1.The Fundamental Reasons Behind the T86 Customs Clearance Incident

Recently, the T86 customs clearance incident in the United States has drawn widespread attention within the industry. Due to stringent inspections by U.S. Customs on T86 clearances, numerous customs brokers have had their T86 clearance operations suspended for the next three months, necessitating rectification and adjustments.

Against this backdrop, major U.S. ports are now backlogged with thousands of tons of cross-border e-commerce packages awaiting clearance, prompting many airlines to temporarily cancel cross-border e-commerce flights or charters to the U.S., adopting a wait-and-see approach.

As some customs brokers have had their operations suspended, the number of brokers capable of effectively handling T86 clearances is dwindling. Those still engaged in T86 clearances are becoming increasingly cautious, imposing various levels of cargo volume restrictions and intensifying scrutiny of customs documentation to ensure their clearance licenses remain unaffected.

Given recent trends, it appears that the strict scrutiny of T86 customs clearance by U.S. Customs may continue for the foreseeable future. The primary reasons for this are as follows:

1. High Regulatory Pressure on U.S. Customs

Over the past two years, the rise of fully-managed cross-border e-commerce has led to a significant increase in cross-border e-commerce packages being shipped to the United States. Some e-commerce platforms have reported daily package volumes reaching the millions. It is estimated that at least 5 million cross-border e-commerce packages are sent to the U.S. market daily via air transport, with daily cargo weights amounting to several thousand tons.

Currently, cross-border e-commerce packages are primarily handled through major U.S. ports such as Los Angeles, New York, Miami, and Chicago for air injection and clearance services. Due to the "de minimis rule" or "small-value exemption policy" in the U.S., goods valued at less than $800 (per person per day) can enter the U.S. tax-free, whether for businesses or consumers. This policy results in a substantial volume of cross-border e-commerce packages entering the U.S. tax-free under the $800 threshold. The sheer volume of these packages has led to a significant increase in the number of T86 clearances required at these ports daily, placing enormous regulatory pressure on customs officials. Consequently, the U.S. government is re-evaluating this business model.

2. Insufficient Professional Capabilities of Logistics Companies

With the increase in cross-border e-commerce packages, many logistics companies have seen business opportunities in T86 clearances in the U.S. Over the past 2-3 years, numerous companies have invested in T86 clearance facilities near major U.S. airport ports, applied for T86 clearance licenses, and even established local offices.

However, despite the growing number of companies entering this space, several issues persist. For example, companies often struggle with ensuring the compliance of customs documentation, the professional knowledge and operational capabilities of their personnel, and their understanding of the cross-border e-commerce business model. These areas highlight the need for significant improvements and capacity-building.

3. Excessive Cost-Cutting by E-Commerce Platforms

Many e-commerce platforms excessively emphasize cost and efficiency, seeking to minimize logistics costs by segmenting procurement and severely squeezing the profit margins of logistics service providers. As a result, many logistics providers, in an effort to avoid financial losses, have resorted to internal cost-cutting measures. For instance, inadequate investment in personnel and information systems has led to deficiencies in the compliance and completeness of customs documentation for many packages.

If platform-based companies excessively squeeze the normal profit margins of logistics companies, it will lead to incidents like the current T86 customs clearance issue in the U.S., which will negatively impact the e-commerce platforms as well. For cross-border e-commerce to develop healthily, platform companies and key industry players must allow logistics service providers to retain reasonable profit margins. This enables these companies to continuously improve and perfect their services, invest in information systems and human resources, and ensure long-term compliance and standardization. Only by fostering a healthy and mutually beneficial industrial chain can the business model sustain itself.

 4. Lack of a Standardized Global Framework

Many overseas regulatory bodies still need to improve their digital governance levels and enhance their abilities to use big data and information-based regulatory measures. Consequently, European and American countries face significant challenges in effectively regulating and taxing the massive influx of cross-border e-commerce packages.

In this regard, China is relatively advanced. There is significant potential for positive and proactive information sharing and communication between Chinese regulatory policies and foreign law enforcement or regulatory agencies.

The absence of a globally recognized and reasonable standardized framework means that each country has a different understanding of cross-border e-commerce. Variations in customs clearance, regulation, taxation, and ensuring the security of goods and information create numerous challenges. These differences can lead to trade or regulatory barriers as cross-border e-commerce volumes increase, potentially resulting in unforeseen issues. Therefore, the cross-border e-commerce industry needs a mechanism to coordinate communication and cooperation across the industrial chain, involving all stakeholders.

Regulating the cross-border e-commerce industry is a challenge faced by governments worldwide, including China. Since data such as payments, logistics, commerce, product value, and more are controlled by e-commerce platforms, these platforms are the key players and data sources within the cross-border e-commerce ecosystem. Effective regulation should start with the cooperation of these key companies in sharing data with upstream and downstream industry participants and regulators. This approach will achieve transparency and efficient regulation across the entire cross-border e-commerce chain, improving cargo flow, customs clearance efficiency, and order fulfillment, while addressing regulatory gaps and monitoring data.

Furthermore, Chinese e-commerce platforms aiming to become world-class must benchmark their practices against global standards, fostering industry self-discipline and regulation. This includes involving industry, government, businesses, consumers, manufacturers, and service providers. This foundation is essential for a sustainable business model.

Therefore, the T86 customs clearance incident in the U.S., where customs brokers were suspended due to non-compliance, improper declaration methods, and missing documentation, is just a symptom. The underlying issues, as outlined above, are the real causes. If these issues are not effectively addressed in the near future, similar customs and tax inspection incidents involving Chinese cross-border e-commerce packages in overseas markets will likely continue to occur, using the U.S. T86 clearance incident as a catalyst.

2.The Impact of the U.S. T86 Customs Clearance Incident on Different Enterprises

The immediate and most direct impact is the increase in costs.

Currently, the remaining qualified customs brokers are bound to place greater emphasis on compliance and standardization. As everyone focuses on compliance and standardization, the cost of customs clearance for U.S. cross-border e-commerce packages will rise. Many customs brokers have already begun to raise their prices.

Secondly, due to the stringent inspections by U.S. Customs at several major ports, many logistics companies will divert their cargo to more ports to avoid congestion at the primary ones.

As cargo is distributed to more ports, the demand for T86 clearances at these other ports will increase, requiring corresponding air transport resources to match. This diversion will also impact the route planning of airlines and charter companies.

In summary, this series of adjustments, including changes in the industry service chain, reorganization of resource elements, and reconstruction of the cost model, will inevitably lead to price increases for cross-border e-commerce parcels on U.S. routes.

Price increases are reasonable under these circumstances; not raising prices would be unreasonable. Therefore, cost reduction and efficiency improvements in cross-border e-commerce logistics must be based on legality and compliance. In the foreseeable future, the industry must consider how to achieve sustainable development within the boundaries of safety, compliance, and effective risk control.

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