Statutory Compliance Statement · Version 1.1

Built for Global Customs Rails — Not a Party to Them.

A transparent technical breakdown of EU Regulation 2026/382, US Section 321 reform, the Pre-Flight HS Sanity engine, and why ParcelDuty operates strictly as headless calculation middleware without pass-through liability.

Rail 01 · European Union

1. EU H7 Statutory Grouping (Regulation 2026/382)

Under Council Regulation (EU) 2026/382 and Commission Delegated Regulation (EU) 2026/1022, the European Union has eliminated the €150 customs-duty-free exemption for low-value imports, establishing a flat statutory customs duty of €3.00 per declared 6-digit HS subheading line on cross-border e-commerce consignments.

Under the regulation's statutory grouping mechanic, when a multi-item package contains multiple SKUs that share the same 6-digit HS tariff classification, they must be legally grouped into a single declaration line. Doing so assesses the €3.00 duty once per tariff subheading rather than once per physical item. ParcelDuty executes this mathematical grouping optimization deterministically in milliseconds, collapsing line counts while verifying €150 intrinsic value ceilings.

Rail 02 · United States

2. US Section 321 Reform & ACE Routing (19 U.S.C. § 1321)

Under DHS/CBP rulemaking (90 FR 6852 / Docket USCBP-2025-0003) and 19 U.S.C. § 1321, U.S. Customs and Border Protection strictly enforces de minimis exclusions. Low-value parcels containing goods covered by Section 301 (China tariffs), Section 232 (steel/aluminum), or Section 201 trade remedies are disqualified from $800 duty-free treatment and must not be filed under Entry Type 86.

ParcelDuty evaluates 10-digit HTSUS classifications against active Section 301/232 schedules, determines whether the cargo qualifies for Entry Type 86 (Duty-Free De Minimis) or requires routing to Entry Type 11 (Informal Entry with ad-valorem duty, punitive tariffs, and merchandise processing fees), generating compliant CATAIR EDI manifest records.

Verification Engine

3. Pre-Flight HS Sanity & Plausibility Scoring

Carrier manifest rejections and customs red-lane holds frequently arise from vague descriptions ("accessories", "samples") or hallucinated HS codes from generative AI tools. ParcelDuty includes a deterministic Pre-Flight HS Sanity Scorer:

Syntax Validation

Validates 6-digit WCO and 10-digit HTSUS formatting, check digits, and tariff existence before payload transmission.

Vagueness Detection

Identifies generic descriptions that fail CBP 19 CFR § 141.86 and EU UCC Annex B specificity thresholds.

Semantic Plausibility

Scores cross-alignment between commercial invoice descriptions and designated chapter headings (0–100 score).

4. Why IOSS Does Not Settle Customs Duties

The EU Import One-Stop Shop (IOSS) is strictly an import VAT reporting mechanism, not a customs duty collection system. This distinction is statutory:

IOSS Portal

Import VAT Only

A monthly turnover return filed with national tax bodies (e.g. BZSt, DGFIP). Collects standard destination VAT. Tax authorities running IOSS possess zero jurisdiction to assess or collect per-consignment customs tariffs.

Electronic H7 Manifest

Customs Tariff Rail

Assessed by national customs directorates (Zoll, Douanes) at the physical port of entry under the Union Customs Code. Settled on the electronic H7 declaration against the declarant's deferment account.

5. The Four Structural Firebreaks

Pillar 1 — No Agency, No Customs Brokerage

ParcelDuty explicitly disclaims customs agency, legal representation, and fiduciary duties under UCC Articles 77/84 and US 19 U.S.C. § 1484. The declarant or Importer of Record designated on the electronic manifest remains solely and exclusively responsible for the accuracy of tariff codes, values, and origin records.

Pillar 2 — Zero Custody of Funds

ParcelDuty never touches, holds, escrows, or remits customs duties or VAT funds. Financial settlement occurs directly between customs directorates and the declarant's deferment account or bond. Our fees are 100% decoupled from duty capital.

Pillar 3 — Deterministic Cryptographic Audit Receipts

Every calculation and manifest emission generates a SHA-256 statutory_hash that binds the raw commercial invoice items cryptographically to the collapsed manifest lines, providing an immutable audit defense trail for customs inquiries.

Pillar 4 — Pure Calculation Middleware (Zero Pass-Through Liability)

Customers warrant the accuracy of invoice data submitted to the API. ParcelDuty executes deterministic tariff algorithms as software middleware; sovereign customs authorities determine admissibility, and ParcelDuty assumes no liability for customs fines, seizures, or back-billing.

Not Legal or Customs Advice

This statement provides technical and operational context for engineers and logistics architects; it does not constitute legal, tax, or customs advice. Classification, valuation, and declaration responsibilities reside exclusively with the declarant. For the complete contractual allocation of obligations, review the Terms of Service.