Reconciling broker entry exports with invoices and your ERP: where the numbers stop matching

What do the three documents actually record?

Each one is right about something different, which is why they disagree.

The commercial invoice is the sale. Under 19 CFR 141.86 it must show the purchase price of each item in the currency of the purchase, quantities in the weights and measures of the shipping country or of the United States, every charge on the merchandise itemized by name and amount (freight, insurance, commission, packing) and any assists not included in the price. It is in the supplier's currency and the supplier's units.

The broker's entry export is the declaration. It lists what was filed on each Form 7501 line: HTS number, any Chapter 99 numbers, country of origin, entered value in US dollars, quantity in the units the tariff requires, and the duty and fees by line. It reflects CBP's valuation rules and CBP's exchange rate, not your purchase order.

Your ERP and general ledger are the books. They hold the purchase order, the goods receipt, the supplier's invoice booked to payables at your booking rate, the broker's invoice (duty paid on your behalf plus brokerage fees), freight invoices and, if you run one, a duty accrual. They are organized by item number and period, not by entry line.

So the job is not to make three numbers equal. It is to explain every difference between them, line by line, and to find the differences that cannot be explained.

Where do the three documents stop agreeing?

Seven gaps account for almost every difference. Most are expected; some are findings.

The rest of this page takes each gap in turn, with one illustrative shipment carried through.

The illustrative shipment. A supplier invoices 2,000 units at EUR 25.00 on CIF terms: EUR 50,000, of which EUR 3,000 is itemized freight and insurance. You supplied the mold free of charge, and USD 4,000 of its value is apportioned to this shipment. CBP's certified rate for the date of exportation is 1.0850 dollars per euro; your ERP booked the invoice at 1.0700. The base duty rate is 3.4 percent. Every rate and amount here is illustrative.

Why does entered value differ from the invoice total?

Two rules move it, in opposite directions.

Freight and insurance come out. Under 19 CFR 152.102(f) the price actually paid or payable is the total payment to the seller "exclusive of any charges, costs, or expenses incurred for transportation, insurance, and related services incident to the international shipment". On CIF or delivered terms the broker deducts them. In the example, EUR 50,000 less EUR 3,000 leaves EUR 47,000.

Additions go in. Under 19 CFR 152.103(b)(1), transaction value adds five things when they are not already in the price: packing costs incurred by the buyer, selling commissions incurred by the buyer, the apportioned value of any assist, royalties or license fees paid as a condition of sale and proceeds of resale that accrue to the seller. The mold in the example is an assist.

Converted at CBP's rate, EUR 47,000 is $50,995.00. Add the $4,000 assist and the correct entered value is $54,995.00. If the broker entered $50,995.00, the assist is missing: duty at 3.4 percent was underpaid by $136.00 on this line, and the processing fee was understated too. That is a finding, and an underpayment one.

The reverse also happens. A broker who deducts a cost that was not international freight (a handling fee paid to the seller, say) understates value; a broker who deducts nothing on CIF terms overstates it and you overpay duty on the freight. Neither shows up unless someone compares the entry line with the invoice's itemized charges.

Why doesn't the currency conversion match your books?

Because CBP and your ERP use different rates on different dates, by design.

Under 19 CFR 159.31, CBP may only use a proclaimed or certified rate. The date that matters is the date of exportation (19 CFR 159.32). For the currencies listed in 19 CFR 159.34, which include Germany, France, Italy and other European countries, China, Canada, Mexico, Japan and the United Kingdom, CBP uses the certified quarterly rate for any date in the quarter, unless the certified daily rate for the date of exportation varies from it by 5 percent or more. For other currencies, 19 CFR 159.35 applies the daily buying rate certified by the Federal Reserve Bank of New York.

Your ERP books the supplier invoice at its own rate on the invoice or receipt date and settles at the payment date. In the example, EUR 50,000 sits in payables at $53,500.00 while the entry uses 1.0850. That gap is expected and belongs in foreign exchange, not in duty.

