Import Compliance Consulting After Section 321: What Your 3PL Should Handle

By ODW Logistics

Import compliance consulting from a 3PL covers the work that surrounds a customs entry: clean shipment data, landed cost visibility, handoffs to a licensed customs broker, and a regular review as the rules change. It does not replace the broker or the importer of record. With Section 321 suspended, importers that once relied on the $800 exemption need that support more than they did a year ago, and ODW’s guide to Section 321 explains the background.

What Changed for Importers After Section 321?

CBP has suspended the de minimis exemption indefinitely for every mode except the international postal network, so shipments valued at $800 or less no longer clear duty-free under Section 321. The global suspension began August 29, 2025, and an interim final rule published June 24, 2026, wrote it into regulation. Those shipments now move through informal entry, filed as Entry Type 11, for goods valued at $2,500 or less, or through formal entry above that. Duty is owed on both, and Entry Type 86 and release from manifest are no longer available.

For a DTC brand shipping thousands of small orders a month, each shipment now needs an accurate description, country of origin, and declared value before it crosses the border. ODW covered the first wave in an earlier article on the suspension.

What Is Import Compliance Consulting From a 3PL?

Import compliance consulting from a 3PL is advisory and operational support that keeps the data, cost, and network decisions around a customs entry in order. It differs from the customs compliance consulting a broker or trade attorney offers, which tends to focus on classification, valuation, and legal positions. Importers comparing customs compliance services usually need both: a licensed customs broker for the entry itself, and a 3PL that sits on the physical and data flow.

What Should Your 3PL’s Trade Compliance Team Handle?

Five things, and the entry filing is not one of them unless the 3PL also holds a customs broker license.

Data accuracy comes first. A 3PL should capture and maintain the product description, country of origin, quantity, and declared value a broker needs for each shipment, and flag mismatches before goods move. Errors here tend to surface later as holds, corrections, or penalty exposure.

Landed cost visibility comes second. Duty now applies to shipments that used to clear free, so the true cost of an order depends on what is in the box and where it came from. A 3PL should report landed cost by shipment type, so pricing and margin decisions rest on real numbers.

Network and consolidation design comes third. Where inventory sits and how freight is grouped change how many entries a shipper files and what each one costs. A 3PL should model the options, such as consolidating shipments or moving more inventory into domestic distribution, and say plainly what each costs in time and money.

Broker coordination comes fourth. The 3PL should know who the shipper’s licensed customs broker is, pass shipment data over in the format that broker needs, and manage the physical side when a shipment is held or examined. Each handoff deserves a named owner.

A recurring review comes fifth. The rules changed several times between early 2025 and late 2026, so a one-time assessment goes stale quickly. Ask for a scheduled review of import exposure instead of a project that closes once.

What Should Stay With the Importer and the Broker?

Tariff classification, valuation positions, and the entry filing belong to the importer of record and its licensed customs broker, and a 3PL should say so clearly. A 3PL can supply data, flag inconsistencies, and model cost. It should not offer legal opinions on classification, act as importer of record without saying so, or promise a compliance outcome, because the importer of record is generally accountable to CBP for what is declared. Roles typically divide as shown below, though contracts vary.

How Could the October 2026 Proposal Affect Your 3PL Relationship?

CBP published a proposed rule on October 8, 2026 (91 FR 64532) that would require Entry Type 11 to be filed electronically on or before the date of importation, require a bond for every Entry Type 11 filer, and require a consignee that is neither the owner nor the purchaser to appoint a licensed customs broker as importer of record. It is not final, and comments are due December 7, 2026. If it is adopted, shipment data would need to be ready before goods arrive, which raises the value of a 3PL that keeps product and shipment records clean.

How Does ODW Support Import Compliance Services?

Customs entries are filed by the importer or its licensed customs broker, and ODW supports the freight, warehouse, and technology plan around them. ODW’s supply chain innovation team designs supply chains from data analysis and provides automation plus WMS and TMS technology configured to agreed KPIs. Freight brokerage covers LTL, truckload, intermodal, temperature-controlled, expedited, flatbed, transloading, and drayage across North America. Warehousing runs through a nationwide network of distribution centers, and ODW’s warehouse and transportation technology adds API and EDI integrations and a 24/7 client portal for warehouse and shipping visibility. Brands that ship direct to consumers can add e-commerce fulfillment with Shopify integration, Fulfilled by Amazon services, and a parcel program.

Frequently Asked Questions

What is customs compliance consulting?

Customs compliance consulting is advisory help that keeps an importer’s entries accurate and defensible, covering classification, valuation, country of origin, and recordkeeping. A 3PL’s version centers on shipment data, landed cost, network design, and coordination with the importer’s licensed customs broker. Ask any provider which parts it performs itself and which it passes to a licensed partner.

Is Section 321 customs entry still available?

For most shipments, no. CBP has suspended the de minimis exemption indefinitely for every mode except the international postal network, so shipments valued at $800 or less now need informal or formal entry. Postal shipments follow a separate process. Confirm the current rules with a licensed customs broker before you plan around any exception.

Does a 3PL need to be a customs broker to offer import compliance services?

No. Filing entries for others generally requires a licensed customs broker, but a 3PL can still handle data accuracy, landed cost reporting, network design, and handoffs to the broker. Ask any 3PL which of these it covers and which it passes to a licensed partner, and get the split in writing.

Who is responsible for import compliance, the shipper or the 3PL?

The importer of record is generally accountable to CBP for the accuracy of its entries, whether or not a broker files them. A 3PL’s role is to supply and protect clean shipment data and flag problems early, so the importer and the broker have what they need.

What should I ask a 3PL about customs compliance before signing?

Ask who owns data accuracy, how landed cost is reported, how the 3PL coordinates with your customs broker, and how often import exposure is reviewed. Also ask what the provider will not do, such as classification opinions or acting as importer of record.

Choosing Import Compliance Consulting Support From Your 3PL

Import compliance consulting from a 3PL works best when roles are clear: the importer owns accuracy, the licensed customs broker files, and the 3PL keeps data, cost, and network decisions in order. With Section 321 suspended and its statutory end set for July 1, 2027, settle that division of work now, before the first unexpected duty bill. Contact ODW Logistics to talk through how your import volume and product categories are affected, or request a quote to see what a 3PL partnership could look like.