**Update** On February 5, 2025 President Trump issued an Executive Order reinstating de minimis imports from China.
We all know that the vast majority of seafood sold in US restaurants and supermarkets is imported, and many of us trade nerds can even recite a few of our favorite statistics on import volumes and species. But here's what might surprise you—those numbers we've been quoting? They are based on just 8% of all US imports. The other 92%—a staggering one billion packages per year—slip silently through a massive reporting and duty-free loophole known as "de minimis" for all small imports. Until now.
Believe it or not, you have first-hand experience with de minimis imports. Every time you go through customs and are asked if you have items to declare and say no (perhaps awkwardly avoiding eye contact with the agent, no judgment here), you are saying that the value of items you purchased overseas and are now importing is too small to be worth the US government's time to collect tariffs on.
This juice-isn't-worth-the-squeeze practice of waiving small imports through customs was formalized in 1938 when US stopped collecting tariffs on imports valued at under $1.00 USD. The de minimis threshold increased slightly over the next 70+ years until a change in strategy suddenly shifted everything. In a bid to boost trade (vs, maximize tariff revenue collection), in 2015 Congress raised the de minimis threshold to $800, dwarfing the $100-$200 limits common in other countries. The result? Small imports surged 500% over the next decade, with China's e-commerce manufacturers seeing the most growth.
But success breeds scrutiny. US Customs and Border Protection, concerned members of Congress, and others, have been vocal about systematic abuse of the de minimis policy. President Trump crystallized these concerns in his America First Trade Policy Executive Order directing Federal agencies to:
"...assess the loss of tariff revenues and the risks from importing counterfeit products and contraband drugs, e.g., fentanyl, that each result from the current implementation of the $800 or less, duty-free de minimis exemption..."
As a result, starting today small imports from China can no longer claim de minimis status (though your vacation souvenirs are still safe). It's the biggest shake up in de minimis rules since 2015, and notably it singles out just one country. While headlines focus on tariff increases and impacts on direct-to-consumer retail like fast fashion, the truth is that nobody knows what the overall impact might be to other commodities, including seafood. It could be substantial. As this transformation of our imports landscape begins, here are a few things to keep in mind:
SIMP covers all imports
Devotees of our blog will recall NOAA teased setting a de minimis value for imports covered by the US Seafood Import Monitoring Program (SIMP) in its recent action plan, but the program currently applies to imports of any size. Since de minimis shipments flew under the radar they have escaped NOAA's audit reach so far, but that blind spot is about to disappear. It is worth keeping in mind that SIMP vessel reporting is also monitored by Customs and Border Protection for compliance with a wide range of regulations and trade bans.
Canada and Mexico could be next
While China is today's focus, eliminating de minimis imports was proposed—then delayed—for Canada and Mexico too. While China is the largest seafood exporter to the US by weight, Canada is the largest by dollar value so this could be significant for seafood as well.
A bipartisan issue
The action we are seeing today began in earnest in 2018 and has been advanced by both Presidents Trump and Biden. The decision to remove de minimis entry filing for exports from China is linked to several bipartisan policy concerns including the low visibility of details on these imports, the ease of evading enforcement, and the potential to use policy change to adjust trade flows and encourage alternative sourcing strategies.
Looking ahead
While conventional wisdom is that seafood imports generally exceed the $800 de minimis threshold, the reality is we don't know what we don't know. The impact could be larger than anyone expects, particularly for specialty items and direct-to-consumer seafood sales. Businesses that rely on de minimis imports may want to start exploring alternative sourcing or prepare for more complex customs procedures and shipment delays. For consumers, the impact will vary depending on where they shop. At a minimum, retailers that already import through formal customs procedures may have to raise prices to address the accompanying 10% tariff increase.
Change can be disruptive, but trade policy has to evolve to keep pace with shifts in economic priorities, regulatory needs, and global supply chain dynamics. Smart money says this is just the beginning, so whether you're an importer, distributor, or retailer, now is the time to review your supply chains and prepare small shipments facing big scrutiny.
If you are ready to set up instant compliance screening, real-time monitoring and modernized data collection, Goldfish can help. Let's chat.
Further reading:
China's De Minimis Boom Goes Bust; Marketplace Pulse; February 4, 2025
GUIDANCE: Additional Duties on Imports from China; US Customs and Border Protection; February 3, 2025.
Imports and the Section 321 (De Minimis) Exemption: Origins, Evolution, and Use; Congressional Research Service; Published January 31, 2025.
