7 Steps to File Your IEEPA Tariff Refund Claim

The Supreme Court ruled IEEPA tariffs unconstitutional in February 2026. CBP has been ordered to refund them. But knowing you’re owed money and actually getting it back are two very different things. The filing process has specific requirements, specific data formats, and specific deadlines — and getting any of them wrong can delay your refund by months or cost you recovery rights entirely.

This is the step-by-step process for filing your IEEPA tariff refund claim, from confirming your status as importer of record through final submission. Whether you’re filing through CBP’s CAPE system, submitting protests on liquidated entries, or exploring immediate capital through claim assignment, these seven steps form the foundation of every recovery path.

If you haven’t already confirmed whether your entries qualify, start with our eligibility guide before working through these steps.

Step 1: Confirm You Are the Importer of Record

Before you touch a single data point, you need to verify that your company is the importer of record (IOR) on the entries you want to recover. This sounds obvious, but it trips up more companies than you’d expect — especially those that use third-party logistics providers, freight forwarders, or customs brokers who may have imported goods under their own IOR number.

Why it matters

Only the importer of record can file a refund claim, submit a protest, or assign a claim to a third party. If your 3PL imported goods on your behalf using their own IOR number, the refund rights belong to them — not to you. You’ll need a written assignment or agreement from the IOR to proceed.

How to verify

Your IOR number is typically your EIN (Employer Identification Number) or, for sole proprietors, your SSN. Check your customs broker’s records or your internal import documentation for the IOR number listed on each entry summary. If you’ve used multiple customs brokers over the IEEPA period (February 4, 2025, through February 24, 2026), verify with each one.

Common complications

Companies that acquired other businesses during the IEEPA period may have entries under the acquired company’s IOR. Entities that restructured, changed EINs, or operated through subsidiaries may have entries scattered across multiple IOR numbers. Each IOR number requires its own filing.

If you’re working with a customs broker, they can pull a report of all entries filed under your IOR number. If you have direct ACE portal access, you can verify this yourself in the next step.

Step 2: Access the ACE Portal or Coordinate With Your Broker

The Automated Commercial Environment — ACE — is CBP’s electronic system for processing imports. All the data you need to build your refund claim lives here. You have two ways to get it: direct portal access or through your customs broker.

Direct ACE access

If your company has an ACE portal account, you can pull reports directly. Log in at ace.cbp.dhs.gov using your credentials. If you don’t have an account, you can request one, but the approval process takes 2-4 weeks — so if you’re starting from scratch, coordinating with your customs broker is faster.

Customs broker coordination

Most importers access their ACE data through their customs broker. Your broker has a portal account and can pull the reports you need on your behalf. If you’ve used multiple brokers during the IEEPA period, you’ll need to coordinate with each one separately.

Here’s the critical point: your broker works for you, and you are entitled to your own data. Some importers hesitate to ask for detailed reports because they don’t want to burden the relationship. Don’t hesitate. This data is yours, and pulling it is a standard service your broker provides. If your broker is unresponsive or charges excessive fees for data pulls, that’s a red flag worth addressing.

What you’re looking for

The specific report you need is the ES-003 — the Entry Summary report. You’ll pull this in the next step, but having portal access confirmed (either directly or through your broker) is a prerequisite. For a detailed breakdown of all required documentation, see our documentation guide.

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Step 3: Pull Your ES-003 Entry Summary Data

The ES-003 is the master report for your refund claim. It contains every entry summary filed during the IEEPA period, including HTS codes, duty amounts, entry dates, and — critically — liquidation status. This report is the raw material from which your entire claim is built.

How to pull it

In the ACE portal, navigate to Reports and select Entry Summary (ES-003). Set the date range to cover the full IEEPA period: February 4, 2025, through February 24, 2026. If you want to be thorough, extend the start date back to January 2025 to catch any entries that may have been filed just before the IEEPA tariffs took effect but were assessed IEEPA duties retroactively.

