The Supreme Court’s IEEPA ruling didn’t just create refund obligations for importers. It created a revenue opportunity for licensed customs brokers that has no precedent in scale. Over 330,000 importers need to recover $166 billion in unconstitutionally collected tariffs, and the vast majority of them will need their customs broker to execute at least part of the recovery. This is billable work — and for brokers who structure it correctly, it can become a significant new practice area.
This guide is for licensed customs brokers who want to understand the full scope of IEEPA recovery services they can offer, how to price them, and how to identify the highest-value opportunities in their existing client book.
The Scope of Billable Services
IEEPA recovery involves a defined set of customs brokerage activities. Each one is a service you can — and should — bill for.
ACE Data Extraction and Analysis
Every IEEPA recovery starts with data. Your clients need entry-level reporting from ACE showing which entries included IEEPA duty payments under HTS headings 9903.01 and 9903.02. Pulling ES-003 reports, cross-referencing against entry summaries, and organizing the data by liquidation status is professional work that deserves professional compensation.
Typical fee structure: Flat fee per client ($500-$2,500 depending on portfolio complexity) or hourly rate for data extraction and organization.
Client value: Most importers can’t access this data themselves. Even those with ACE portal access rarely know how to query for IEEPA-specific entries. Your expertise in navigating the system is the bottleneck they need you to clear.
Post-Summary Corrections (PSC)
For unliquidated entries, you file PSCs through ACE to remove IEEPA tariff codes. This is the fastest government recovery path — CBP processes corrected entries in days to weeks. It’s also a routine filing that’s well within your standard service scope.
Typical fee structure: Per-PSC filing fee ($100-$500 per entry, volume-discounted) or flat fee for batch processing across multiple entries.
Client value: PSC is the simplest and fastest path to refund for eligible entries. Clients with unliquidated entries should be PSC-filing immediately. If you haven’t proactively offered this service to your IEEPA-affected clients, you’re leaving revenue on the table — and your clients are losing time in the CAPE queue.
Protest Preparation and Filing
For liquidated entries within the 180-day protest window, you prepare and file formal protests under 19 U.S.C. Section 1514. This requires identifying the specific entries, preparing the protest documentation, citing the Supreme Court ruling and CIT order as legal basis, and filing through ACE.
Typical fee structure: Per-protest filing fee ($250-$1,000) or flat fee per client for batch protest filing. Some brokers charge a premium for accelerated disposition requests.
Client value: The 180-day window is a hard deadline. Clients who miss it lose administrative recovery options and are pushed to CIT litigation — which is slower, more expensive, and requires trade counsel. Your proactive protest filing literally saves them from a worse outcome.
CAPE Filing Preparation
When CBP’s CAPE system launches (projected mid-April 2026), validated claims need to be submitted in the required format. Preparing client data for CAPE submission — verifying entry details, organizing documentation, formatting for electronic submission — is a distinct service.
Typical fee structure: Flat fee per client for CAPE preparation ($1,000-$5,000 depending on portfolio size) or percentage of validated claim value (0.5-2%).
Client value: CAPE is first-come, first-served. Clients whose data is prepared and ready for Day 1 submission get processed before clients who start preparing after launch. Your preparation work directly affects their queue position and, consequently, how quickly they get paid. The complete IEEPA guide explains the CAPE process in detail.
Client Advisory and Consulting
Beyond the filing work, many clients need guidance on which recovery path applies to which entries, whether to pursue government filing or immediate capital, and how to coordinate between PSC, protest, and potential CIT litigation. This advisory role is distinct from the mechanical filing work and should be billed accordingly.
Typical fee structure: Hourly consulting rate ($150-$350/hour) or flat advisory fee per engagement.
Client value: Without guidance, clients often apply the wrong recovery mechanism to the wrong entries, miss deadlines, or make suboptimal decisions about timing. Your expertise prevents costly mistakes. For example, a client who files all entries through CAPE without first checking for unliquidated entries misses the opportunity to recover immediately via PSC. A client who waits for CAPE launch without monitoring protest deadlines may lose administrative recovery rights on their earliest entries. Your advisory role prevents these errors.
Get your free Impact Assessment →
Identifying Your Highest-Value Clients
Not every client in your book represents the same IEEPA recovery opportunity. Here’s how to prioritize.