A currency difference is a finding only when the broker used the wrong rate or the wrong date, for example the arrival date instead of the date of exportation, or a commercial rate instead of the certified one. Recompute a sample of lines each period with the certified rate to catch it.

Why do quantities and units disagree?

The invoice counts what you bought. The entry counts what the tariff measures.

19 CFR 141.86(a)(4) lets the invoice state quantities in the weights and measures of the shipping country or of the United States. The entry line reports the net quantity in the unit the HTS number requires: kilograms, dozens, pairs, square meters, numbers. Some lines carry a second quantity. Under CSMS #68253075, for example, a line reported under heading 9903.82.03 must carry the aggregate weight of the applicable metals in kilograms as a second quantity.

Two things to check. First, the conversion itself: cartons to pieces, pieces to kilograms, pairs to dozens. A wrong conversion matters most on lines with a specific or compound duty, where the duty is calculated per unit. Second, duplication when a line is split. CBP's October 17, 2025 reminder on Section 232 reporting told filers to "avoid duplicating quantities when splitting entry lines". If the split lines together report twice the invoice quantity, the line is wrong even if the value is right.

Why does one invoice line become several entry lines?

Because some duty rules have to be reported on their own line, and because an entry line can carry several HTS numbers.

Section 232 content splits. For steel and aluminum derivative articles, CBP guidance in CSMS #65236374 and #65236645, restated on October 17, 2025, said the Section 232 duty was assessed on the value of the metal content. Where the content value was less than the entered value, filers had to report the metal and non-metal content "on separate entry summary lines with the appropriate classifications and quantities". One invoice line became two entry lines with different Chapter 99 numbers and different duty.

The rule changed for entries from April 6, 2026. CSMS #68253075 implements Proclamation 11021 of April 2, 2026, which "imposes 10-50% additional duties on the full customs value" of covered steel, aluminum and copper articles and derivatives, effective for goods entered on or after April 6, 2026. Lines entered before and after that date reconcile differently, so a reconciliation rule written for one period will misfire on the other. Why your entry shows the wrong duty stack works through these lines in detail.

Several duties on one line. CBP's guidance also says that where an entry summary line includes multiple HTS numbers, duties "must not be combined and cannot be reported on only one HTS". Your ERP probably holds one duty figure per item. The entry holds one per HTS number on the line: the base rate, then each Chapter 99 measure.

How to match. Use invoice number and invoice line on one side and entry number and entry line on the other, and allow many entry lines to one invoice line. Sum the split lines back to the invoice line before comparing value and quantity, and compare duty per HTS number, not per line. You can rebuild the expected stack for a line with the duty calculator.

Where do MPF and HMF come from, and why are they off?

The merchandise processing fee under 19 CFR 24.23 is an ad valorem fee of 0.3464 percent, based on value as determined under 19 U.S.C. 1401a and due when the entry summary is presented, with a minimum and maximum adjusted each fiscal year. CBP Dec. 26-14 (91 FR 48398, July 31, 2026) sets the minimum at $34.58 and the maximum at $670.86 for entries from October 1, 2026. For fiscal year 2026, CBP Dec. 25-10 set them at $33.58 and $651.50. In the example, 0.3464 percent of $54,995.00 is $190.50, between the limits.

The harbor maintenance fee under 19 CFR 24.24 is 0.125 percent of the value of commercial cargo loaded or unloaded from a commercial vessel at a listed port. Air and truck shipments do not pay it. In the example, if the goods arrived by ocean at a listed port, HMF is $68.74.

Why the books differ. The MPF minimum and maximum apply to the entry, not the line. An ERP that allocates 0.3464 percent to every item will over-allocate on large entries that hit the maximum and under-allocate on small ones that hit the minimum. An ERP that applies HMF to every shipment will overstate it on air freight. Neither is a customs error. A customs finding is an MPF or HMF that is wrong on the entry itself, usually because the entered value it was computed on was wrong.

Why does the duty in your ledger differ from the duty on the entry?

Because the duty on an entry is not final when you pay it.

