Your IEEPA tariff refund recovery path depends entirely on one thing: the liquidation status of each affected entry. Unliquidated entries go through Post-Summary Correction. Liquidated entries within the 180-day window go through formal protest. Finally liquidated entries require CIT litigation. You can’t choose the right path if you don’t know the status.
The good news: this information is available right now in CBP’s Automated Commercial Environment (ACE) portal. You don’t need to wait for your broker. You don’t need to hire an attorney. You don’t need to wait for CAPE. If you have ACE access, you can check your liquidation status today.
This guide walks you through the process step by step — from logging into ACE to interpreting the status codes and understanding what each one means for your recovery.
Before You Start: What You’ll Need
ACE Portal Access
The ACE portal is CBP’s web-based system for managing import transactions. If you’re the importer of record and have been filing entries, you likely already have an ACE account. If you’re not sure, check with your customs broker — they may have set up access on your behalf.
ACE Portal URL: https://ace.cbp.dhs.gov
You’ll need your ACE user ID and password. If you’ve never logged in, or if your credentials have expired, you’ll need to reset them through the ACE helpdesk or your broker.
Your Importer of Record Number
This is your IRS Employer Identification Number (EIN) or your CBP-assigned importer number. You’ll use this to filter entry data to your specific import activity.
HTS Codes to Filter
IEEPA tariffs were assessed under HTS headings 9903.01 and 9903.02. These are the tariff codes you’ll filter for to isolate IEEPA-affected entries from your broader import activity.
Time Frame
IEEPA tariffs were collected from February 4, 2025, through February 24, 2026. You’ll want to pull data covering this entire period to capture all affected entries.
Step 1: Log Into the ACE Portal
Navigate to https://ace.cbp.dhs.gov in your web browser. ACE works best in Chrome or Edge. Some older browsers may have compatibility issues with certain report features.
Enter your ACE user credentials. If you have multi-factor authentication enabled (and you should), complete the verification step. You’ll land on the ACE Secure Data Portal home screen.
If you can’t log in, don’t panic. The most common issues are:
- Expired password: ACE passwords expire periodically. Use the “Forgot Password” link to reset.
- Locked account: Multiple failed login attempts will lock your account. Contact the ACE helpdesk at (866) 530-4172.
- No account: If you’ve never had ACE access, you’ll need to register. This takes 5-10 business days. In the meantime, your customs broker can pull the data for you.
Step 2: Navigate to Entry Summary Reports
Once logged in, you need to get to the Entry Summary section where liquidation data lives.
From the ACE home screen:
- Click on “Reports” in the main navigation menu
- Select “Entry Summary Reports” from the dropdown
- You’ll see a list of available report types
The report you want is the ES-003 Entry Summary Details report. This is the most comprehensive entry-level report available in ACE, and it includes the liquidation status field you need.
If you don’t see the ES-003 option, your account permissions may not include entry summary reporting. Contact your ACE account administrator or your customs broker to request the appropriate role assignment.
Step 3: Configure Your Report Parameters
When you select the ES-003 report, you’ll be prompted to set filter parameters. Configure them as follows:
Date Range: Set the start date to February 1, 2025 and the end date to February 28, 2026. This captures all entries that could have been subject to IEEPA tariffs, with a small buffer on each end.
Importer of Record: Enter your EIN or CBP importer number. This ensures you’re only seeing your own entries.
Entry Type: Select “01 - Consumption” and “06 - Consumption - FTZ” if applicable. These are the standard entry types for imported goods subject to duty.
HTS Code Filter: This is critical. Enter 9903.01 and 9903.02 to filter for entries with IEEPA tariff codes. Some ACE interfaces allow wildcard filtering (9903.01* and 9903.02*) to capture all sub-headings.
If the HTS code filter isn’t available at the report configuration stage, you can pull the full report and filter in the next step.
Output Format: Select CSV or Excel format. You’ll want a spreadsheet-compatible format for analysis and deadline calculation.
Click “Generate Report” or “Run Report.” Depending on the volume of entries, this may take a few seconds to several minutes.
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Step 4: Identify the Liquidation Status Field
Once your report generates, open it in Excel or Google Sheets. You’ll see a row for each entry summary, with columns for various data fields.
