Your First 48 Hours After Deciding to Pursue IEEPA Recovery

You’ve decided to pursue your IEEPA tariff refund. The Supreme Court’s 6-3 ruling in Learning Resources, Inc. v. Trump invalidated all IEEPA tariffs collected between February 4, 2025, and February 24, 2026. The money is legally yours. Now the question is execution — and the first 48 hours set the tone for everything that follows.

This isn’t a complicated process, but it’s a sequenced one. Do things in the wrong order and you’ll waste a week chasing documents you didn’t need yet. Do them in the right order and you’ll have a clear picture of your recovery within two business days.

Here’s exactly what to do, hour by hour.

Hours 0–4: Establish Your Internal Authority

Before you touch a single document, make sure you have organizational buy-in. IEEPA recovery touches finance, operations, logistics, and legal. If you start pulling data without telling anyone why, you’ll create confusion and slow yourself down.

Identify Your Decision Maker

Someone needs to own this process. In most companies, that’s the CFO or VP of Finance. In smaller operations, it might be the controller or even the CEO. Whoever it is, they need to know three things:

• The opportunity exists. The Supreme Court ruled IEEPA tariffs unconstitutional. Every dollar paid under those tariffs between February 2025 and February 2026 is refundable.
• There are deadlines. The 180-day protest window is already running on some liquidated entries. Missing it means more expensive recovery options.
• The first step costs nothing. A free Impact Assessment quantifies your exposure without any commitment.

If you need help framing this for senior leadership, we’ve written a dedicated guide on how to explain IEEPA recovery to your board that condenses the key points into a five-minute presentation.

Send the Internal Notification

Draft a brief email to your CFO, controller, and logistics lead. Keep it factual: the ruling happened, refunds are available, you’re gathering preliminary data to assess the opportunity. Don’t oversell. The numbers will speak for themselves once you have them.

You’ll also want to loop in whoever manages your customs broker relationship. That person will be critical in the next phase when you request specific reports.

Check for Existing Recovery Efforts

Before you go further, confirm that no one else in your organization has already started this process. In larger companies, trade compliance teams sometimes initiate protests independently. Your customs broker may have already taken preliminary steps. A quick check prevents duplicate efforts and potential conflicts.

Hours 4–8: Contact Your Customs Broker

Your customs broker is the single most important external relationship in this process. They have access to your import data through the ACE portal, and they can pull the reports you need to quantify your exposure.

What to Ask For

You need three things from your broker:

1. Your ES-003 Report. This is the entry summary status report from ACE. It shows every entry filed during the IEEPA period, along with the liquidation status of each one. Unliquidated entries follow one recovery path; liquidated entries follow another. You can’t plan your recovery strategy without knowing which entries fall into which category.

2. A list of entries with IEEPA-specific HTS codes. The tariff codes under HTS headings 9903.01 and 9903.02 are the ones that generated IEEPA duties. Your broker can filter for these codes to isolate the relevant entries from your broader import portfolio.

3. Total IEEPA duties paid. This is the headline number — the total amount you paid in IEEPA tariffs during the covered period. It’s the starting point for calculating your refund.

We’ve created a template email you can send your customs broker that covers exactly what to request and why. Copy, paste, customize, send. It saves you the time of figuring out the right terminology.

What to Expect Back

Most brokers can pull ACE data within 24-48 hours. Some will have questions about the scope of your request. Be prepared to clarify the date range (February 4, 2025, through February 24, 2026) and the specific HTS headings you’re interested in.

If your broker isn’t familiar with the IEEPA recovery process, that’s not unusual — this is a new area for everyone. Point them to the customs broker guide to IEEPA recovery for background.

Multiple Brokers?

If you’ve used different customs brokers for different ports, product lines, or time periods, you’ll need data from all of them. This is common for mid-size and large importers. Make a list of every broker relationship and send the request to each one simultaneously. Don’t do this sequentially — you’ll lose days.

Hours 8–16: Gather Your Internal Records

While your broker is pulling ACE data, you can start assembling internal records that will speed up your Impact Assessment.

Financial Records to Locate

Pull these documents into a single folder (physical or digital):

You don’t need perfect records at this stage. The goal is to know where things are so you can produce them quickly when needed. Our data preparation guide goes deeper on what to gather and how to organize it.

