最低限度数量放缓；立法议程表明豁免将消失

Barclays_De_Minimis_Industry_Model_060425.xlsxBarclays De Minimis IndustryModelRestricted - External China TechnologyPOSITIVEU.S. InternetPOSITIVEU.S. InternetTrevor Young, CFA+1 212 526 3098trevor.young@barclays.comBCI, USRoss Sandler+1 415 263 4470ross.sandler@barclays.comBCI, USChina TechnologyJiong Shao, CFA+1 212 526 5562jiong.shao@barclays.comBCI, USLian Xiu (Roger) Duan+1 212 526 4633lianxiu.duan@barclays.comBCI, US Beyond the data, there is now renewed uncertainty on whether low-value (<$800 at retail value)orders from China are eligible for de minimis treatment. At present, duties are still in place forshipments from China/Hong Kong to the US that would have previously qualified for de minimisexemption. That said, we suspect that uncertainty will continue for some time, but given thenumerous bills at various stages of the legislative process that may eliminate de minimis, wethink there is high likelihood the exemption goes away for China, and eventually all countries,although the exact timing of that is uncertain. When examining the current policy, we seepotential duties of 54-200% on a base $50 order based on using international post, irrespectiveof what the base import duties are (or whether those are temporarily suspended). While thesetoo could be suspended or eliminated, we think this speaks to such uncertainty that manymerchants and consumers may opt to avoid low-value, cross-border purchases from China fora while, which does seem to be manifesting in our own Barclays credit card data (link).De Minimis Policy in Limbo. We Still Think De Minimis Exemption Ultimately Goes Away.The US Court for International Trade (CIT) recently vacated President Trump's actions/EO's ontariffs,and the opinion also appears to vacate the elimination of the de minimis exemption (i.e.,de minimis shipments from China and Hong Kong would once again be allowed), according toour Public Policy analyst Michael McLean (link). However, this decision was stayed following anappeal from the Administration, and it is our understanding that the current duty-regimeand de minimis elimination for China/HK remains ineffect.While there's a lot of uncertaintyaround the appeal timeline on that CIT ruling, we believe the Administration could make acompelling case on why de minimis shipments should not be duty free and subject toreasonable inspection, with some form oftariffsor fees to cover that inspection. Recall thatprior to May 2nd, more than 4m packages per day came into the US under de minimis, androughly two-thirds of them were from China/Hong Kong. Given the aforementionedsusceptibility to declarations fraud and limited inspection, we think the Administration couldargue these posesufficientrisks and provide a basis for eliminating the de minimis exemption.That said, we think the debate on the mechanism for eliminating de minimis (i.e., via ExecutiveOrder vs. a bill through Congress) is less clear. On that point, even if the executive action route isunsuccessful, recent policy action from the legislative branch supports our view: The "One BigBeautiful Bill Act" that passed the House would permanently end de minimis for commercialshipments from all countries by July 1, 2027, for example, and there have been other examplesofdraftlegislation (Figure 1) that would eliminate de minimis exemption, which we believe mayhave bipartisan support. Saiddifferently,we think de minimis exempt imports are likely to goaway for all countries at some point, but the timing remains highly uncertain.FIGURE 1. The One Big Beautiful Bill Act would end de minimis altogether July 1, 2027, and hasadvanced the farthest out of all the bipartisaneffortsTimeline of legislative and executive branch actions regarding de minimis from 2024-PresentSource: Barclays Research, Congress, Federal Register2 FIGURE 2. Our illustrative scenarios on low-value apparel order from China that no longer qualify for de minimis highlight much higherpotential costs – and also greater uncertainty on that cost – under current policy*MFN duties depend on category, **Section 301 duties depend on category, ***Postal duties have two options for the transport carrier involved in the international postalnetwork, and must apply the same method to all shipmentsEven with ChinaTariffsReduced Temporarily, International Postal Duties Are in Place,Unclear and Burdensome.Based on our current understanding of what policies are on holdand still in place, we believe that low-value orders from China/Hong Kong are still subject tosome duties when using the international postal system (e.g., including US Postal Service) forshipping goods to the US. There are currently two methods of duty calculation – a 54% AdValorem duty or a $100 Specific Duty fee. The determination of which fee to charge seems to beat the discretion of the transport carrier involved (and it is unclear when there are multiplecarriers – although we would assume the burden would fall on the US Postal Service as that isthe organization