The columns you need to focus on:
| Column | What It Contains | Why It Matters |
|---|---|---|
| Entry Number | Unique identifier for each import entry | Identifies the specific entry |
| Entry Date | Date the entry was filed with CBP | Determines when liquidation clock started |
| HTS Number | Harmonized Tariff Schedule code | Confirms IEEPA tariff was assessed |
| Duty Amount | Total duty assessed on the entry | Shows how much was paid, including IEEPA |
| Liquidation Date | Date CBP finalized the entry (if applicable) | Starts the 180-day protest clock |
| Liquidation Type | How the entry was liquidated | Indicates whether it was routine or by operation of law |
| Liquidation Status | Current status of the entry | This is the key field |
The Liquidation Status field is what you’re after. It will show one of several values.
Step 5: Interpret the Status Codes
ACE uses specific status codes and descriptions for liquidation. Here’s what each one means for your IEEPA refund:
Status: “Open” or “Unliquidated”
What it means: CBP has not yet finalized the duty assessment for this entry. The entry is still in provisional status.
What it means for your refund: This is the best-case scenario. You can file a Post-Summary Correction (PSC) through your customs broker to remove the IEEPA tariff codes. PSC is the fastest recovery path — processing typically takes days to weeks. No protest needed. No CAPE queue. No litigation.
Your next step: Contact your customs broker and request PSC filings on all unliquidated IEEPA entries immediately. Don’t wait — these entries could liquidate at any time, at which point the PSC option closes.
Status: “Liquidated”
What it means: CBP has finalized the duty assessment. The entry has been processed and duties are considered assessed.
What it means for your refund: You need to check whether the entry is within the 180-day protest window. Look at the Liquidation Date column. Add 180 days. If today’s date is before that deadline, you can file a formal CBP protest.
Your next step: Calculate the 180-day deadline for each liquidated entry. Prioritize entries with the nearest deadlines. File protests through your customs broker or trade attorney before the window closes.
Status: “Liquidated by Operation of Law”
What it means: The entry was automatically liquidated because CBP didn’t take action within the statutory timeframe (typically 314 days, but CBP can extend). The entry is liquidated at the rate originally assessed.
What it means for your refund: Same as “Liquidated” — check whether you’re within the 180-day protest window. The recovery path is the same regardless of whether liquidation was active (CBP reviewed it) or passive (operation of law).
Your next step: Same as above. Calculate your 180-day deadline and file a protest if within the window.
Status: “Extended Liquidation” or “Suspended Liquidation”
What it means: CBP has either extended the standard liquidation timeline or suspended liquidation entirely. This can happen for entries under audit, investigation, or subject to a court order.
What it means for your refund: The entry remains unliquidated. The PSC path may still be available. However, extended or suspended entries may have additional complications. Consult with your customs broker to understand why the extension or suspension was applied.
Your next step: Verify with your broker whether PSC filing is appropriate. In some cases, the extension may be related to the IEEPA situation itself, which could simplify recovery.
Status: “Protested”
What it means: A formal protest has already been filed on this entry. This could be a protest you or your broker filed, or it could be a protest filed by another party (if there are multiple parties to the entry).
What it means for your refund: Good news — the entry is protected. A protested entry remains “not final” and stays within the scope of the CIT’s universal refund order. No further action is needed to preserve your rights, though you should monitor the protest status.
Your next step: Verify that the protest correctly references the IEEPA tariff issue and the Supreme Court ruling. If the protest was filed for a different reason, you may need to file an additional protest specifically addressing IEEPA duties.
Status: “Finally Liquidated”
What it means: The entry has been liquidated and the 180-day protest window has expired without a protest being filed. The duty assessment is final and conclusive.
What it means for your refund: The administrative paths (PSC and protest) are no longer available. Your only option is CIT litigation under 28 U.S.C. Section 1581(i), which has a two-year statute of limitations.
Your next step: Consult a trade attorney admitted to the CIT bar. The partner network includes vetted CIT practitioners if you need a referral.
Step 6: Build Your Entry Status Summary
Once the status field is visible, the path choice becomes operational. Unliquidated entries move to PSC, liquidated entries move to protest analysis, and finality pushes the claim into litigation territory.
