Shipping from China to Amazon FBA: importer, ISF, duties, de minimis

Who is the importer of record

19 CFR 101.1 defines the importer as the person primarily liable for the payment of duties, or an authorized agent, and it may be the consignee or the importer of record. Under 19 U.S.C. 1484(a)(2)(B), entry documents are filed by the owner or purchaser of the goods or, when appropriately designated by the owner, purchaser or consignee, a licensed customs broker; the importer of record must be one of those parties. Under 19 CFR 141.1(b), liability for duties is the importer’s personal debt, and paying a broker does not relieve the importer if the broker does not pay.

Amazon’s own help pages need a seller login and we could not fetch them, so we do not say what Amazon does. Look at the commercial invoice, your bill of lading and the entry: whoever owns or buys the goods when they are imported, or the broker acting for them, files. A supplier who sells to you delivered duty paid may be the one who arranges that; check the sale terms (who pays ).

ISF for ocean freight

Cargo arriving by vessel needs an Importer Security Filing, which the importer or its agent files before loading at the foreign port. See ISF requirements and the ISF checklist .

Duty layers on Chinese goods

The duty on a Chinese-origin product is the base rate for its HTS code plus additional layers. USTR publishes the Section 301 actions on China, in lists with exclusion processes. IEEPA tariffs changed in 2026: CBP’s June 24, 2026 rule records that on February 20, 2026 the Supreme Court held in Learning Resources, Inc. v. Trump that IEEPA does not authorize additional tariffs, and that E.O. 14389 of the same date terminated the additional duties imposed under IEEPA in certain orders. Which layers apply to your product depends on its code and entry date: use the tariff stacking page , and see the IEEPA refund page if you paid IEEPA duty.

De minimis (Section 321) for China

The exemption in 19 U.S.C. 1321(a)(2)(C) for goods valued at $800 or less has been suspended for China since May 2, 2025 (E.O. 14256) and for all countries since August 29, 2025 (E.O. 14324), according to CBP. E.O. 14388 of February 20, 2026 continued the suspension. CBP’s interim final rule effective June 24, 2026 (19 CFR 10.151(b)) suspends it indefinitely for all modes except the international postal network, and CBP says it will be permanently terminated in 2027 under Pub. L. 119-21, section 70531(b). The result: small FBA shipments need a formal or informal entry like any other.

Demurrage and detention can hit FBA freight

46 CFR 541.3 defines demurrage or detention as charges related to the use of marine terminal space or shipping containers. Nothing in that definition depends on what is inside the container or where it goes. If a full container is not collected within free time, or the empty is not returned in time, charges accrue. Use the last free day calculator , see demurrage vs detention , and if an invoice looks wrong, what it must show and the letter tool .

Sources

• 19 CFR 101.1, definition of importer (eCFR)
• 19 CFR 141.1, liability of importer for duties (eCFR)
• 19 U.S.C. 1484, entry of merchandise (GovInfo)
• CBP interim final rule, Indefinite Suspension of the De Minimis Exemption, 91 FR 37789 (2026-06-24)
• USTR: China Section 301 tariff actions
• 46 CFR 541.3, definition of demurrage or detention (eCFR)

Updated: 2026-10-21