In all of my shipments since the Section 301 tariffs went into effect, it would appear that CBP's policy (at least in New York) is to not apply the tariffs on any informal entries, not just de minimis informal entries.
This still seems to be the case. I just received my order for a single S17 Pro via DHL processed through NY and was charged only 2.6% (approx. $67). Shipped from Malaysia. No 25% tariff. I paid DHL the 2.6% while the shipment was in transit.
I have another pre-order for a single S17e through UPS. Let's see how that works out.