Duplicate MPF, HMF, and Broker Fees: 5 Double-Charge Patterns to Catch on Every Entry
Fee duplication is the small-dollar-per-entry leakage pattern that adds up materially at portfolio scale. Five patterns account for most of it: MPF cap misses, MPF collected twice on consolidated entries, HMF on air freight, HMF on FTZ withdrawal against original admission, and broker administrative fees passed through as CBP fees. Here is how to detect each one.
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Open calculatorDuplicate MPF, HMF, and Broker Fees: 5 Double-Charge Patterns to Catch on Every Entry
Fee duplication is the small-dollar-per-entry leakage pattern that adds up materially at portfolio scale. A few hundred dollars per entry on typical patterns, occasionally into the low thousands. Individually small, but on portfolios of thousands of entries the annualized recoverable dollars are substantial.
Five patterns account for most of it. This guide walks through detection and recovery. The leakage engine surfaces every pattern automatically. Confirmed findings route to tasks for PSC or protest filing.
Pattern 1: MPF cap misses
Merchandise Processing Fee under 19 CFR 24.23 is 0.3464 percent of entered value, capped at 634.62 USD per entry for calendar year 2026 (the cap adjusts annually for inflation under the CBP User Fee Advance Notice).
The math: an entry at 183,247 USD entered value hits the cap exactly (0.3464 percent equals 634.62 USD). Any entry above 183,247 USD entered value should pay only the cap, not the percentage.
Automated broker systems cap MPF automatically. Manual entries and consolidated entries with multiple sub-invoices can miss the cap. Common failure modes:
- Broker software configured to compute MPF per invoice on a consolidated entry rather than per entry, producing multiple MPF charges that each hit the cap.
- Manual entry keyed with the percentage rate but not the cap check.
- Corrected entry after PSC where the MPF was recomputed on the amended value without re-verifying the cap.
Detection: MPF amount on 7501 above 634.62 USD (or the applicable year's cap value).
Recovery: PSC before liquidation, protest after liquidation within 180 days.
Recoverable per finding: the delta between the actual MPF charged and the cap. On a 1,000,000 USD entry that missed the cap, the recoverable is 3,464 minus 634.62 = 2,829.38 USD.
Pattern 2: MPF collected twice on consolidated entries
A consolidated entry can carry multiple commercial invoices from the same shipper. MPF is a per-entry fee, not a per-invoice fee. Two invoices should produce one MPF charge, not two.
The failure mode is broker software that treats each invoice as a separate entry summary line for fee calculation purposes. The result: MPF at 0.3464 percent applied twice to the split values, or the cap applied twice to values above the cap threshold.
Detection: MPF charges that exceed the cap in aggregate across a single entry number, or MPF computation that appears as multiple line items on the 7501 rather than a single fee.
Recovery: PSC before liquidation, protest after liquidation within 180 days.
Recoverable per finding: the duplicate MPF amount, up to 634.62 USD per duplicate.
Pattern 3: HMF on air freight
Harbor Maintenance Fee under 19 CFR 24.24 is 0.125 percent of entered value on cargo transported by ocean, no cap. HMF does not apply to air, truck, or rail cargo.
The failure mode is broker software that computes HMF unconditionally when a bill of lading is present in the entry data, without checking the mode of transport. Air cargo with an air waybill mistakenly typed as a bill of lading triggers HMF.
Detection: HMF charge on an entry where the mode-of-transport code (column 20 on the 7501) is anything other than ocean-related (codes 10, 11, 12, or 13 for ocean; codes 40, 41 for air; codes 20, 21 for truck; codes 60, 61 for rail).
Recovery: PSC before liquidation, protest after liquidation within 180 days.
Recoverable per finding: full HMF charge, typically 62.50 USD per 50,000 USD entered value, so a 1,000,000 USD air entry with HMF wrongly applied recovers 1,250 USD.
Pattern 4: HMF on FTZ withdrawal against original admission
Foreign Trade Zone admission under 19 CFR 146 requires HMF on the CBP-supervised admission to the zone. Subsequent withdrawal for consumption should not pay HMF a second time if HMF was already paid on original admission.
The rule under 19 CFR 24.24(e)(4)(iii) is that HMF is a one-time fee tied to the port-related use of the harbor infrastructure. Once paid on admission (or on original ocean import prior to zone admission), it is not owed again on withdrawal.
The failure mode is broker software that computes HMF on the withdrawal entry summary without cross-checking the FTZ admission fee record. This is a recurring pattern for zone operators using automated withdrawal filing.
Detection: HMF charge on an entry with Type 06 (FTZ withdrawal) or Type 08 (FTZ warehouse withdrawal) where the original zone admission also carried HMF.
Recovery: PSC before liquidation, protest after liquidation within 180 days.
Recoverable per finding: full HMF charge on the withdrawal.
Pattern 5: Broker administrative fees passed through as CBP fees
Some broker software configurations aggregate the broker's own administrative fees (single entry bond fee, ISF filing fee, dispatch fee, storage fee) into the CBP fee line on the 7501. The importer sees a single "fees" charge and assumes it is all CBP-owed.
Legitimate CBP fees on a 7501 are limited to: MPF, HMF, cotton fee (19 CFR 24.24(g) for cotton imports), sugar fee (for certain sugar imports), beef and dairy assessments, and a small handful of commodity-specific user fees. Anything else is either a broker administrative charge (not paid to CBP) or a CBP penalty (which shows in a different field).
Detection: fee line amounts on the 7501 that do not match a legitimate CBP fee schedule. The audit engine cross-references every fee amount against the CBP fee table and flags mismatches.
