What a landed cost spreadsheet gets wrong about US fees

The cost columns in an import tracker are usually the part nobody argues with. Goods, freight, insurance, duty, broker fee, transport. One row per container, one column per charge, a percentage where a percentage belongs.

Two of those columns cannot hold a percentage, and on a US import they sit side by side on the same document.

The regulation says its own numbers are not the fees

Start with the sentence that invalidates most of what gets typed into a landed cost tracker. It is in the opening paragraph of 19 CFR § 24.22, before any fee is stated:

the specific customs user fee amounts and corresponding limitations that appear in this section are not the actual fees or limitations but represent the base year amounts that are subject to adjustment each fiscal year in accordance with the Fixing America’s Surface Transportation Act (FAST Act) using Fiscal Year 2014 as the base year for comparison.

The dollar amounts printed in the regulation are a 2014 baseline. The operative figures are re-indexed, and § 24.22(k)(1) says who publishes them and when:

CBP will determine annually whether an adjustment to the fees and limitations is necessary and a notice specifying the amount of the fees and limitations, as adjusted, will be published in the Federal Register annually for each fiscal year at least 60 days prior to the effective date of the new fees and limitations.

Sixty days’ notice, every fiscal year, in a document a desk has to go and read. A constant typed into a spreadsheet in 2023 is not a constant. It is a number that was right once.

That notice landed for this fiscal year on 31 July 2026, and its figures are required from today. CBP Dec. 26-14 sets the minimum processing fee at $34.58, the maximum at $670.86 and the manual-entry surcharge at $4.15, each required as of 1 October 2026. Set those against the $25, $485 and $3 printed in the regulation and every limit is 38 percent higher than the base-year figure it is derived from. The rate itself did not move, and the notice says so in a footnote: “Only the limitation is increasing; the ad valorem rate of 0.3464 percent remains the same.”

So a tracker carrying the regulation’s own numbers is not slightly stale. On a small entry it is out by nine dollars and fifty-eight cents, every time, and on a large one by a hundred and eighty-six.

Why 0.3464% is never the share you pay

The merchandise processing fee on a formal entry is stated plainly enough:

merchandise that is formally entered or released is subject to the payment to CBP of an ad valorem fee of 0.3464 percent

Then the next subparagraph does something a percentage column has no room for. The fee “must not exceed $485 … and must not be less than $25”, both as adjusted under § 24.22(k).

A rate with a floor and a ceiling is not a rate. Divide the base-year floor by the rate and the minimum governs everything below about US$7,217 of entered value. Divide the base-year ceiling by the rate and the maximum governs everything above about US$140,012. In between, and only in between, the stated percentage is the percentage.

So on a US$5,000 consignment the base-year floor of $25 is an effective 0.50%, not far off half again as much as the printed rate. On a US$250,000 consignment the base-year ceiling of $485 is an effective 0.194%, a little over half of it. One cell holding 0.3464% overstates the cheap box and understates the expensive one, and the error runs in opposite directions on the same page of the same tracker.

There is a third line most columns miss entirely: a formal manual entry carries a surcharge of $3, base-year, on top of the ad valorem fee.

The harbour fee has no clamp, and the port decides whether it applies

The harbor maintenance fee looks like the simpler of the two and is differently awkward:

Commercial cargo loaded on or unloaded from a commercial vessel is subject to a port use fee of 0.125 percent (.00125) of its value if the loading or unloading occurs at a port within the definition of this section

No floor, no ceiling, no annual re-indexing: 0.125% all the way up. A percentage column holds this one correctly, which is why it is the fee desks tend to get right.

The catch is in the conditional. “A port within the definition of this section” is not every US port; it is an enumerated list, printed in the regulation, port code by port code. And the list carries notes at harbour level: against one Alaskan entry, “Fee does not apply to Juneau Harbor”; against another, “Fee does not apply to Wades Cove”. The port of discharge is therefore an input to whether the charge exists, and a tracker that applies 0.125% to every arrival is applying it to some arrivals that never owed it.

A trade agreement zeroes one and leaves the other

Here is the pair’s sharpest divergence, and the one most likely to put a wrong total in front of a buying decision. On the processing fee, origin is dispositive:

The ad valorem, surcharge, and specific fees provided for under paragraphs (b)(1) and (2) of this section will not apply to goods originating within the meaning of General Note 11, HTSUS … or to goods that qualify for preferential tariff treatment under § 182.82 of this chapter

The harbour fee’s exemptions are in its own paragraph (c) and they are about something else altogether: bunker fuel, ship’s stores, fish not previously landed, ferries, and a set of Alaska, Hawaii and possessions movements. Origin appears nowhere in them.

A USMCA-originating container therefore owes no processing fee and owes the harbour fee in full. “Duty-free under the agreement” is a statement about duty, and a tracker that treats it as a statement about fees is carrying a shortfall on every preferential entry it holds.

Two fees, two dates, one shipment

The last difference is the one that matters to anyone reconciling an estimate against an actual. The two fees attach at different moments.

The processing fee “is due and payable to CBP by the importer of record of the merchandise at the time of presentation of the entry summary”. The harbour fee, on imports, makes the importer “liable for the payment of the port use fee at the time of unloading”, and is then paid on the entry summary alongside the duty.

Liability at discharge, payment at filing. On a shipment where those fall in different accounting periods, a tracker that stamps both fees with the entry date has put one of them in the wrong month, and the month-end that notices is the one after the container left.

What those two columns need

Neither fee is hard arithmetic. Both are hard bookkeeping, and the requirements fall out of the regulations rather than out of anyone’s opinion:

• The current floor, ceiling and surcharge, from this fiscal year’s notice, with the date they took effect, not the figures in the printed regulation.
• The entered value under 19 U.S.C. 1401a, which is also the customs value the duty is assessed on, so both fees and the duty share one base.
• Whether the goods claimed preferential origin, because that zeroes one fee and not the other.
• The port of discharge, against the regulation’s own list.
• Whether the entry was filed manually, for the surcharge.
• Two dates per shipment, not one.

That is six inputs and two dates to produce two lines, on a document that also carries the duty. That is work which is trivial per container and unmanageable at five hundred a month, which is the whole of the argument for doing it from the documents as they arrive rather than from a rate card someone typed in. Docket keeps each charge against the container with the email that carried it, which is what makes a fee line checkable a year later when a broker’s figure and yours disagree.

If you want to see the shape of the total rather than the two fee lines, the landed cost calculator takes your own duty rate and your own charge lines and publishes none of its own.

A fee line being right at the time of entry is also not the end of it. The duty on an entry is provisional until the entry liquidates, and where a duty is later held unlawful the money comes back only to importers who can say which entries carried it — which is what makes an IEEPA tariff refund a records exercise rather than a filing one.

One thing to do with this page: open your tracker, find the cells holding the processing fee’s minimum and maximum, and see whether they say $34.58 and $670.86. If they say $25 and $485, or last year’s figures, every formal entry you file from today carries the wrong number.