Your customs broker is the single most important person in your IEEPA tariff refund recovery. They filed the original entries. They have access to your ACE data. They can file post-summary corrections on unliquidated entries. They can submit formal protests on liquidated entries. They interact with CBP daily and understand the system’s quirks in ways that no guide, no article, and no advisory firm can replicate.
But here’s the thing: your broker may not be doing any of this proactively. Many brokers are overwhelmed by the scale of the IEEPA refund event — they have hundreds or thousands of importer clients, all of whom are suddenly asking for the same data and the same filings at the same time. Others are unsure of their role in the CAPE process or are waiting for CBP to provide clearer guidance before taking action.
You can’t afford to wait for your broker to come to you. This guide shows you how to take the lead in coordinating with your broker on IEEPA recovery — what to ask for, what they can and can’t do, and how to handle common friction points.
What to ask your broker for (right now)
Don’t wait for the CAPE portal to open. There are several things your broker can provide or do today that will accelerate your refund:
1. ES-003 Entry Summary Details report
This is the single most important document for your IEEPA refund. The ES-003 report from ACE contains every entry summary line filed under your importer of record number, including HTS codes, duty amounts, and liquidation statuses.
Ask your broker to: Export the ES-003 for the full IEEPA period (February 4, 2025 through February 24, 2026), in CSV format, with all available fields. Specify that you need line-level detail, not a summary.
Timeline: Your broker should be able to pull this within 1-2 business days. If they say it will take weeks, push back. It’s a standard ACE report.
2. Liquidation status report
Not all entries in your ES-003 will have up-to-date liquidation information, depending on when the report was pulled. Ask your broker for a current liquidation status check on all IEEPA-period entries.
Ask your broker to: Identify which entries are unliquidated, which are liquidated (with dates), and which are approaching the 180-day protest window.
Why this matters: Unliquidated entries are eligible for Post-Summary Correction — the fastest refund path. Liquidated entries within 180 days need protective protests. Entries beyond 180 days have limited options. You need to know the status of every entry to build the right recovery strategy.
3. ACH enrollment confirmation
CBP disburses refunds via ACH (Automated Clearing House) electronic payment. If you’re not enrolled, no refund can be processed regardless of how quickly your CAPE claim is approved.
Ask your broker to: Confirm your current ACH enrollment status with CBP and, if you’re not enrolled, initiate the enrollment process.
4. Power of Attorney verification
If your broker will be filing CAPE claims or protests on your behalf, they need an active Power of Attorney on file with CBP.
Ask your broker to: Confirm that your POA is current and covers the specific activities needed for IEEPA recovery (entry amendments, protests, CAPE declarations). If the POA is expired or limited, execute a new one.
5. Prior Post-Summary Corrections
Some brokers have already filed PSCs on unliquidated entries to remove IEEPA duties. Others haven’t touched anything, waiting for CAPE.
Ask your broker to: Identify any entries where a PSC has already been filed to remove IEEPA duties, and the status of those PSCs. Entries with completed PSCs don’t need to go through CAPE — the refund is already in process.
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What your broker CAN do for IEEPA recovery
Understanding your broker’s capabilities helps you set the right expectations:
File Post-Summary Corrections (PSC)
For unliquidated entries, your broker can file a PSC through ACE to remove the IEEPA tariff codes (9903.01, 9903.02) and recalculate duties without the IEEPA surcharge. This is the fastest government refund path — PSCs can be processed in days to weeks.
Important: PSCs can only be filed on unliquidated entries. Once an entry liquidates, PSC is no longer available and you need to use the protest path.
File formal protests
For entries that have been liquidated within the last 180 days, your broker can file a formal protest under 19 U.S.C. Section 1514 challenging the liquidation. The protest requests reliquidation without IEEPA duties. This preserves your refund rights while CAPE is being built.
Your broker can also request accelerated disposition on the protest. If CBP doesn’t respond within 30 days of the accelerated request, the protest is deemed denied, which allows you to escalate to the Court of International Trade if needed.
File CAPE declarations (when portal opens)
When the CAPE portal goes live, your broker can file refund declarations on your behalf through the portal, using the same ACE credentials they use for daily entry filing.
Pull ACE reports and data
Your broker has direct access to ACE and can pull any report you need: ES-003 entry details, liquidation reports, duty payment records, and compliance histories. They can also check real-time entry statuses that may not appear in batch reports.
Coordinate with CBP on discrepancies
If there are data quality issues — duty amounts that don’t reconcile, HTS codes that need correction, entries with compliance holds — your broker can communicate directly with CBP’s import specialists at the port level to resolve them.
