How to Send Paintings to the USA Now: New Customs Rules 2026
Art DomJuly 28, 2026
Donald Trump introduced customs tariffs that turned the logic of shipping paintings to the US upside down. Since August 29, 2025, a package of any value is subject to mandatory declaration, and the recipient pays duty upon delivery. Previously, gifts, personal items, and commercial shipments valued up to $800 crossed the border duty-free; now that threshold has been eliminated, and only a simplified regime with a fixed fee remains for mail up to $100.
For an artist from Ukraine, this isn't an abstract Bloomberg headline — it's a direct hit to the cost of doing business. A client from Brooklyn who ordered a $250 watercolor now gets a DHL receipt with duty and a broker fee, and calls with questions. Let's break down what actually changed, who pays for what, and how to arrange a shipment so it doesn't get stuck in New York for three weeks.
- Executive Order 14324 eliminated the $800 duty-free threshold; the rule has been in effect since August 29, 2025.
- The baseline 10% IEEPA surcharge for Ukraine was in effect from April 5, 2025 to February 24, 2026; after the US Supreme Court ruling it was struck down — check the current rate with your broker.
- The $100 figure mentioned refers to the simplified postal shipment regime: below this amount the declaration is simpler, above it full customs processing applies.
- The default duty payer is the recipient (DDU terms). If you want to pay it yourself, choose DDP at shipping.
- Handmade work does not grant an automatic exemption. The HS code 9701 "original paintings" exemption was eliminated along with the other exceptions.
What Trump actually introduced and when it took effect
A brief timeline. On April 2, 2025, the US president signed Executive Order 14257, the reciprocal tariffs order the White House called "Liberation Day." Starting April 5, a universal baseline rate of 10% took effect on imports from all countries. From April 9, elevated "mirror" rates kicked in for dozens of economies: 20% for the EU, 54% for China, 46% for Vietnam, 36% for Thailand. Ukraine remained in the baseline 10% category.
On July 30, 2025, Executive Order 14324 followed, ending the de minimis exemption. Until that day, shipments to the US valued up to $800 entered duty-free and with simplified processing; after August 29, 2025, the exemption stopped applying to any country without exception. On September 5 of the same year, EO 14346 established an updated Annex II and outlined procedures for framework agreements — for example, with EU countries that agreed to move toward zero rates on a range of goods in exchange for reciprocal commitments.
By summer 2026 the framework had been rebuilt several times. On February 20, 2026, the US Supreme Court ruled 6-3 that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) exceeded presidential authority; CBP stopped collecting IEEPA duties on February 24. The administration immediately reissued the baseline 10% under Section 122 of the Trade Act of 1974 for 150 days, then on July 24, 2026 launched a new wave under Section 301: rates of 10–12.5% for more than 80 economies, including Canada, Mexico, EU countries, the UK, India, and China. Ukraine does not appear directly in the new wave's lists, so the actual rate on the shipping date is worth checking with your courier's broker.
So what's the deal with the $100 threshold on packages
There's some confusion here that US Customs and Border Protection (CBP) itself only cleared up in guidance issued in August 2025. Formally, the $800 de minimis threshold was eliminated entirely. There is no "shift to $100" anywhere in the text of EO 14324. However, the Postal Service introduced a transitional regime specifically for postal shipments: packages up to $100 go through a simplified postal channel with a flat fee, while anything above that goes through formal customs processing with duty calculated on value.
For an artist, here's what this means in practice. If a painting is declared at $90 and shipped by regular mail, the recipient pays a flat fee. The amount depends on the sender country's reciprocal rate and typically falls in the $80–200 range per route. If the painting is worth $500, the full procedure kicks in: 10% baseline duty plus the regular customs duty under the HS code. Under-declaring the value is a false economy — insurance reimbursement in case of loss is calculated based on the declared value, not the actual one.
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$800
Former duty-free threshold, in effect until August 29, 2025
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$100
Threshold of the simplified postal regime after the exemption ended
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10%
IEEPA rate for Ukraine (in effect until February 24, 2026)
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How to arrange a shipment of a painting or a print run now
Forget about marking packages "personal gift, no commercial value." CBP stopped trusting such formal labels long ago, and after August 29, 2025, gift status doesn't grant an exemption in principle anyway. Any shipment to the US is now built on three documents: a correctly filled-out CN22 declaration (for packages up to 300 SDR, about $400) or CN23 (for higher-value items), a commercial invoice with the recipient's details, and the item's HS code.