Step 1: Pull Your IEEPA Entry Summary
Run a report across your client base for the IEEPA period (February 4, 2025 — February 24, 2026). Identify all entries with duty payments under HTS headings 9903.01 and 9903.02. Sum the IEEPA duty amounts by client.
Step 2: Rank by IEEPA Duty Volume
Sort your client list by total IEEPA duties paid, highest to lowest. Your top 20% of clients by IEEPA volume likely account for 70-80% of the total recovery opportunity in your book. These are your priority outreach targets.
Step 3: Assess Liquidation Status
For your top clients, check the liquidation status of their IEEPA entries. Clients with mostly unliquidated entries are PSC-ready now. Clients with recently liquidated entries need protests filed before the 180-day window closes. Clients with entries approaching the window deadline need immediate attention.
Step 4: Flag Deadline-Critical Accounts
Any client with entries where the 180-day protest window expires within the next 90 days should be flagged for urgent outreach. Missing the window on a $200,000 entry because nobody checked the liquidation date is a client relationship problem you don’t want.
| Priority Level | IEEPA Duties | Liquidation Status | Action |
|---|---|---|---|
| Urgent | Any amount | Window closing within 90 days | File protests immediately |
| High | $500K+ | Mix of unliquidated and liquidated | PSC + protests + CAPE prep |
| Medium | $100K-$500K | Mostly unliquidated | PSC filing + CAPE prep |
| Standard | <$100K | Any status | Batch processing |
Client Outreach Template
You don’t need to write a research paper. A concise, specific communication gets the best response. Here’s a framework:
Subject: IEEPA Tariff Refund — Your Account
Body:
“Based on our review of your import entries for the period February 2025 through February 2026, your company paid approximately $[X] in IEEPA tariff duties that are now refundable following the Supreme Court’s ruling.
We’ve identified [Y] entries eligible for immediate post-summary correction and [Z] entries that require protest filing within the 180-day window. The earliest protest deadlines for your entries are [date].
We recommend the following next steps:
- PSC filing on [Y] unliquidated entries — estimated refund: $[amount]
- Protest filing on [Z] liquidated entries — estimated refund: $[amount]
- CAPE preparation for Day 1 submission — covers all entries
Our fee for this work is $[amount]. Please confirm by [date] so we can begin processing before any protest deadlines expire.
If you’d like a more detailed analysis of your recovery options, including a comparison of government filing versus immediate capital options, a confidential Impact Assessment can be arranged at no cost.”
Revenue Projection for Your Brokerage
Let’s put rough numbers on the opportunity. Assume you have 200 clients with IEEPA exposure, averaging $250,000 in refundable duties per client. That’s $50 million in total IEEPA duties across your book.
| Service | Fee per Client | Clients Served | Total Revenue |
|---|---|---|---|
| ACE data extraction | $1,000 | 200 | $200,000 |
| PSC filings (avg 10/client) | $2,000 | 150 | $300,000 |
| Protest filings (avg 5/client) | $1,500 | 100 | $150,000 |
| CAPE preparation | $2,500 | 200 | $500,000 |
| Advisory consulting | $1,000 | 50 | $50,000 |
| Total | $1,200,000 |
These are conservative estimates. Larger brokerages with more clients and higher IEEPA concentrations (especially those with heavy China trade lanes) could see multiples of these numbers. The key is that this revenue is incremental — it comes on top of your existing service fees and requires expertise you already have.
Client Communication Strategy
How you communicate about IEEPA recovery matters as much as what you communicate. Here’s a framework for different client segments.
For Your Largest Accounts ($500K+ IEEPA Exposure)
These clients deserve a personal phone call and a dedicated meeting. Come prepared with their specific entry data: total IEEPA duties, entry count, liquidation status breakdown, and approaching deadlines. Present a clear service proposal with pricing. These conversations should happen this week.
Large accounts are also the most likely to be approached by competitors — other brokers, advisory firms, and trade attorneys who identify them from public import records. Being first to the conversation establishes your position as the recovery partner. Being second means you’re playing catch-up.
For Mid-Tier Accounts ($100K-$500K)
Email with a specific data summary, followed by a phone call. These clients are unlikely to have done the analysis themselves, so showing them their approximate exposure gets their attention. Offer a 30-minute call to walk through the recovery options and your proposed service plan.
For Smaller Accounts (<$100K)
A well-crafted email with a general overview and an offer to review their specific situation. Consider batch processing options that allow you to serve these clients efficiently at a lower per-client cost. Many of these clients will be the most surprised to learn they have meaningful refunds — and the most grateful when you help them recover.
