Duty accrual vs what you actually paid: reconciling the accrual to the 7501 lines, not the broker invoice

Which figure is the duty CBP will liquidate?

The amount owed to CBP is set by law, line by line, on the entry summary: the value under 19 U.S.C. 1401a, the rate in force at the time of entry under 19 CFR 141.69, and the fees under 19 CFR 24.23 and 24.24. 19 U.S.C. 1505 then says when that estimate is deposited and how interest runs on any difference found at liquidation. Everything else finance holds for the shipment is either a forecast of that amount or a record of paying it.

The usual close routine ties the accrual to the broker's bill. Both are secondary records, so a match proves only that the broker billed what finance expected, and a mismatch cannot say which side is wrong. The tie that finds money runs from each of them to the entry lines.

What makes the accrual differ from the entry?

Each input to the accrual differs from the input CBP uses.

Value. The accrual starts from the invoice total. The entered value is the price actually paid or payable, which under 19 CFR 152.102(f) excludes the cost of international transport and insurance, and under 19 CFR 152.103 includes additions such as assists, royalties paid as a condition of sale and packing paid by the buyer. A freight-inclusive invoice overstates the base; an invoice that omits a tooling assist understates it. What counts in the value is its own page: what counts in customs value.

Currency. The accrual converts at the ERP posting rate on the invoice date. CBP converts at the rate for the date of exportation (19 CFR 159.32, 152.1(c)): the certified quarterly rate, or the certified daily rate if it differs by 5 percent or more (19 CFR 159.34, 159.35). On a volatile currency the two rates can be several percent apart.

Rate. The accrual uses one rate per product, typically the general rate from a rate card built when the product was set up. The entry carries that rate in column 37A and, on a separate Chapter 99 line with its own rate and duty, every additional measure in force on the entry date: Section 232 on metal content or full value, Section 301 on products of China, and since July 24, 2026 the Section 301 forced-labor duties of 10 or 12.5 percent on products of sixty economies (91 FR 47318). A product of Vietnam costed in 2025 at a 2 percent general rate files at 14.5 percent on entries from July 24, 2026, when heading 9903.05.84 added 12.5 percent. Which layers belong on a line, and why the broker's stack can be wrong too, is in why your entry shows the wrong duty stack.

Date. The accrual is keyed to receipt or invoice date. The rate is keyed to the time of entry under 19 CFR 141.68, which for most consumption entries is when the entry summary is filed with estimated duties or when CBP authorizes release. A rate change that lands between shipment and entry, as the July 24, 2026 action did for goods on the water that month, moves the filed duty and leaves the accrual where it was. How effective dates treat goods already shipped is in does a new tariff apply to goods already in transit.

Fees. The accrual usually ignores the merchandise processing fee (0.3464 percent of entered value, between $33.58 and $651.50 per entry from October 1, 2025 and between $34.58 and $670.86 from October 1, 2026) and the harbor maintenance fee (0.125 percent on vessel cargo at listed ports). They appear in the entry totals and on the broker invoice, so they land in the variance.

Where does each amount sit on the 7501?

Reconciling to the entry means knowing which box holds what. Using the numbering of the current form, described box by box in Form 7501 field by field:

The entry export your broker can produce carries the same fields per line in a table, which is what the close routine below reads. The ACE entry summary data, available to the importer in its own portal account, is the same thing from CBP's side.

What is on the broker invoice that is not duty?

A broker invoice is a payment record with the duty inside it. 19 CFR 111.29(a) requires the broker to pay the Government on time and to account in writing within 60 days for client money not paid over; 19 CFR 111.29(b) requires the broker to tell you in writing that paying the broker does not discharge your liability to CBP. The invoice therefore lists:

• Disbursement of duty, merchandise processing fee and harbor maintenance fee, usually one figure per entry, which should equal blocks 41 to 44 of that entry.
• Brokerage for filing the entry, often plus charges per additional line or per Chapter 99 heading.
• Pass-through charges such as bond, ISF filing, exam or storage, and a disbursement fee.
• Timing. The broker bills on its own cycle; the duty was deposited at entry or on the periodic statement, which CBP notes can be up to 45 days after the entry date.

Book the disbursement line against the entry totals and the rest as service cost. When the disbursement on the invoice does not equal the entry totals, one of them is wrong, and the entry is the one to check first.

How far apart are the accrual and the entry on one line?

The product is a solenoid valve, HTS 8481.80.90, general rate 2 percent. The product master was costed in June 2026 with a 2 percent duty rate. The purchase invoice is $208,000, which includes $8,000 of ocean freight. The goods were exported on August 20, 2026 and the entry summary was filed on September 2, 2026. The cargo arrived by vessel at a listed port. Illustrative figures.

The broker invoice three weeks later shows a disbursement of $29,901.50, brokerage and a disbursement fee. Finance sees an invoice seven times the accrual and books the difference to a variance account. The true picture is four separate facts: the base was $8,000 too high, the rate card missed a 12.5 percent layer that took effect on July 24, 2026, two fees were never in the accrual, and the rest is service cost. Three of those four will recur on every entry of the product until the rate card and the accrual logic change. To price a line for its entry date before the accrual is set, use the duty calculator.

The direction matters too. Had the entry been filed with an extra Chapter 99 line that did not belong, or with the freight left in the entered value, the broker invoice would still have reconciled to the entry. The reconciliation only finds that by recomputing the expected duty per line.

How do you true up the accrual each month from the entry export?

Six steps, in the order that finds the money first:

1. Pull the month's entry lines by entry date from the broker export or the ACE entry summary data: entry number, line, HTS and Chapter 99 headings, entered value, each rate, each duty amount, fees and the importation and entry dates.
2. Recompute the expected duty per line for its entry date: entered value times the general rate, plus entered value times each Chapter 99 rate that applies to that origin and product on that date, plus the fee amounts under 19 CFR 24.23 and 24.24. List the lines where the filed duty differs from the recomputed duty in either direction.
3. Tie the entered value to the invoice: invoice amount, less separately identified international freight and insurance, plus any additions under 19 CFR 152.103, converted at the export-date rate. List lines where the entered value does not follow from the invoice.
4. Tie the entry totals to the statement and the broker invoice. Blocks 41 to 44 equal the disbursement; everything else on the invoice is service cost. Note entries deposited on a statement that falls in the next month.
5. Post the accrual true-up by cause, not as one variance: base, rate layer, fees, currency, and anything from step 2 that is an entry error rather than an accrual error.
6. Hand the step 2 and step 3 exceptions to compliance with the entry number and line. Before liquidation they are post-summary corrections within 300 days of entry and at least 15 days before the scheduled liquidation; after liquidation they are protests or disclosures. The windows are in how long you have to fix a past entry.

Step 2 is also the fix for the rate card: the recomputed rate per product and origin, as of this month's entry dates, is the accrual rate for next month. Whether the duty is capitalized into inventory or expensed is a question for your accounting policy and auditors; what this routine changes is that the figure being capitalized is the entry figure, with its liquidation exposure known, rather than a bill.

The full reconciliation of broker exports to invoices and the ERP, including the cases where the three cannot be matched line to line, is in reconciling broker entry exports with invoices and your ERP. For what to check on each line beyond the arithmetic, start from the post-entry audit pillar.

TariffSense reads broker entry exports, entry summaries and invoices, recomputes each line's duty and fees for its entry date and reports the lines where the filed amount, the entered value or the stack differs from what the documents support, in both directions. The accounting entries and any filing stay with your team and your broker.