The Hidden Cost of US Imports: MPF, HMF, and the PGA Filings Most Calculators Miss
Duty is the line every importer watches. The lines they don't watch — Merchandise Processing Fee, Harbor Maintenance Fee, and the Partner Government Agency filings — are where surprise costs and held shipments actually live. Here's the full US-import stack, demystified.
Short version.Duty is the line every importer watches. The lines they don’t watch — the Merchandise Processing Fee (MPF), the Harbor Maintenance Fee (HMF), and the Partner Government Agency(PGA) filings — are where shipments get held, surprise charges show up on the entry summary, and avoidable penalties get assessed. This guide walks through every line CBP charges on a US import in 2026, in the order it appears on the entry, with the live ad-valorem percentages we’ve coded into our landed-cost calculator.
The full US import-cost stack (in calculation order)
For any commercial entry into the United States, CBP’s charge stack is:
1. Customs value = invoice + freight + insurance (CIF basis)
2. + MFN duty = CIF × HTS Column 1 rate
3. + Section 301 surcharge = CIF × Chapter 99 rate (if China-origin)
4. + Anti-dumping / countervailing = CIF × ADD/CVD rate (if applicable)
5. + MPF = CIF × 0.3464% (capped MIN $32.71 / MAX $634.62)
6. + HMF = CIF × 0.125% (sea cargo only)
7. + Federal excise / IRS taxes (alcohol, tobacco, etc.)
= Total CBP charges (state sales tax may apply at point of resale)
The duty line is "the" line everyone Googles. The four lines below it — Section 301, MPF, HMF, excise — collectively change a quote from approximately right to approximately wrong. Let’s take them one at a time.
1. The Merchandise Processing Fee (MPF)
MPF is the user-fee CBP charges for processing each commercial entry. Established under the Consolidated Omnibus Budget Reconciliation Act of 1985 and updated annually under 19 CFR 24.23, it’s a small percentage with a tight floor and ceiling. As of fiscal year 2026:
| Entry type | MPF rate | FY2026 cap |
|---|---|---|
| Formal entry (declared value > $2,500) | 0.3464% of customs value | MIN $32.71 / MAX $634.62 |
| Informal entry (declared value ≤ $2,500) | Flat fee | $2.62 per shipment |
| Section 321 de minimis (≤ $800, non-commercial) | Waived | $0 |
| Mail entry (USPS) | Flat fee | $2.62 |
| Manual surcharge (paper-filed entries) | Add-on | $3.49 |
What the MIN and MAX actually do
On a $5,000entry: 0.3464% of $5,000 = $17.32. That’s below the $32.71 minimum, so you pay $32.71 — about 0.65% of declared value. On a $300,000entry: 0.3464% of $300,000 = $1,039. That’s above the $634.62 maximum, so you pay $634.62 — about 0.21%. The cap structure means MPF as a percentage is regressive: small importers pay relatively more.
FTA exemptions — the part most calculators miss
MPF is waivedfor goods that qualify under USMCA, CAFTA-DR, Israel FTA, Jordan FTA, Australia FTA, Bahrain FTA, Chile FTA, Colombia TPA, Korea FTA (KORUS), Morocco FTA, Oman FTA, Panama TPA, Peru TPA, and Singapore FTA — provided you claim the preference at entry with a valid Certification of Origin and the goods qualify under the agreement’s rules of origin. Section 301 surcharges, notably, do not exempt MPF — China-origin goods still pay the fee even when subject to a 25% Chapter 99 surcharge.
2. The Harbor Maintenance Fee (HMF)
HMF is a flat 0.125% ad-valorem feeon commercial cargo entering through US seaports. It funds the US Army Corps of Engineers’ Harbor Maintenance Trust Fund — dredging, jetty maintenance, and federal channel work. Crucially:
- HMF applies only to sea cargo. Air, road, and courier shipments do not pay HMF.
- HMF has no minimum or maximum— it’s a straight percentage. On a $1M ocean shipment, HMF is $1,250. On a $5,000 ocean shipment, HMF is $6.25.
- HMF is not waived by FTAs, even for USMCA goods. HMF funds infrastructure, not the entry-processing work that MPF covers, so the legal logic for waiver doesn’t apply.
- HMF is also charged on exports from US seaports, though the constitutionality of that has been challenged.