What your broker CAN’T do
There are important limitations:
CIT litigation
If entries are liquidated and beyond the 180-day protest window, the only remaining government path is litigation in the U.S. Court of International Trade. Brokers are not attorneys and cannot file CIT cases. You’ll need a trade attorney admitted to the CIT bar. Our partner network includes vetted CIT practitioners if you need a referral.
Claim assignment / immediate capital
If you want to assign your IEEPA claims to an institutional buyer for immediate payment, that’s a financial transaction outside the broker’s scope. Your broker provides the data; the claim assignment is handled separately.
Strategic advisory
Brokers are compliance experts, not financial strategists. They can tell you which entries qualify for refunds, but they typically won’t advise you on whether to file through CAPE, assign claims for immediate capital, or pursue CIT litigation. An Impact Assessment provides the strategic analysis that bridges the gap between broker data and recovery decisions.
Guarantee processing timelines
Your broker has no control over CBP’s processing speed. They can file PSCs, protests, and CAPE claims, but they can’t guarantee when CBP will process them. Setting realistic timeline expectations — based on the staffing math of 2,500 CBP staff for 330,000+ importers — helps avoid friction with your broker over things they can’t control.
How to handle multiple brokers
If you used different customs brokers for different entries during the IEEPA period — which is common for importers who ship through multiple ports, handle different product lines, or switched brokers mid-year — you need to coordinate across all of them.
The challenge
Each broker only has access to the entries they filed. Broker A can’t see the entries Broker B filed, even though they’re all under your IOR number. That means you need ES-003 data from each broker, and you need to aggregate it yourself (or have someone do it for you) to get a complete picture.
The solution
- Request ES-003 reports from every broker who filed entries during the IEEPA period
- Aggregate the data into a single master spreadsheet, standardizing field names and formats across brokers
- Check for gaps — compare the total entry count against your shipping records to make sure no entries are missing
- Assign responsibility — determine which broker will handle PSC/protest filings for which entries. Typically, the broker who filed the original entry handles the correction or protest for that entry.
- Coordinate timing — if you’re filing protests on entries approaching the 180-day window, make sure the responsible broker is aware of the deadline and has committed to filing in time
When brokers disagree
Occasionally, brokers have different opinions about classification, refund eligibility, or the best filing approach. If your brokers disagree, defer to the ACE data — it’s the authoritative record that CAPE will validate against. And if you’re unsure, an Impact Assessment provides an independent analysis that doesn’t depend on any single broker’s perspective.
Broker fees for IEEPA work
This is a conversation many importers find uncomfortable but need to have. Your broker will likely charge fees for IEEPA-related work, and the fee structure varies widely across the industry.
What to expect
- ES-003 report generation: Some brokers provide this at no charge; others charge $50-$200 per report
- Post-Summary Corrections: Typically $50-$150 per PSC filing, per entry
- Protest filings: Typically $200-$500 per protest, depending on complexity
- Hourly consultation: $100-$300/hour for broker time spent on data reconciliation, CBP communication, and IEEPA-related questions
- CAPE portal filing: TBD — brokers haven’t standardized fees for CAPE yet since the portal isn’t live
How to negotiate
Some brokers are offering IEEPA recovery services as flat-fee packages. Others are billing hourly. A few are offering contingency arrangements (percentage of refund recovered). There’s no industry standard yet, so you have room to negotiate.
Key negotiating points:
- Volume matters. If you have hundreds of entries, the per-entry cost should be lower than for an importer with five entries. Ask for volume discounts.
- Bundled services. If your broker is handling PSCs, protests, and CAPE filings, negotiate a package price rather than paying per action.
- Existing relationship. If you’ve been a client for years and represent significant ongoing revenue, your broker has an incentive to handle IEEPA work at competitive rates to retain your business.
- Competition. You can get IEEPA filing services from any licensed customs broker, not just your current one. If your current broker’s fees are unreasonable, shop around.
What’s reasonable
For a mid-size importer with 100-500 IEEPA entries, expect to spend $5,000-$25,000 in broker fees for comprehensive IEEPA recovery work (data pulls, PSCs, protests, CAPE filings). For a large importer with thousands of entries, the number will be higher but the per-entry cost should be lower.
Compare these fees against your potential refund. If you’re owed $500,000 in IEEPA duties plus interest, spending $15,000 on broker fees to ensure clean, timely filing is a high-ROI investment.
