I just want to explain how I understand this, and please correct me if I am wrong.

In theory, importers have been required to provide a Certificate of Analysis (COA) since around 2003. This comes from federal TSCA regulations as well as California’s RoHS requirements (bill SB 20).

But in practice, nobody really followed those rules because they could claim the “de minimis” import exemption.

The problem now is that Trump issued Executive Order 14324, “Suspending Duty-Free De Minimis Treatment for All Countries.” This means that shipments valued at $800 or less from any country are no longer eligible for de minimis treatment. So in order to properly calculate taxes you need CoA.

And no one is going to update their systems because TACO.