Why this matters for landed-cost quotes
A $200,000 formal sea-cargo entry from China hits HMF for $250. On paper that’s a rounding error — but for high-volume importers (think a 20-container year), HMF on the cumulative customs value can add tens of thousands annually. Air freight skips the line entirely; a quote that lumps "customs fees" into a single number obscures whether the importer would save by switching mode.
3. Section 301 — the China factor
Section 301 of the Trade Act of 1974 gives the US Trade Representative the authority to impose additional duties on goods from countries determined to engage in unfair trade practices. Since 2018, four lists of Chinese-origin goods have been hit with surcharges of 7.5% to 25% — applied on top of the regular MFN duty.
The surcharge isn’t published in the main duty column of the HTS. Instead, the regular HTS line carries a footnote that points at a Chapter 99 line — typically 9903.88.xx— where the surcharge rate is published ("the duty provided in the applicable subheading plus 25%"). Off-the-shelf calculators that read only Column 1 silently drop the 25%. We mapped every footnote: 10,032 explicit Section 301 rows linked to their source Chapter 99 line.
4. PGA filings — where shipments get held
A Partner Government Agency filing is required when an imported good falls under another federal agency’s regulatory jurisdiction. CBP coordinates with about 50 PGAs through the Automated Commercial Environment (ACE) system. The major ones for commercial importers:
| Agency | Regulates | Common HS chapters | Filing |
|---|---|---|---|
| FDA | Food, drugs, cosmetics, medical devices | 02–24, 30, 33, 90, 96 | FDA prior notice (food), FDA Form 2877 (devices) |
| USDA APHIS | Live animals, plants, phytosanitary | 01, 06–08, 10, 12 | PPQ Form 587 / VS Form 17-129 |
| USDA FSIS | Meat, poultry, egg products | 02, 04, 16 | FSIS Form 9540-1 |
| FCC | RF devices, transmitters, receivers | 85 (8517, 8525, 8526, 8527) | FCC Form 740 |
| EPA | Pesticides, refrigerants, vehicle emissions | 28, 29, 38, 39, 84, 85, 87 | EPA FIFRA Notice of Arrival, Form 3520-1 |
| DOT NHTSA | Motor vehicle safety standards | 87 | DOT HS-7 form |
| CPSC | Toys, recreational equipment, consumer goods | 39, 95 | CPSC General Conformity Certificate |
| ATF | Firearms, ammunition, tobacco permits | 24, 93 | ATF Form 6 / 6A |
| TTB | Alcoholic beverages — federal excise | 22 | TTB Form 5100.24 |
The PGA disaster pattern
Importer ships an LED light fixture (Chapter 85) from China to LA. MFN duty is 3.9%. They quote the customer landed cost based on duty + freight + last-mile. The container arrives. CBP holds the shipment because the FCC Form 740 wasn’t filed (LED drivers contain RF circuitry). Days of demurrage charges accumulate. The customer gets it three weeks late and the relationship is over.
Most calculators don’t flag PGA involvement at all because the HTS doesn’t carry a one-to-one PGA map. Each agency publishes its own commodity scoping document. We solved this with chapter-level heuristics: when the HS code falls into a chapter that frequently triggers a PGA filing, our calculator surfaces an amber-tinted "Likely PGA filings" panel below the breakdown — listing the agency, what it regulates, and the form to file.
Worked example: $50,000 LED fixture shipment from China by sea
| Line | Calculation | Amount |
|---|---|---|
| Customs value (CIF Long Beach) | $50,000.00 | |
| HTS 9405.11 (LED fixtures) MFN duty 3.9% | $50,000 × 3.9% | $1,950.00 |
| Section 301 surcharge (List 3, 25%) | $50,000 × 25% | $12,500.00 |
| MPF (formal-entry, capped at MAX) | 0.3464% × $50,000 = $173.20 | $173.20 |
| HMF (sea cargo) | 0.125% × $50,000 | $62.50 |
| Total CBP charges | $14,685.70 | |
| + FCC Form 740 filing (per shipment) | Broker fee, typically $35–$75 | ~$50 |
| Effective rate vs. customs value | ~29.4% |
A naive quote would have come in at $1,950 duty (3.9% — feels reasonable). The actual landed cost added $12,735 — six times the duty — across Section 301, MPF, HMF, and the PGA filing fee. This is why the breakdown matters more than the headline rate.
