gathering speed as the months have gone on. 

The Front Line

Perhaps one of the larger reasons behind this apparent shift in worldview is that over the past few decades, CBP and its related PGAs, along with most of the world, have increasingly been called to serve as a front line against a host of criminal, social, commercial, and political challenges, and of late, this global shift has only accelerated.  

From enforcing tariffs to combating fentanyl, counterfeit goods, and products made with forced labor, it’s a gargantuan task by virtually every metric, and as a result, bit by bit, we have seen a necessary move towards a more cooperative approach with importers under the auspices of CBP’s ‘informed compliance’ and ‘shared responsibility’ precepts. ‘Reasonable care’ now often includes the requirement to prove the compliance of their goods with one of the most significant examples, the Uyghur Forced Labor Prevention Act (UFLPA), introduced in 2021.

For those unfamiliar, the UFLPA bans goods from the Xinjiang Uyghur Autonomous Region of China. It was one of the first acts of its kind to implement a ‘rebuttable presumption’ for goods, and what that means is that the importer is obligated to provide the proof of their ‘innocence’ and that their goods did not come from the Xinjiang Region. It is unique as a law in that if you can’t prove it, then your goods will be rejected out of hand. 

Combine this with the de minimis being suspended above, and the result is clear: every part of your import is now under the microscope, and no matter the size or cost of the good, nothing is beneath the notice of Customs. 

While avoiding goods made with forced labor is inherently a good thing, this means, once again, another hefty increase in the documentation required for even the simplest import. 

Of course, there are many other elements we can look at, for example, many sections of goods now require the derivatives of their finished articles to be declared separately, including the appropriate documentation as though that was the good itself. This is a departure from the old way of thinking, where the ‘essential character’ of the article may have been sufficient for declaration, but now it is what regulated parts make up that good, and how much those parts contribute to the value of the article in question. 

You then need to consider the relevant PGA filing, which may require an entirely different collection of documentation, and before long, what was once simple has become markedly more complex. 

A good imported today may need a base filing, a PGA filing, and anything required for any relevant applicable tariffs, so taken together, it is evidence of a fundamental shift in the perspective of Customs that is increasing the workload for importers, and in doing so, heralding the end of the ‘simple import.’ 

The New Simple is Trade Advisory

Where does this leave us? The hard truth of the matter is that in 2026, an import is not just an import, and the age of simple declarations is over. The fact of the matter is that there is just no room for this incredibly complex process to be ‘simple’ anymore, no matter the good, and the US Government appears to be ahead of that curve. Now, more than at any other point, more is being asked of importers by Customs, which means now is the time to invest more heavily in intellectual capital and lean on experts more than ever before. 

A good trade advisor can bring back the feeling of simplicity in a new form. Having someone who knows what CBP and the PGAs are focused on, while also knowing your goods, supply chain, goals, and business down to the bones, is not just worth the money at this point - it’s nearing necessity. 

Brokers and Trade Advisors can help with your import goods, but it is just one part of the puzzle now, and a more comprehensive trade advisory strategy is rapidly becoming the ‘simple’ baseline. The sooner you connect with a trade advisor you can count on, the sooner your imports will start to feel simple again.

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Of course, if you’re looking for help, PCB is here. Our Trade Advisory team is staffed with tenured experts who are standing by to make sure that your goods have everything they need to cross quickly and efficiently. 

You are encouraged to look through our Trade Advisory page for the service that best meets your needs, and when you are ready, get in touch. We’ll be here to help make sure your next import is as simple and easy as possible.