The "Additional Services" Loophole Past the 110% Cap

If you have read about the federal 100%/110% release rule and assumed it caps everything a mover can charge you at delivery, this is the page that complicates that picture. There is a real exception in the law, and it is the single most important thing to understand if a delivery demand is far above your estimate. This is general information, not legal advice.

What the exception actually says

The release rule lives at 49 U.S.C. § 13707(b)(3). Subparagraph (A) is the 100%/110% ceiling. Subparagraph (C) carves out an exception: that ceiling does not apply to additional services requested by a shipper after the contract of service is executed that were not included in the estimate.^[1] This exception was added to the statute by a 2005 amendment. Before then, the cap was harder to work around; afterward, “additional services” became the recognized channel for legitimate extra charges — and, in the hands of a bad actor, the recognized cover story for an inflated demand.

So both things are true at once: a mover that adds a charge for a service you really did request after signing may be entirely within the rules, and a mover that relabels old work as “additional services” to slip past the cap is doing something the rule was never meant to allow. The whole skill is telling the two apart.

Legitimate add-on vs. disguised demand

A genuine additional service has a few hallmarks. Use them as questions, not verdicts:

• Did you actually request it, after signing? The exception is for services requested by the shipper after the contract is executed. A charge the mover decided to add on its own, for something you did not ask for, does not fit the description.
• Was it absent from your estimate? The exception only covers services not included in the estimate. If the work was already described or priced in your estimate, billing it again as an “additional service” is double-dipping.
• Is it a real, identifiable service? Packing materials you asked for at the door, an extra stop you added, storage you requested — these are concrete things. A vague line item that just makes the total bigger is a flag.

By contrast, a disguised demand tends to show up as a large, round, hard-to-itemize increase that appears for the first time once the truck is loaded — often framed as something you supposedly agreed to but cannot find in any signed document.

”Impracticable operations”: the disclosed-in-the-tariff category

There is a related and legitimate category of extra charges called impracticable operations — situations the crew could not reasonably have priced in advance because of the conditions at pickup or delivery. Common examples are long carries (a long distance between the truck and your door), stair carries, and shuttle service (using a smaller vehicle when the moving van cannot reach your residence).

These charges are allowed, but with a condition: a mover may bill for impracticable operations only if those services and their charges are disclosed in the mover’s published tariff. If a fee for stairs or a long carry is not described in the tariff the mover operates under, the mover does not have a basis to invent it at delivery. The detailed requirements for how movers must handle estimates, charges, and these operations are set out in FMCSA’s consumer-protection regulations.^[2]

The written-agreement timing rule

This is the detail that catches the most people. If a mover wants to revise your estimate upward — because there turned out to be more goods than expected, or because you genuinely added services — that revised estimate only counts if it is agreed to in writing, before the added items or services are provided, and before loading begins.

Once loading has started, the original estimate is treated as reaffirmed. A mover cannot wait until your belongings are on the truck and then present a higher number for the same job and treat it as a binding revision. The leverage moment — your things loaded, the crew waiting — is precisely the moment the timing rule is designed to take off the table.

Before you book, and after the demand

The cleanest protection is on the front end: get a written estimate, keep every document, and watch for the warning signs in moving scam red flags. If the demand has already happened, compare your numbers to the federal ceiling with the Overcharge Checker, confirm your move is even covered by the federal rules using the Coverage Checker, and follow the steps below.

Last reviewed: June 10, 2026