The same shipment from Mexico under USMCA
| Line | Calculation | Amount |
|---|---|---|
| Customs value (CIF McAllen) | $50,000.00 | |
| USMCA preferential duty | $50,000 × 0% | $0.00 |
| Section 301 surcharge | Not applicable (origin = MEX) | $0.00 |
| MPF (waived under USMCA) | USMCA exempt | $0.00 |
| HMF | Not applicable (road, not sea) | $0.00 |
| Total CBP charges | $0.00 |
Same product, same value, different sourcing decision: $14,685.70 difference. The decision-maker who runs both numbers in the calculator before signing the supplier contract is the one who builds margin into the quote.
FAQ
Is MPF the same as duty?
No. Duty is the percentage applied to the customs value based on the HTS schedule. MPF is a separate processing fee charged by Customs and Border Protection (CBP) for the work of clearing your shipment. They sit on different lines on the entry summary and they have different waiver rules — most notably, USMCA waives MPF but obviously does not waive duty (it sets it to 0%, which is mathematically the same outcome but legally a different concept).
Do I pay HMF on air freight?
No. The Harbor Maintenance Fee is a 0.125% ad-valorem fee that funds dredging and waterway maintenance — it applies only to commercial cargo arriving by sea. Air, road, and courier shipments do not pay HMF. Our calculator shows the HMF line only when the user selects 'Sea' as the transport mode; on any other mode, the line is omitted entirely.
What's the threshold between informal and formal entry?
$2,500 USD declared value. Below that threshold, CBP processes as an 'informal entry' with a flat $2.62 MPF, no formal Customs Form 7501, and simplified handling. At or above $2,500, the entry is formal — full Customs Form 7501, ad-valorem MPF (0.3464%, MIN $32.71 / MAX $634.62 in FY2026), full broker engagement. Section 321 'de minimis' is a separate $800 threshold below which goods enter duty-free for non-commercial use.
If my goods are USMCA-originating, do I still pay MPF?
No — MPF is waived for goods that qualify as USMCA-originating, provided you claim the preference at entry with a valid Certification of Origin. Same for goods qualifying under CAFTA-DR, Israel FTA, Jordan FTA, and several other US bilateral FTAs. Our calculator detects the matching FTA, sets MPF to $0 in the breakdown, and surfaces a 'subject to rules-of-origin verification' note so you don't claim a benefit you can't substantiate.
How do I know if my product needs an FDA, FCC, or EPA filing?
There's no single official table that maps every HTS code to its required PGA filings — each Partner Government Agency publishes its own commodity scoping documents, and CBP's Automated Commercial Environment (ACE) system has the per-code rules baked in. As a fast heuristic, our calculator surfaces likely PGA filings based on the HS chapter (e.g. Chapter 30 = FDA, Chapter 85 = FCC for RF devices, Chapter 87 = EPA + DOT NHTSA). Verify with CBP or your broker for binding determinations, but the heuristic catches the high-frequency cases.
Can I appeal an MPF charge that seems wrong?
Yes. CBP allows post-summary correction (PSC) within 314 days of liquidation, or a protest within 180 days. The most common MPF errors are (1) charging formal MPF on what should have been informal, (2) failing to apply an FTA exemption, and (3) double-charging on consolidated shipments. Our breakdown surfaces the basis for every MPF line so you can verify against the entry summary — useful evidence if you do file a PSC.
What to do next
Before you commit to a US-bound shipment, run the full breakdown. Open the landed-cost calculator, set destination to USA, choose your origin, pick your transport mode (sea triggers HMF), and look at every line — duty, Section 301, MPF, HMF, PGA flags. If you import from China, our US-China tariff lookup page documents all 10,032 Section 301 surcharges. If you have a USMCA option, the USMCA duty-free check page shows the 14,376 preferential rules across Mexico + Canada.
Adjacent reading: How much duty will I pay covers the duty math itself; Landed cost vs FOB frames the bigger total-cost picture; and The USMCA ‘S’ Indicator explained tells the story of why most calculators miss USMCA preferences and how we fixed it.
Stop re-typing the same fields.
Generate a compliant customs invoice PDF in under a minute, with HS code autocomplete and Incoterms validation baked in.
Create an invoice