Landed Cost Beyond the Duty Rate: MPF, HMF and the Fee Floor on Every US Entry
Look up almost any product in the Harmonized Tariff Schedule and the first number you find - the general duty rate - feels like the whole story. It is not. Two statutory fees attach to nearly every formal US import entry before a single dollar of tariff is assessed, and neither appears anywhere in the HTS rate columns: the merchandise processing fee (MPF), set for fiscal year 2027 at 0.3464% of declared value with a floor of $34.58 and a cap of $670.86 per entry summary line, and the harbor maintenance fee (HMF), a flat 0.125% of declared value on waterborne cargo. Together they put a hard $65.83 fee floor under a $25,000.00 entry even when the duty rate itself is zero.
This page rebuilds the landed-cost arithmetic from primary sources: a line-by-line census of all 23,193 HTS ten-digit lines in our warehouse (vintage 2026-10-19), the CBP fiscal-year fee schedule published in the Federal Register, and the HMF statute. Every table below carries its slice definition and fetch date, so you can audit the arithmetic - or re-run it against your own invoice stack.
Census: where the duty rate column actually lands
The US schedule contains 23,193 ten-digit lines. 8,504 of them (36.7%) carry a general rate of "Free", which lures buyers into budgeting zero. Among the 12,705 lines whose rate parses as a percentage, the median is 6.0%, the floor 0.1% and the ceiling 350%:
| General rate band | HTS lines | Share |
|---|---|---|
| Duty-free lines (general column "Free") | 8,504 | 36.7% |
| Paid, 0.1%-5% ad valorem | 5,248 | 22.6% |
| Paid, >5%-10% | 4,553 | 19.6% |
| Paid, >10%-20% | 2,274 | 9.8% |
| Paid, >20% (up to 350%) | 630 | 2.7% |
Two structural facts follow. First, most paid lines cluster between 0.1% and 10% - which means the fixed per-entry fees are proportionally largest exactly where buyers expect the smallest tariff bill. Second, the share of fully free lines (36.7%) makes "Free" the single most common outcome of an HS lookup, so the fee floor - not the duty - is often the largest government charge on the shipment.
The two fees that never show up in a duty lookup
The MPF funds Customs and Border Protection's processing of formal entries. Congress set it as an ad-valorem percentage with statutory clamps; CBP adjusts the dollar limits each fiscal year. For FY2027 (effective October 1, 2026) the fee is 0.3464% of declared value, per entry summary line, subject to the $34.58 minimum and $670.86 maximum. The HMF is older and narrower: a 0.125% tax on the value of commercial cargo unloaded at US ports, levied under 26 U.S.C. 4461 and administered at 19 CFR 24.27. Air and land arrivals owe HMF never; sea arrivals always do.
| Declared customs value | MPF charged | MPF as % of value | HMF charged |
|---|---|---|---|
| $2,000.00 | $34.58 | 1.73% | $2.50 |
| $9,982.68 | $34.58 | 0.35% | $12.48 |
| $25,000.00 | $86.60 | 0.35% | $31.25 |
| $193,666.28 | $670.86 | 0.35% | $242.08 |
| $500,000.00 | $670.86 | 0.13% | $625.00 |
Read the middle column: below $9,982.68 of declared value the minimum turns the MPF into a regressive surcharge - a $2,000.00 sample shipment pays 1.73% of its value before any duty, while a container importer past $193,666.28 pays a capped 0.3464%. Between the clamps the fee is a clean linear 0.3464%. Any landed-cost spreadsheet that models duty as the only variable rate will misprice the left tail of that curve by more than a full percentage point.
Worked example: three lanes, same $25,000.00 customs value
Take three real HTS lines spanning the spectrum - a paid apparel line, a mid-band footwear line and a fully free electronics line - each imported at a declared customs value of $25,000.00 by sea (so HMF applies; halve the fee total for air freight):
| Lane | Customs value | Duty | MPF | HMF | Government charges | Effective rate |
|---|---|---|---|---|---|---|
| Cotton knit T-shirts, China (MFN) 6109.10.00.04, general 16.5% | $25,000.00 | $4,125.00 | $86.60 | $31.25 | $4,242.85 | 16.97% |
| Wooden-platform footwear, Vietnam (MFN) 6403.99.20, general 8% | $25,000.00 | $2,000.00 | $86.60 | $31.25 | $2,117.85 | 8.47% |
| Data-center modems, Taiwan (Free line) 8517.62.00.10, general Free | $25,000.00 | $0.00 | $86.60 | $31.25 | $117.85 | 0.47% |
The free lane is the tell. Zero duty still produces $117.85 of government charges - a 0.47% effective rate that comes entirely from the fee layer. On thin-margin resale that is the difference between quoting a buyer the HTS rate and quoting the real cost of putting goods on the shelf.
