Importing Samples from China After De Minimis: Duty, Entry, and Paperwork
Why sample shipments from China now owe duty, how couriers clear them under informal entry, and why a no commercial value invoice does not help.
The factory charged you $60 for the sample and $45 for DHL, the box arrived in four days, and then a week later DHL emails an invoice for duty plus a clearance fee. Nothing went wrong. That second bill is simply how sample imports from China work now. The $800 de minimis exemption that used to wave small shipments through duty-free is gone for Chinese goods, and a sample is a commercial import no matter how small the box. This page is general information, not legal advice, and these rules have already changed more than once since 2025, so confirm anything that matters with CBP or a licensed customs broker before you rely on it.
Yes, the $60 Sample Owes Duty
Sampling used to be the one part of importing with no customs math at all. Under the old Section 321 rule, any shipment valued under $800 entered the US duty-free with essentially no paperwork, which described nearly every sample ever shipped. That ended for China and Hong Kong on May 2, 2025, and the suspension was extended to all countries on August 29, 2025. The full story is in our de minimis guide.
What it means in practice is blunt. Every commercial shipment from China is now assessed duty regardless of value, and the rate is the same stack your eventual production order faces, base duty plus Section 301 plus the IEEPA tariff. Where that lands depends on your HTS code and on whatever the tariff stack looks like the month your box ships, anywhere from the high teens to around half the declared value for many consumer electronics. Check the current numbers in the US customs duties guide. On a $60 sample, the duty itself might be $10 to $30. At sample scale the percentage is not the painful part. The fixed fees around it are, and those are covered below.
How a Courier Sample Clears Now
You do not file anything yourself. When the factory ships on DHL, FedEx, or UPS, the courier’s own brokerage files the entry with CBP using the commercial invoice attached to the box, advances the duty on your behalf, delivers the package, and bills you afterward. The invoice you get shows the duty plus an advancement fee, typically 2 to 3 percent of the duty or a flat charge, and sometimes a separate clearance line. The express couriers guide covers these fees in more detail.
Two things follow from that. First, the invoice the factory sticks in the document pouch determines your duty bill and your compliance exposure, which is why the next two sections matter. Second, the bill often arrives days or weeks after the box, so a sample run can look cheap right up until the courier invoices land.
A side note on postal shipping. Factories sometimes offer EMS or other postal services to save a few dollars. Postal shipments from China owe duty now too, collected under rules CBP has revised more than once since 2025, and postal clearance gives you the least visibility when something goes sideways. For samples, a courier is the predictable route.
The $2,500 Line Between Informal and Formal Entry
Shipments valued at $2,500 or less clear under informal entry. The courier files it, no customs bond is required, and you do not need to hire a broker. Nearly every sample shipment falls here, and for a typical one or two unit sample the whole process is invisible until the fee invoice arrives.
Above $2,500 the shipment needs a formal entry, which means CBP Form 7501, a customs bond, and either the courier’s brokerage at formal-entry rates or your own broker, typically $150 to $300 per entry. Sample runs cross that line more often than you would think. Three pre-production units of a $900 e-bike is a formal entry. So is the “sample order” of 50 units a factory ships before a private label run. If your sampling genuinely involves that kind of value, treat it as a small production order and budget the entry costs honestly rather than playing games with the declared value to stay under the line.
Why “No Commercial Value” Does Not Work
Chinese factories habitually mark sample invoices “sample of no commercial value” or declare $1. The phrase changes nothing. CBP requires a true value on everything entering the country, including goods you got for free. If the factory charged you nothing, the declared value is what the goods are actually worth, not zero. The tariff schedule does contain one narrow exception, heading 9811.00.60, which admits samples duty-free if they are worth no more than $1 each or are mutilated beyond sale, torn garments and single shoes being the classic cases. A working Bluetooth speaker qualifies on neither count, so do not plan around that provision without a broker confirming it applies.
The more serious problem is the supplier who offers to write $10 on a $60 sample. That is an offer to make a false declaration in your name. You are the importer, the declared value is your statement to CBP, and penalties for undervaluation land on you, not the factory. A pattern of low-balled small shipments is also exactly the kind of history that gets your later, larger entries pulled for customs exams. Decline the favor.
What the invoice should say is simple. The real price you paid, or a fair value if the sample was free. An honest description, such as “Bluetooth speaker, 2 units, engineering samples.” Country of origin China, the supplier’s details, and your name and address. Adding “sample, not for resale” as a remark is fine and true. It just does not reduce the duty.
Budget Sampling Like It Has a Customs Line
Run the numbers on a normal sample round with three shortlisted suppliers. Factories commonly charge $40 to $80 for a sample, courier shipping runs $40 to $100 per box, and the post-delivery customs invoice often adds another $20 to $50 once duty and courier fees stack. Each sample can land at $120 to $200 all-in, so a three-supplier comparison is a $400 to $600 exercise. Our guide to requesting samples covers how to keep the supplier side of that bill down, including getting sample fees credited against your first order.
One legitimate way to cut the customs overhead is consolidation. An agent or a consolidation warehouse in China can collect samples from several factories and forward them as a single shipment, which means one clearance and one set of fees instead of three.
Whatever you do, do not let a $40 duty bill push you into skipping samples or into invoice games. The de minimis change made sampling more expensive and more paperwork-prone. It did not change the reason you sample, which is that a $150 surprise on a test unit is noise compared to 5,000 defective units clearing customs with your name on the entry.