Recovery: this is not a PSC or protest issue with CBP; the recovery is a billing dispute with the broker. The importer requests the broker to issue a corrected invoice separating broker administrative fees from CBP fees, and the broker refunds any overpayment.
Recoverable per finding: variable, depends on broker fee structure. On a portfolio with a consistent pattern, this can be a large annualized number.
The 60-second per-entry fee audit
For a single entry, the fee audit runs approximately:
- 15 seconds: check MPF against cap for entries above 183,247 USD entered value.
- 15 seconds: check HMF applicability against mode-of-transport code.
- 15 seconds: check for duplicate MPF on consolidated entries.
- 15 seconds: check for HMF on FTZ withdrawal against original admission.
At portfolio scale, the audit is fully automated in the leakage engine. For a broker filing 200 entries a week, running the fee audit on every entry catches most of the recoverable dollars in bulk.
The CBP fee schedule for 2026
Legitimate CBP user fees on entries filed in calendar year 2026:
| Fee | Rate | Cap | Applicability |
|---|---|---|---|
| MPF | 0.3464% | 634.62 USD per entry | Formal entries and Type 11 above 2500 USD |
| MPF minimum | 32.71 USD | Formal entries with computed MPF below the minimum | |
| HMF | 0.125% | No cap | Ocean cargo only |
| Cotton fee | Varies | Cotton and cotton products, per 19 CFR 24.24(g) | |
| Sugar fee | Varies | Certain sugar imports | |
| Manual surcharge | 3.33 USD | Manual entries where automated would have worked |
Any fee line on a 7501 that does not match one of these should trigger a "broker administrative fee misclassified as CBP fee" flag.
Recoverable dollars at portfolio scale
For a mid-market importer with 200 entries a month over 12 months (2,400 entries):
- Pattern 1 MPF cap misses affecting 5 percent of high-value entries: 120 entries at average 1,500 USD recoverable each = 180,000 USD.
- Pattern 2 MPF duplicates affecting 2 percent of consolidated entries: 48 entries at average 400 USD each = 19,200 USD.
- Pattern 3 HMF on air freight affecting 1 percent of air entries: 24 entries at average 200 USD each = 4,800 USD.
- Pattern 4 HMF on FTZ withdrawal affecting all withdrawals if pattern is present: highly variable.
- Pattern 5 broker admin fee misclassification: variable, potentially large depending on broker.
Total on a routine audit: 200,000 to 500,000 USD annually. Individually small findings, but the recovery velocity is high because fee corrections liquidate at zero incremental duty impact and CBP acceptance rates on fee-correction PSCs are very high (near 100 percent when documentation is clean).
Run fee audit on your entry portfolio
The leakage engine surfaces every fee pattern in a single scan. Confirmed findings route to tasks for PSC or protest filing. Full audit trail preserved.
Start at landedfees.com/audit.
Related guides
- Broker audit: how to review a CBP 7501 in 60 minutes
- Duty leakage: 6 patterns costing importers 3 to 8 percent of imports
- PSC vs 1520(d) vs 19 CFR 174 protest decision tree
- Remediation workflow: from findings to filed tasks
- Chapter 99 line-item transparency on CBP 7501 blended duty
Citations
- 19 CFR 24.23 MPF: https://www.ecfr.gov/current/title-19/chapter-I/part-24/section-24.23
- 19 CFR 24.24 HMF: https://www.ecfr.gov/current/title-19/chapter-I/part-24/section-24.24
- 19 CFR 141.114 PSC: https://www.ecfr.gov/current/title-19/chapter-I/part-141/subpart-B/section-141.114
- 19 USC 1514 protest: https://www.law.cornell.edu/uscode/text/19/1514
- 19 CFR Part 146 FTZ: https://www.ecfr.gov/current/title-19/chapter-I/part-146
- CBP User Fee schedule: https://www.cbp.gov/trade/entry-summary/cop-user-fee
Frequently asked questions
What is MPF?
Merchandise Processing Fee under 19 CFR 24.23 is 0.3464 percent of entered value, capped at 634.62 USD per entry for 2026 (the cap adjusts annually for inflation). MPF applies to formal entries and to Type 11 informal entries above 2500 USD. Automated broker systems compute MPF automatically but manual and consolidated entries can miss the cap.
What is HMF?
Harbor Maintenance Fee under 19 CFR 24.24 is 0.125 percent of entered value on cargo transported by ocean, no cap. HMF does not apply to air, truck, or rail cargo. HMF applies to CBP-supervised admission to FTZ but not to subsequent withdrawal for consumption if HMF was already paid on original admission.
How large is fee duplication per entry?
A few hundred dollars per entry on typical patterns, occasionally into the low thousands on high-value entries where MPF cap misses land. Individually small, but on portfolios of thousands of entries the annualized recoverable dollars are substantial. The LandedFees leakage engine surfaces every pattern in one scan.
How do I recover duplicate fees?
Post Summary Correction under 19 CFR 141.114 before liquidation and within 314 days of entry. After liquidation, 19 USC 1514 protest within 180 days. Fee corrections liquidate at zero incremental duty impact; the recovery is straightforward once the pattern is documented.
Does the LandedFees engine catch broker administrative fees passed through as CBP fees?
Yes. The engine cross-checks each fee line on the 7501 against the CBP fee schedule and flags any fee amount that does not match a legitimate CBP fee (MPF, HMF, cotton fee, sugar fee, beef fee, dairy fee, etc). Broker administrative fees masquerading as CBP fees are a common pattern in some broker software configurations.
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