Under 19 U.S.C. 1505(a), the importer deposits estimated duties and fees at entry or no later than 12 working days after entry or release. Importers on the periodic monthly statement deposit no later than 15 working days following the month of entry or release; CBP's business rules describe it as consolidating daily statements and paying once a month. Either way, what you pay is an estimate.

The final number comes at liquidation, which 19 CFR 159.1 defines as "the final computation or ascertainment of duties". Under 19 CFR 159.11, an entry not liquidated within one year of entry is deemed liquidated at the amounts the importer asserted, unless liquidation was extended or suspended. At liquidation, 19 U.S.C. 1505(b) says CBP collects increased duties with interest or refunds excess deposits with interest. Bills are due 30 days after issue; refunds are paid within 30 days of liquidation.

Before liquidation, your broker can change the deposit with a post-summary correction. CBP's business rules require the entry to be accepted, fully paid, not under CBP review and not liquidated, and, without an extension, the correction must be filed within 300 days from the date of entry. Each correction changes the duty that should be in your accrual. How long do you have to fix a past entry? sets out these clocks per entry.

How should finance accrue and true up import duty?

Treat each entry as an open item until it liquidates. The steps below assume duty is part of landed cost; how variances flow between inventory and cost of goods sold is a policy for your controller and auditors.

1. Accrue from the entry, not from a standard rate. Book duty and fees per entry line from the broker's entry export when the entry summary is filed, including every Chapter 99 line. A standard-rate accrual will be wrong on every line that carries Section 232, Section 301, IEEPA or Section 122 duty.
2. Tie the accrual to the CBP payment. Match the accrued amount per entry to the daily or monthly statement payment and to the broker's invoice for duty paid on your behalf. Keep brokerage fees separate from duty.
3. Track liquidation status per entry. Keep the entry date, the scheduled liquidation date and the actual liquidation date next to the accrual. An entry still unliquidated after a year without an extension notice is worth a question to your broker.
4. True up at liquidation. A bill increases duty on that entry and carries interest; a refund decreases it and carries interest. Book the duty change against the entry's accrual and the interest as interest, not as duty.
5. Book corrections and protests on the entry they belong to. A post-summary correction, a protest decision or a prior disclosure tender all change one entry's final duty. Book them there so the entry's history explains itself.
6. Set a tolerance and investigate above it. Rounding and fee allocation will leave small differences. Anything larger than your tolerance is a finding to take to your broker, in either direction.

In the example, the accrual from the entry export was $1,733.83 duty. The correct duty, with the assist, is $1,869.83. If you correct it before liquidation, book the $136.00 when the correction is filed. If you find it after liquidation, the route is different and so is the accounting. Unpaid duty found this way is an underpayment to correct with your broker, and possibly a prior disclosure; CF-28 and CF-29: how to audit yourself before CBP asks covers that path.

How do you run the reconciliation on a whole period?

1. Export every entry line for the period from your broker, with entry date, line, HTS and Chapter 99 numbers, value, quantity, duty by HTS number and fees.
2. Export the matching supplier invoices and the ERP receipts, payables and duty accruals for the same period.
3. Pair invoice lines to entry lines, allowing many entry lines per invoice line.
4. For each pair, explain the gaps above in order: value basis, currency, quantity, splits, fees, duty, timing.
5. List what is left as findings: overpaid, underpaid or unsupported, with the entry, the line and the amount.

This is the matching TariffSense does for an audit: it reads broker entry exports, invoices and ERP billing exports in whatever layout they arrive, pairs invoice lines to entry lines, checks each line against the measures in force on its entry date, and returns findings with the reason and the corrected value. See post-entry audit.

What should you do on your own entries next?

Take last month's entry export and the supplier invoices behind it, and reconcile your five largest entries line by line using the seven gaps above. The post-entry audit guide lists the rest of what to check on each line. If any line has a missing addition, a wrong rate or a stack that does not match the entry date, raise it with your broker while the entry is still unliquidated. Where a correction, protest or disclosure is involved, confirm the route with a licensed customs broker or customs counsel.