Now that you understand the status codes, organize your data into a summary table. For each IEEPA-affected entry, record:
| Entry # | Entry Date | IEEPA Duty Paid | Liquidation Status | Liquidation Date | Protest Deadline | Recovery Path |
|---|---|---|---|---|---|---|
| 001 | 2/15/2025 | $12,450 | Liquidated | 12/22/2025 | 6/20/2026 | Protest |
| 002 | 3/03/2025 | $8,200 | Unliquidated | — | — | PSC |
| 003 | 4/18/2025 | $23,100 | Liquidated | 2/25/2026 | 8/24/2026 | Protest |
| 004 | 2/10/2025 | $6,800 | Finally Liquidated | 12/15/2025 | Expired | CIT |
This summary becomes your recovery roadmap. Sort by protest deadline (earliest first) to identify your most urgent entries. Sum the IEEPA duty amounts by recovery path to understand your total exposure under each mechanism.
The unliquidated vs. liquidated entries guide explains in detail what each status means for your recovery strategy.
Step 7: Calculate Your Total IEEPA Exposure
While you have the data open, calculate your total IEEPA tariff exposure. Sum the duty amounts for all entries with HTS codes under 9903.01 and 9903.02.
Important distinction: The total duty amount on an entry may include non-IEEPA duties (standard tariffs, Section 301 duties, antidumping/countervailing duties, etc.). You want to isolate the IEEPA-specific portion. In the ES-003 report, look for duty amounts associated specifically with the 9903 HTS codes.
If you’re having trouble isolating the IEEPA-specific amounts, your customs broker can help parse the data. An Impact Assessment does this calculation automatically as part of the analysis.
If You Don’t Have ACE Access
Not every importer has direct ACE portal access. If you fall into this category, here are your options:
Ask Your Customs Broker
This is the fastest alternative. Your broker has ACE access and can pull ES-003 reports on your behalf. Send them a clear request:
“Please pull an ES-003 Entry Summary Details report for all entries filed between February 1, 2025, and February 28, 2026, with HTS codes beginning with 9903.01 and 9903.02. I need entry numbers, entry dates, HTS codes, duty amounts, liquidation status, and liquidation dates. Please deliver in CSV or Excel format.”
Most brokers can deliver this within 2-5 business days.
Register for ACE Access
If you want direct access going forward, you can register for an ACE account through CBP’s online system. The process involves:
- Visit the ACE Secure Data Portal registration page
- Complete the online application with your company information and EIN
- Designate an account owner (typically a compliance officer or logistics manager)
- Submit the application
- Wait for CBP approval — typically 5-10 business days
- Receive your login credentials and set up multi-factor authentication
Note that ACE access requires a valid importer of record number and may require additional verification for first-time registrants.
Request an Impact Assessment
If you’d rather skip the ACE navigation entirely, an Impact Assessment pulls and analyzes all of this data for you. You provide basic company information and a power of attorney for data access, and the assessment team handles the ACE data pull, analysis, status mapping, deadline calculation, and recovery path recommendations.
This is often the most practical option for importers who aren’t familiar with ACE reporting or who have large portfolios requiring comprehensive analysis.
Common ACE Issues and Troubleshooting
Missing Entries in Your Report
If your report seems to be missing entries you know exist, check your filter parameters. Common causes:
- Date range too narrow: Expand the date range to capture all IEEPA-period entries
- Wrong importer number: Verify you’re using the correct EIN or CBP importer number
- Entry type filter: Make sure you’ve included all relevant entry types (01, 06, etc.)
- HTS code filter: Some entries may have the IEEPA code as a secondary heading rather than the primary. Try running without the HTS filter and searching manually
Liquidation Status Shows “N/A” or Is Blank
Some entries may not display a clear liquidation status. This typically means the entry is unliquidated and CBP hasn’t processed it yet. Confirm with your broker.
Report Takes Too Long or Times Out
Large portfolios can generate massive reports. If your report is timing out:
- Break the date range into smaller segments (e.g., monthly)
- Remove non-essential columns from the report configuration
- Try running the report during off-peak hours (early morning or late evening Eastern time)
Data Doesn’t Match Your Records
Discrepancies between ACE data and your internal records may indicate corrections, amendments, or data entry issues. Flag these for your broker to investigate before filing any recovery actions.
What to Do With Your Results
Once you have your status summary:
- File PSCs immediately on all unliquidated entries — these are your fastest-track refunds
- File protests on all liquidated entries within the 180-day window, starting with the nearest deadlines
- Consult CIT counsel for any finally liquidated entries
- Consider immediate capital for entries where you’d rather have cash now than wait 18-36 months — claim assignment delivers payment in 14-21 days
- Calculate your total exposure and model recovery under each path using the CFO guide framework
The four recovery paths overview provides the complete framework for matching each entry to its optimal recovery mechanism.