Communication Timing
Don’t wait until you have perfect information. A preliminary communication that says “based on our initial review, you may be owed approximately $X in IEEPA refunds, and we’d like to schedule time to discuss the details” is more effective than waiting weeks to produce a comprehensive analysis. Speed of communication signals that you’re on top of the situation and looking out for their interests.
Staffing and Capacity Planning
IEEPA recovery work is incremental to your normal brokerage operations. If you’re going to treat it as a practice area — and you should — plan for the workload.
Data Extraction
Pulling ES-003 reports and organizing entry-level data for 200 clients takes time. Depending on your system and staffing, budget 20-40 hours of analyst time for the initial data extraction across your full client base. This front-loaded investment pays for itself many times over in billable services.
Filing Volume
If you’re filing PSCs and protests across 200 clients with an average of 15 entries each, that’s 3,000 filings. Even with batch processing, this is significant filing volume that needs to be scheduled and staffed. Consider whether you need temporary support during the initial filing wave.
Client Communication
Each client conversation — from initial outreach through service agreement to filing confirmation — takes 2-4 hours of staff time. For 200 clients, that’s 400-800 hours spread over several weeks. Assign dedicated staff to client communication rather than adding it to everyone’s existing workload.
Referral Partnerships for Claims Beyond Your Scope
Some recovery work falls outside standard customs brokerage — CIT litigation for entries outside the protest window, claim assignment for immediate capital, and complex multi-path recovery strategies for large portfolios. Rather than turning this work away, structure referral partnerships with trade attorneys and advisory firms who handle these services.
The partner program provides a framework for customs brokers who want to:
- Refer clients with entries past the protest window to CIT-qualified trade attorneys
- Connect clients interested in immediate capital with institutional claim buyers
- Access Impact Assessment services for clients who need comprehensive recovery planning
Referral fees are standard in these arrangements. You keep the filing work that’s within your scope and earn additional revenue on the work that isn’t.
The Competitive Imperative
Here’s the part that matters most: if you don’t proactively offer IEEPA recovery services to your clients, someone else will. Advisory firms, trade attorneys, and other brokers are actively reaching out to importers — including your clients — with recovery offers. The broker who moves first on a client account establishes the advisory relationship for this entire recovery cycle.
Conversely, clients who discover their IEEPA refund opportunity from someone other than their broker will wonder why their broker didn’t raise it first. That’s a trust erosion you can prevent by being proactive.
The cost of waiting applies to brokers as much as importers. Protest deadlines expire. Queue positions fill. And the window for establishing yourself as the go-to IEEPA recovery resource in your market narrows with each passing week.
Structuring This as a Practice Area
IEEPA recovery isn’t a one-time project. The processing timeline will stretch 18-36 months. During that period, you’ll be managing CAPE filings, monitoring processing status, handling supplemental documentation requests from CBP, and advising clients on evolving options. This is a practice area — a sustained revenue stream — not a favor.
Structure it accordingly:
- Create a standard service menu with clear pricing for each IEEPA recovery service
- Assign dedicated staff to IEEPA recovery work (even if it’s part-time initially)
- Track metrics — clients served, total duties recovered, revenue generated, deadlines managed
- Communicate regularly with clients about their recovery status, CAPE processing updates, and any new developments
Marketing and Visibility
Consider creating IEEPA recovery content for your client communications: email newsletters, webinar invitations, LinkedIn posts, and FAQ documents. Position your brokerage as the expert resource for IEEPA recovery in your market. The brokerages that establish thought leadership on this topic will attract clients from competitors who are slower to respond.
You can also create an IEEPA resource page on your website with general information, a contact form for clients who want to discuss their exposure, and links to educational content like the complete IEEPA guide and eligibility information.
Quality Assurance
IEEPA recovery filings carry the same accuracy requirements as any customs filing. Errors in PSCs or protests can delay processing, trigger CBP review, or result in incorrect refund amounts. Build quality checks into your filing workflow: verify entry numbers against ACE records, confirm IEEPA duty calculations match the tariff schedules, and double-check liquidation dates before filing protests.
The brokerages that treat IEEPA recovery as a strategic practice area will capture the most revenue and build the strongest client relationships. The ones that treat it as ad hoc work will leave both on the table.
[Help your clients find out what they’re owed — no cost, no obligation.]