When the rate is not a percentage at all
About the census above: it deliberately counts only lines whose general column parses as a percentage. Hundreds of further lines are priced in dollars-per-unit or compound form, and those need quantity assumptions before any landed cost closes. Two live examples from the current schedule:
- Paper-wrapped cigarettes (2402.20.80.00, "$1.05/kg + 2.3%"): a 400 kg consignment valued at $25,000.00 owes $420.00 specific duty plus $575.00 ad-valorem - $1,112.85 in government charges, 4.45% of value.
- Effervescent wine (2204.21.20.00, "19.8¢/liter"): 12,000 liters valued at $60,000.00 owe $2,376.00 in duty plus $282.84 in fees - a 4.43% effective rate where a naive "no percentage, no cost" reading would book zero.
Our specific-and-compound worked examples walk the unit-of-measure mechanics line by line; the stacked-tariffs guide shows what happens when Chapter 99 add-ons sit on top of the base rate.
Fitting the pieces into a quotable landed cost
A defensible landed-cost sheet separates four layers and prices each from its own authority: (1) the duty leg - MFN general rate minus any preferential program your origin qualifies for, which our FTA eligibility checker screens in seconds; (2) the fixed fee layer - MPF per entry summary line and HMF per waterborne entry, exactly as tabulated above; (3) the remedy layer - antidumping, countervailing and Section 232/301 add-ons, which stack rather than substitute; and (4) everything outside the government's cut - ocean freight, insurance, brokerage and inland haulage - which no tariff schedule publishes. Layers 1-3 are mechanical and auditable; layer 4 is negotiation. Conflating them is why quotes built off duty rate alone lose money on arrival.
The ExportSonar tariff calculator applies the FY2027 fee schedule automatically alongside the duty result, and our MPF and HMF primer covers the small-importer edge cases - including when the $34.58 minimum dominates the whole fee bill. For teams reconciling hundreds of SKUs, the subscription tier exports the full per-line breakdown with the fee legs itemized.
Methodology and caveats
- Slice definition: every one of the 23,193 ten-digit HTS lines; "Free" by literal prefix of the general column; percentages parsed from the first percentage token. Special preferential columns are out of scope for the census (they modify layer 1 only, never the fee layer).
- MPF figures are the CBP FY2027 adjustment (Federal Register 2026-15530, effective October 1, 2026); HMF from 26 U.S.C. 4461(b). Both retrieved 2026-10-16; re-verify before booking entries after the next fiscal-year adjustment.
- HMF applies to commercial cargo unloaded at US ports; entries arriving by air or land generally fall outside it. MPF applies to formally entered merchandise; low-value Section 321 shipments never enter the formal-entry fee system at all.
- Worked examples use hypothetical declared values; actual entry summaries compute fees per line and per entry type. Nothing here is legal advice - confirm with your broker.
How do you calculate landed cost for US imports?
Start from declared customs value, then add the duty leg (MFN or preferential rate for your origin), the merchandise processing fee (0.3464% of value for FY2027, minimum $34.58, maximum $670.86 per entry summary line), the 0.125% harbor maintenance fee on waterborne cargo, and finally non-government costs such as ocean freight, insurance and brokerage. Government charges on a $25,000 sea entry are at least $117.85 even when the duty rate is Free.
What is the merchandise processing fee for FY2027?
CBP's FY2027 adjustment (Federal Register 2026-15530, effective October 1, 2026) sets the MPF at 0.3464% of declared value, with a minimum of $34.58 and a maximum of $670.86, charged per entry summary line under 19 CFR 24.23. The minimum binds below about 9,983 of declared value; the maximum binds above about 193,666.
Is there a minimum entry fee even when duty is free?
Yes. The $34.58 MPF minimum applies to every formal entry summary line regardless of the duty outcome, and the 0.125% HMF adds further cost on sea cargo. A Free-line shipment worth $25,000 still carries about $117.85 of government charges - roughly 0.47% of value before a cent of tariff.
Does the harbor maintenance fee apply to air freight?
No. HMF is levied on the value of commercial cargo unloaded at US ports, so it attaches to waterborne imports under 26 U.S.C. 4461 and 19 CFR 24.27. Air and land arrivals fall outside it - one more reason mode choice changes landed cost even at identical duty rates.
Do Section 321 low-value shipments pay MPF and HMF?
No. The MPF attaches to merchandise formally entered or released per entry summary line; low-value Section 321/de-minimis shipments are not formal entries and therefore sit outside the formal-entry fee system. Note that following the 2026 suspension of the $800 de minimis exemption for most goods, far fewer shipments qualify.