Key fields to capture

Your ES-003 report should include, at minimum:

Volume considerations

If you’re a mid-size or large importer, your ES-003 report may contain thousands of entry lines. That’s normal. The data volume is exactly why an organized, systematic approach matters — you can’t eyeball a 5,000-line spreadsheet and catch every deadline. For importers with over $1 million in estimated IEEPA exposure, the complexity of the data alone justifies professional support.

Data quality checks

Once you have the report, scan for obvious issues: missing HTS codes, entries with $0 duty amounts that shouldn’t be zero, or entries outside the IEEPA date range. These anomalies usually indicate data entry errors at the time of filing, and they’ll need to be resolved before you can submit a clean claim. Our guide on common mistakes that delay refunds covers the most frequent data quality issues.

Step 4: Identify IEEPA-Affected Entries

Not every entry in your ES-003 report is an IEEPA entry. You need to isolate the ones that are. This is where the HTS code filtering happens, and it’s where many importers make their first mistake by either including entries that aren’t IEEPA-related or missing entries that are.

Which HTS codes qualify

IEEPA tariffs were assessed under two HTS headings:

• 9903.01.xx — IEEPA tariffs on goods from China
• 9903.02.xx — IEEPA tariffs on goods from other countries (Canada, Mexico, EU, etc.)

Filter your ES-003 data to show only entry lines containing these headings. Every line with a 9903.01 or 9903.02 code represents an IEEPA duty assessment that is now refundable.

What’s NOT included

This is equally important. The following tariff programs are not affected by the Supreme Court ruling and are not refundable through this process:

• Section 301 tariffs (HTS 9903.88.xx) — China trade war tariffs from 2018-2019
• Section 232 tariffs (HTS 9903.80.xx) — Steel and aluminum tariffs
• Standard MFN duties — Normal most-favored-nation tariff rates
• Antidumping/Countervailing duties (AD/CVD) — Product-specific duties

A single entry may include both IEEPA duties and other tariff types. Only the IEEPA portion is refundable. This is why separating IEEPA duties from other tariff programs in your data is critical — commingling them in a claim submission will slow processing or trigger a rejection.

For a comprehensive overview of what qualifies and what doesn’t, see our complete guide to IEEPA tariff refunds.

Entry date range

Only entries with an entry date between February 4, 2025 (when the first IEEPA executive order took effect) and February 24, 2026 (four days after the Supreme Court ruling, when CBP suspended IEEPA assessments) are eligible. Entries outside this window, even if they contain 9903.01 or 9903.02 codes, require separate analysis.

Step 5: Calculate Your Estimated Exposure

With your IEEPA-affected entries isolated, you can now calculate your total estimated refund. This number drives every decision that follows — whether to file directly, engage professional support, or pursue immediate capital.

The basic calculation

Your estimated refund equals the sum of all IEEPA duties paid, plus statutory interest under 19 U.S.C. Section 1505(c). The interest accrues from the date of duty payment to the date of refund. For a detailed walkthrough of the interest calculation and worked examples at different exposure levels, see our refund calculation guide.

Quick estimation table

These are estimates. Actual amounts depend on the specific IEEPA rate that applied to your goods (which varied by country and changed multiple times during the period), the mix of products, and the timing of your entries. The only way to get an exact number is an entry-level analysis.

Why accuracy matters now

Your exposure number determines your recovery path strategy. Importers with under $100,000 in exposure may find the CAPE system sufficient. Importers with $500,000 to $5 million may want to combine CAPE filing with professional advisory support to ensure nothing falls through the cracks. Importers with over $5 million need a structured approach that accounts for protest deadlines, CAPE queue positioning, and potentially immediate capital on a portion of the claim.

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Step 6: Choose Your Recovery Path

You’ve confirmed your IOR status, pulled your data, isolated the IEEPA entries, and calculated your exposure. Now you need to decide how to actually recover the money. There are four distinct recovery paths, and most importers with significant exposure will use more than one.

