Are MPF and HMF refundable under CAPE?

No — MPF and HMF are user fees, not duties. They are not affected by the IEEPA ruling. Only the IEEPA duty portion is refundable through CAPE.

Can I recover MPF through drawback?

Yes — 99% of MPF is drawback-eligible under 19 USC 1313(j) when goods are exported. HMF is also recoverable. Amounts are small per entry but add up across high-volume importers.

What are the current MPF/HMF rates?

MPF: 0.3464% of entered value, min $31.67 / max $614.35 per entry. HMF: 0.125% of entered value, applies only to vessel-imported goods. Rates adjust annually.

Do MPF and HMF apply to every entry?

MPF applies to every formal entry. HMF applies only to ocean shipments unloaded at US ports. Air freight and truck imports from Canada/Mexico are HMF-exempt.

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Are MPF and HMF refundable?

Tariff Refund Credits·Updated 2026-04-22·~2 min read

● Quick answer

Merchandise Processing Fee (MPF) under 19 USC 58c(a)(9) is refundable through duty drawback under 19 USC 1313(l), but is not refunded through the CAPE IEEPA program because MPF is a user fee, not an IEEPA-imposed duty. Harbor Maintenance Fee (HMF) is generally not refundable on consumption entries. Both fees appear separately on CBP Form 7501.

What MPF is

Merchandise Processing Fee is a user fee CBP charges to cover the cost of processing entries. Rates as of 2026:

Formal entries (Type 01) — 0.3464 percent of declared value, minimum $32.71, maximum $634.62 per entry
Informal entries (Type 11) — flat $2.62 per entry
Manual entries — $9.99 additional

MPF is authorized under 19 USC 58c(a)(9)(A) and set by regulation at 19 CFR 24.23. The minimum and maximum per-entry caps are indexed annually for inflation.

What HMF is

Harbor Maintenance Fee is a separate user fee funding port dredging and harbor maintenance. Rate: 0.125 percent of declared value on goods arriving by vessel at US ports. HMF applies to both imports and domestic shipments moving through deep-water ports.

HMF does not apply to air freight or to some inland ports. It appears on the 7501 as a separate fee line.

MPF and CAPE IEEPA refunds

CAPE refunds only the IEEPA duty. MPF is a user fee collected under a different statute (19 USC 58c), is not impacted by the SCOTUS IEEPA ruling, and does not refund through CAPE.

If the SCOTUS IEEPA ruling had struck down MPF (it did not), MPF would refund. As written, CBP CAPE processes only the IEEPA duty line on the 7501.

Practical consequence: on a $100,000 entry with $10,000 IEEPA duty and $346 MPF, CAPE refunds $10,000 and retains the $346 MPF.

MPF and duty drawback

MPF is refundable under duty drawback per 19 USC 1313(l), which was amended by the Trade Facilitation and Trade Enforcement Act (TFTEA) in 2016 to explicitly include merchandise processing fees in drawback recovery. If you export, destroy, or substitute imported goods, the MPF on the underlying import entry is recoverable at 99 percent along with the duty.

See duty drawback guide for filing mechanics.

HMF refund limitations

HMF on consumption entries is generally non-refundable under CBP guidance. The Court of International Trade and Federal Circuit have upheld HMF's status as a user fee rather than a duty.

Limited HMF refund paths:

Exports (not imports) — HMF on exports was struck down in US Shoe Corp. v. United States (1998) as an unconstitutional export tax. HMF now applies only to imports and domestic shipments.
Goods entered and exported in same condition — Drawback under 19 USC 1313(j) can recover HMF on qualifying unused-merchandise drawback claims.

For most importers, HMF stays paid.

Reading your 7501 for these fees

On CBP Form 7501:

Block 38 — Merchandise Processing Fee
Block 39 — Harbor Maintenance Fee
Block 37 — Duty (includes MFN + 301 + 232 + IEEPA)

When calculating your CAPE refund, do not include Block 38 or 39. Only the IEEPA portion within Block 37 is refundable through CAPE.

Other fees on the 7501

For completeness:

Cotton Fee — 19 USC 6103, refundable under 1313
Beef/Pork Fees — 7 USC 2904, not refundable
Sugar Fee — 7 USC 7701, not refundable
Honey Fee — 7 USC 4602, refundable under limited circumstances

Most of these are narrow-commodity user fees. For mainstream consumer imports they don't apply.

MPF minimums and maximums matter

On small entries, the $32.71 MPF minimum can be a meaningful share of duty. On large entries, the $634.62 cap means MPF flattens out — a $10M entry pays the same MPF as a $183,000 entry (both hit the cap).

High-value single-shipment importers benefit from consolidation; the MPF cap rewards larger entries. But for IEEPA refund purposes, each entry is refunded on its own merits regardless of MPF size.

De minimis entries (Section 321)

Section 321 entries under $800 per day per consignee clear without formal entry and without MPF or HMF. Changes to de minimis rules are under active USTR review as of April 2026; the Trump administration has proposed tightening de minimis for China-origin goods. Watch Federal Register for updates.

De minimis entries are not typically eligible for CAPE refunds because the entry structure is informal.

Calculate your tariff refund → /calculators/ieepa-refund

What's the difference between drawback and refund? See drawback vs refund.

Does CBP pay interest on refunds? Yes. See refund interest.

Who qualifies for IEEPA refund? See who qualifies.

Not legal advice. Customs business performed by licensed customs broker partners under 19 CFR 111.

Not legal advice. Customs business performed by licensed customs broker partners under 19 CFR 111. Refund amounts are estimates only and subject to CBP adjudication.