1 |
Determine the HS code. For original works painted in oil, tempera, or gouache, use 9701.21 or 9701.22. For prints made from an original plate, use 9702. For fine art photography, the code depends on the technique — usually 4911.91 (reproductions) or 9701 for a signed, unique work; your broker confirms the exact classification. |
2 |
Assess the real value. The invoice should reflect what the collector actually paid, not a "symbolic" $20. An under-declared price turns into a risk of the package being held, fined, and requiring documents to be resubmitted. |
3 |
Choose the delivery terms. DDU (Delivered Duties Unpaid): the recipient pays on arrival. DDP (Delivered Duties Paid): you include customs costs in the invoice and settle through the courier while still in Ukraine. For galleries and repeat clients, the latter is the more courteous option. |
4 |
Think through your labeling. For fragile pieces, mark "Fragile, artwork" in writing, in both Ukrainian and English. For stretched canvases, use a rigid box with double-wall corrugated cardboard; for rolled works, use tubes with an inner diameter 3–4 cm larger than the roll's diameter. |
5 |
Send the recipient the document package in advance: scans of the CN22 or CN23, the invoice, and the certificate of authenticity. If the shipment is held for inspection, your client will have everything ready to answer the broker in a single exchange rather than a week of back-and-forth. |
Who pays what, and how it works out in practice
Let's break it down with concrete numbers. An oil painting worth $400, shipped from Kyiv via EMS. HS code 9701.21, weight 1.8 kg with packaging. Before August 29, 2025, the recipient paid $0 in duty. From August 29, 2025 to February 24, 2026, while the IEEPA surcharge applied, the 10% baseline rate added about $40 in duty plus the courier's broker fee (typically $15–25 with DHL and FedEx). After the Supreme Court ruling struck down the IEEPA tariffs, for original paintings under HTS 9701 the baseline MFN rate is zero, so the current duty depends on whether the sender's country falls under the new Section 301 wave. Check on the shipping date.
Another example: a run of 20 hand-printed prints, $60 each, for a total package value of $1,200. HS code 9702, baseline MFN HTS rate: 0%. While the 10% IEEPA surcharge applied, the recipient would have paid around $120; after February 24, 2026, that surcharge was struck down. When it's not a single delivery to a gallery but a consolidated lot for a marketplace, a courier broker fee of roughly 3% of the shipment's value is added on top of the duty.
| Shipment type | Painting/print value | Duty payable by recipient | Default payer |
|---|---|---|---|
| Postal shipment (USPS) | up to $100 | flat fee $80–200 per route | recipient |
| Postal shipment (USPS) | $100–800 | 10% of value | recipient |
| Courier: DHL, FedEx, UPS | any | 10% + broker fee $15–25 | DDU: recipient / DDP: sender |
| Gallery shipment via customs broker | from $2,000 | 10% + broker fee per contract | sender or gallery per contract |
The 10% rate in the table reflects the IEEPA surcharge under EO 14257 before it was struck down by the US Supreme Court on February 20, 2026. After that date, and until the new legal framework under Sections 122 and 301 fully takes shape, verify the current duty with the CBP calculator or your courier's broker.
What an artist should do: five scenarios
The most common mistake is padding the price to "hide" the duty. The American market reacts worse to that — clients see a double price on the website versus the DHL receipt, and trust drops. The opposite approach works: transparency, with customs costs folded into the total under DDP. It goes over more smoothly, and reputation stays intact.
✅ Strategies that work
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❌ What not to do
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What's left out of the picture
EO 14346 included an important carve-out. Products that cannot be produced or sourced within the US in sufficient volume, along with certain categories of agricultural goods, aircraft components, and generic pharmaceutical ingredients, may receive a zero reciprocal rate under the terms of final agreements. Original art, meanwhile, retained its zero MFN rate under HTS 9701 and 9702: the baseline duty for paintings, original prints, and unique sculpture hasn't changed. Additionally, the 10% IEEPA surcharge was struck down along with the other IEEPA tariffs following the US Supreme Court's ruling on February 20, 2026. In practice, this means that for originals, what matters now isn't so much the rate as the declaration and processing procedure itself — which hasn't gone away even after the end of de minimis.
A separate note on sanctions and parallel restrictions. Artists working with materials from sanctioned sources (for example, birch plywood or pigments from Russia) risk additional scrutiny. This has nothing to do with the artwork itself, but explaining a material's origin on the broker's twelfth question is an unpleasant experience. Note the composition of your canvas and ground layer in the item's passport as a separate line item.
Bottom line
Donald Trump introduced customs tariffs that turned a shipment to the US from a simple postal transaction into a small export project. The $800 threshold is history, mirror tariffs are the new normal, and the CN22 declaration has become a mandatory skill for any artist selling work to the States. The bad news: client costs have gone up. The good news: the rules are now the same for everyone, and transparent processing no longer loses out to the gray-market approach.