Path selection by entry status

The hybrid approach

Here’s what this looks like in practice for a mid-size importer with $2 million in IEEPA exposure across 400 entry lines:

• 120 entries are still unliquidated → file PSCs through your customs broker
• 200 entries were liquidated in the last 90 days → file protests immediately to preserve the 180-day window
• 50 entries were liquidated more than 180 days ago → consult trade counsel about CIT litigation
• 30 entries with the highest individual duty amounts → consider immediate capital if you need the cash flow now

This hybrid approach maximizes recovery across your entire portfolio. The key is that each entry has its own status and its own optimal path — you can’t apply a single strategy to all of them.

When to engage professional support

If your total exposure exceeds $250,000, or if you have more than 100 affected entries, or if any entries are approaching their protest deadline, professional advisory support pays for itself. The cost of waiting or making a filing error is almost always higher than the cost of getting it right the first time.

Step 7: Submit Your Claim or Engage an Advisory Firm

This is where preparation meets execution. Depending on the path you chose in Step 6, your submission process looks different.

If you’re filing PSCs

Your customs broker handles this through the ACE portal. Provide them with your filtered IEEPA entry data and instruct them to file post-summary corrections removing the 9903.01 and 9903.02 HTS codes. PSCs on unliquidated entries are the fastest government path — processing typically takes days to weeks.

If you’re filing protests

Again, your customs broker files these through ACE. Each protest must reference the specific entry, cite the Supreme Court ruling in Learning Resources, Inc. v. Trump, and request reliquidation without IEEPA duties. File protests on every liquidated entry within the window — even protective protests that simply preserve your rights. The protest filing process has specific requirements that must be met for the protest to be valid.

If you’re filing through CAPE

CBP’s Centralized Adjustment and Processing Entity system is expected to launch in mid-April 2026. When it does, you’ll submit a declaration covering all your IEEPA entries. Having your data validated and formatted before launch day gives you the best possible queue position. Importers who wait until after launch to start preparing their data will join the back of a very long line.

If you’re pursuing immediate capital

Contact an advisory firm that works with institutional claim buyers. You’ll provide your validated IEEPA entry data, the buyer’s team will verify the claim, and you’ll receive an offer within 14-21 business days. Payment is non-recourse — once you’re paid, the buyer assumes all CBP processing risk.

If you’re engaging an advisory firm

For importers with significant exposure, a free Impact Assessment is the logical starting point. The assessment maps every entry’s status, calculates your total exposure including statutory interest, identifies approaching deadlines, and recommends the optimal recovery path for each entry. It’s the difference between filing blind and filing with precision.

What Happens After You File

Filing is not the end of the process. After submission, you’ll need to track your claim through CBP’s processing pipeline. Here’s what to expect:

For PSCs: Monitor the ACE portal for updated liquidation status. Processing is generally quick, but volume may slow things down as thousands of importers file simultaneously.

For protests: CBP has up to two years to respond. You can request accelerated disposition after 60 days — if CBP doesn’t respond within 30 days of that request, the protest is deemed denied, allowing you to escalate to the CIT.

For CAPE filings: CBP will process claims sequentially. Your queue position matters. The IEEPA tariff refund timeline provides the most current estimates for processing times.

For all paths: Statutory interest under 19 U.S.C. Section 1505(c) accrues until the date of refund, so delays are partially compensated. But as the CFO guide to IEEPA recovery explains, the statutory rate typically runs below your company’s cost of capital, meaning delay still has a real cost.

The Bottom Line

Filing an IEEPA tariff refund claim isn’t complicated, but it is detailed. Miss a step, misidentify an entry, or choose the wrong path, and you’re looking at months of delay or lost recovery rights. The seven steps above give you a clear roadmap from start to finish.

If you’d rather have professionals handle the data analysis, deadline tracking, and path optimization, that’s exactly what an Impact Assessment delivers — at no cost and no obligation.