What to do if your broker isn’t proactive
Some importers have reached out to their brokers about IEEPA refunds and gotten… crickets. No data. No filings. No plan. Maybe a vague “we’re waiting for guidance from CBP” email from months ago.
If your broker isn’t moving, here’s a graduated escalation approach:
Level 1: Direct request with deadline
Send a specific, written request (email) listing exactly what you need and when. The template earlier in this article works well. Give a clear deadline — “I need the ES-003 report by [date]” — and explain that you’re preparing for CAPE portal filing.
Level 2: Escalate to management
If the front-line contact doesn’t respond or misses the deadline, escalate to their supervisor or the brokerage’s account management team. Be professional but firm: “I’ve requested my ES-003 data twice and haven’t received it. This is time-sensitive due to approaching protest deadlines. I need the data by [date] or I’ll need to explore alternatives.”
Level 3: Request direct ACE access
If the broker remains unresponsive, ask them to set up direct ACE portal access for your IOR number so you can pull reports yourself. As the importer of record, you have the right to access your own CBP data. The broker may need to assist with the account setup, but once you have access, you’re no longer dependent on them for data.
Level 4: Engage a second broker
You can authorize a second customs broker to access your ACE data and file on your behalf. This doesn’t require terminating your relationship with your current broker — you can have multiple brokers authorized simultaneously. If your current broker isn’t providing IEEPA services, a second broker who specializes in IEEPA recovery can step in.
Level 5: Independent data reconstruction
If all else fails, an Impact Assessment can work with whatever data you have available — shipping records, commercial invoices, accounts payable records — and cross-reference against publicly available CBP data to reconstruct your entry history. This isn’t the ideal approach (it’s slower and less precise than working from the ES-003), but it’s a viable fallback for importers whose brokers are uncooperative.
The broker-importer partnership for IEEPA
The most successful IEEPA recoveries we’ve seen follow a pattern: the importer takes the lead on strategy and timeline, while the broker executes the technical filings. The importer decides which recovery path to pursue for each entry, sets deadlines, and provides oversight. The broker pulls the data, files the PSCs and protests, prepares the CAPE declarations, and communicates with CBP.
This partnership works when both sides understand their roles:
| Your Role (Importer) | Broker’s Role |
|---|---|
| Define recovery strategy per entry | Pull ES-003 and liquidation data |
| Set filing deadlines and priorities | File PSCs on unliquidated entries |
| Review and approve filings | File protests on liquidated entries |
| Monitor progress and follow up | File CAPE declarations when portal opens |
| Make decisions on claim assignment vs. government filing | Coordinate with CBP on discrepancies |
| Fund broker fees | Provide data and compliance expertise |
The brokers who are most effective in IEEPA recovery are the ones whose importer clients give them clear direction and hold them accountable. The importers who get the fastest refunds are the ones who don’t wait for their broker to figure it out — they take charge of the process and use their broker as a skilled executor.
Template: initial IEEPA coordination email to your broker
Here’s a comprehensive email template you can customize and send to your broker today:
Subject: IEEPA Tariff Refund Coordination — Action Items and Timeline
Hi [Broker Name],
Following the Supreme Court ruling in Learning Resources, Inc. v. Trump and the CIT’s March 4 refund order, I’m preparing our IEEPA tariff refund claims for the upcoming CAPE portal launch (expected mid-April 2026). I’d like to coordinate with you on the following:
Immediate needs (this week):
- ES-003 Entry Summary Details report for all entries filed under our IOR [number] from February 4, 2025 through February 24, 2026, in CSV format with all fields
- Current liquidation status for all entries in that period
- Identification of any entries where the 180-day protest window closes within the next 60 days
- Confirmation of our ACH enrollment status
- Confirmation that our Power of Attorney is current and covers PSC, protest, and CAPE filings
Near-term actions (next 2 weeks): 6. File Post-Summary Corrections on all unliquidated IEEPA entries (9903.01, 9903.02) 7. File protective protests on all liquidated entries within the 180-day window 8. Identify any entries with prior PSCs that may have already addressed IEEPA duties
CAPE preparation: 9. Confirm your team will be ready to file CAPE declarations on our behalf when the portal launches 10. Provide your fee schedule for IEEPA-related services (PSCs, protests, CAPE filings, data reconciliation)
Please confirm receipt and provide an estimated timeline for items 1-5. This is time-sensitive — every day of delay affects our queue position when CAPE opens.
Thank you, [Your Name]
Customize this for your situation and send it today. The importers who are coordinating with their brokers now will be filing CAPE claims on day one. The ones who wait will be at the back of a very long line.
