With De Minimis Suspended, How Do K-Beauty Samples Clear US Customs?

Your Korean ODM is ready to ship round one of samples. A few years ago a box like that usually crossed the border duty-free, with little paperwork. That path is closed. De minimis is the customs exemption that let a shipment valued at $800 or less enter the US duty-free under a simplified release. CBP has now suspended it in its own regulations (CBP interim final rule, June 24, 2026).

This guide covers only development samples and other small parcels from Korea. It explains how they clear by courier and by mail, who files and pays, what the invoice must say, and where FDA fits. For full production shipments, see our guide to importing Korean cosmetics into the US.

Do Samples From Korea Still Enter the US Duty-Free?

No. De minimis has been suspended for most imports since August 29, 2025, under Executive Order 14324. In June 2026, CBP wrote the suspension into its own rules for courier, freight and mail shipments. A box of serum samples now needs a customs entry and pays duty on its declared value, like any other import.

The non-postal rule suspends the exemption in 19 CFR 10.151 for every mode except mail, and a companion rule does the same for the postal network (FR 2026-12670). The statute behind de minimis is repealed from July 1, 2027, so this is not a pause to wait out.

The duty is the part founders underestimate. Korean-origin cosmetics carry a combined 12.5 percent duty, the MFN rate plus the Section 301 tariff (forced-labor action) in effect since July 24, 2026 (Federal Register 2026-15181). Our US tariff guide for Korean cosmetics covers the HTS codes and the cost math.

Two June 2026 Rules Changed the Path for Sample Boxes

The two rules split sample traffic by carrier. A box sent by express courier clears on an ordinary informal entry. A box sent by mail goes through a new postal process with stricter filing rules, and for cosmetics that process tightens again on January 20, 2027.

An informal entry is the simplified customs entry for shipments valued at $2,500 or less (19 CFR 143.21). With de minimis gone, CBP names Entry Type 11 as the main informal option for these shipments. The old release-from-manifest shortcut is no longer available, and the Entry Type 86 test is suspended (FR 2026-12670).

Mail changed more. CBP officers no longer prepare mail entries, and duty is no longer collected at your door. The filer must be the owner or purchaser of the goods, or a licensed customs broker they designate, and must hold a customs bond (FR 2026-12669). From January 20, 2027, mail that carries Section 301 duties or falls under a partner agency such as FDA must use the electronic Entry Type 13 for informal entry. Otherwise it needs a formal entry. CBP moved that date from October 22, 2026 (ST&R Trade Report).

Sources: CBP non-postal rule, CBP postal rule and 19 CFR 143.21.

Who Files the Entry and Pays the Duty on a Sample?

The importer of record files and pays. The importer of record is the party named on the entry as responsible for the duty and for the goods meeting US law. On a sample box, that is usually your brand, unless the ODM ships with duties paid.

Courier airway bills carry a duties-and-taxes field. If it says the receiver pays, the courier clears the box as your broker and invoices you the duty plus its own clearance fee. If the ODM pays, the duty lands on the ODM's courier bill, and it may come back to you in a later quote. Agree on that field in writing before round one ships.

Production orders follow the same logic at a bigger scale. Our guide to EXW, FOB and DDP from Korea explains who acts as importer of record on a full order.

Give the courier what it needs before the box lands. That means your importer number (for most companies, the IRS employer identification number), a contact who answers the same day, and the exact consignee name on the invoice. A box with no reachable importer waits in the courier's hold.

A No-Charge Invoice Still Needs a Customs Value

Marking a box "no commercial value" does not make it duty-free. When goods are not sold, the invoice must still state a value for each item. Without such a value, it states the price the seller would charge in the ordinary course of trade (19 CFR 141.86).

A zero or token value invites a hold while the broker or CBP works out what the goods are worth. Ask the ODM for a commercial invoice that lists each sample by name, formula version, quantity, unit value, country of origin and the HTS code it expects.

One duty-free provision exists for samples. HTSUS 9811.00.60 covers samples valued at not over $1 each, or samples marked, torn or perforated so they are unsuitable for sale. They must be used in the US only to solicit orders for foreign products (C.H. Robinson summary of the provision). Whether a development sample qualifies is a question for your licensed customs broker, and so is any prototype provision for a formula still in development. Ask before you claim it, because the claim changes the paperwork.

Can FDA Hold a Box of Cosmetic Samples?

Yes. Imported cosmetics must meet the same requirements as US products, and they are subject to examination and sampling through CBP at entry. FDA can refuse products that appear adulterated or misbranded (FDA). Not every shipment is examined, but a sample box is not exempt because it is small.

Development samples rarely carry a finished US label, so describe them plainly. Ask the ODM to mark each container with the product name, the formula version and "sample, not for sale," and to describe the goods as cosmetics on the invoice. If a sample is a sunscreen or an acne product, say so, because drug products follow different FDA rules. Our FDA requirements guide for Korean skincare covers FDA import entry review in more depth.

Plan Customs Time Into Every Sample Round

Each sample round is now its own import, with its own entry, its own duty and its own chance of a hold. Build a buffer for customs release into every round, and fix the shipping instructions once so every round clears the same way.

If your project runs three sample rounds, that is three entries before you approve a formula. Put these in writing with the ODM before round one:

• The courier, the account and the duties field on the airway bill
• A commercial invoice per box with item names, formula version, quantity, unit value, origin and the expected HTS code
• Your importer details and a reachable contact on file with the courier
• One consolidated box per round instead of several small ones
• A budget line for duty and clearance fees on every round

Shipping samples straight from a Korean warehouse to US customers follows the same rule, whether they go to influencers or early buyers. Every parcel is an import that needs an entry and pays duty. Our fulfillment comparison for K-beauty brands covers when a US-side stock point makes more sense.

Once the boxes clear, the real work is judging them; see our guide to evaluating Korean ODM samples. For the wider route to US buyers, see the US launch playbook for Korean cosmetics.

Frequently Asked Questions

Do I pay duty on every sample round, or only the first?
Every round. Each box is a separate import, so each one gets its own customs entry and pays duty on its declared value. One consolidated box per round keeps the number of entries, and clearance fees, down.

Can I hand-carry samples back from a trip to Seoul instead?
The traveler exemption covers goods for personal or household use, so samples you carry for your brand should be declared as commercial goods when you land. CBP then decides how they enter, and duty can still apply. Our travelers customs guide covers the personal rules.

If the ODM ships samples duties paid, do I still have a customs role?
Less of one. The ODM side files and pays, but the box still needs an accurate invoice and can still be examined by CBP or FDA. Expect the duty to show up in a later quote or invoice.

When does the mail filing change take effect for cosmetics?
January 20, 2027. From then, mailed cosmetics that carry Section 301 duties or fall under FDA jurisdiction must be filed electronically as Entry Type 13 for informal entry, or go through formal entry. CBP moved the date from October 22, 2026.

By Liz Song, K-beauty sourcing consultant.