Create Your Entry Inventory

Start a simple spreadsheet with one row per entry. Columns should include:

• Entry number
• Entry date
• Port of entry
• Country of origin
• IEEPA duty amount
• Liquidation status (fill in when broker data arrives)
• Protest deadline (calculate when liquidation dates are known)

This spreadsheet becomes your master tracking document throughout the recovery process. It’s also what you’ll share during your Impact Assessment to get the most precise analysis possible.

Flag Time-Sensitive Entries

If you know or suspect that some of your entries liquidated in late 2025 or early 2026, those may have protest deadlines approaching. Flag these for priority attention. A missed protest deadline doesn’t eliminate your recovery options, but it moves you to the more expensive CIT litigation path.

Hours 16–24: Request Your Impact Assessment

With your internal records gathered and your broker data request in progress, you’re ready to request a professional assessment of your recovery options.

Why an Assessment Matters

An Impact Assessment isn’t a sales pitch. It’s an analytical exercise that produces a specific deliverable: a detailed breakdown of your IEEPA exposure, organized by recovery path, with estimated timelines and dollar amounts for each.

Here’s what the assessment covers:

• Total IEEPA duties paid across all entries
• Entry-by-entry status — unliquidated vs. liquidated, protest windows remaining
• Recommended recovery path for each entry category (PSC, protest, CIT, or immediate capital)
• Estimated timeline for each path
• Net recovery projections accounting for costs and time value

You can read the full walkthrough of what to expect during an assessment for more detail on the process and deliverables.

Submitting the Request

Go to tariffresolution.com/assessment and complete the intake form. You’ll need your company name, estimated annual import volume, primary countries of origin, and a brief description of what you import. You don’t need your broker data in hand yet — the assessment team will work with whatever you have and request specifics as needed.

Response time: You’ll hear back within one business day with a confirmation and any follow-up questions.

What You Don’t Need Yet

Don’t wait until you have every document perfectly organized. The assessment process is iterative. Submit the request with what you know now, and provide additional data as it becomes available. Perfectionism at this stage only costs you time — and time has real costs in this process.

Hours 24–36: Review Broker Data and Refine Your Position

By now, your customs broker should be returning initial data. When it arrives, cross-reference it against your internal records.

Reconciliation Checklist

• Entry counts match. Does the number of entries in the ACE data match your internal records?
• Duty amounts align. Do the IEEPA duty amounts from ACE match what you show in accounts payable?
• Dates are correct. Are all entries within the February 4, 2025, to February 24, 2026, window?
• Liquidation statuses are clear. Can you clearly identify which entries are liquidated and which are not?

Discrepancies at this stage are normal. Timing differences between when duties were assessed and when they were paid, entries that span the start or end of the IEEPA period, and entries where IEEPA duties were combined with other duty types can all create confusion. Document the discrepancies — the assessment team will help resolve them.

Calculate Your Preliminary Exposure

Add up the IEEPA duties on all qualifying entries. This is your gross recovery amount. For context, the average mid-market importer we’ve assessed has between $200,000 and $2.5 million in recoverable IEEPA duties, though some are significantly higher.

Compare this number against the four recovery paths to understand which options apply to your specific portfolio:

• Unliquidated entries → Post-Summary Correction (fastest, lowest cost)
• Recently liquidated entries → Formal CBP Protest (time-sensitive)
• Entries past protest deadline → CIT Litigation (most expensive)
• Any entries → Immediate capital through claim assignment (fastest cash, discounted)

Hours 36–48: Build Your Recovery Roadmap

With data in hand and an assessment underway, your final step in the first 48 hours is to outline your recovery roadmap.

Prioritize by Deadline

The single most important prioritization factor is deadline proximity. Entries approaching their 180-day protest window need action first, regardless of dollar amount. A $10,000 entry with a deadline next month matters more right now than a $500,000 unliquidated entry that can be corrected at any time.

Assign Responsibilities

Map out who does what:

Set Your Decision Timeline

Don’t let this process drift. Set a specific date — ideally within two weeks of your assessment results — to make a decision on your recovery strategy. The longer you deliberate, the more the cost of waiting compounds. CAPE is projected to launch mid-April 2026, and your filing position in the queue depends on being prepared before that date.

Common Mistakes in the First 48 Hours

Having guided hundreds of importers through this process, we see the same missteps repeatedly.

Waiting for perfect data. Your data will never be perfect. Start with what you have and refine as you go. The assessment process is designed to handle incomplete information.

Skipping the broker conversation. Some importers try to reconstruct their import history from internal records alone. This always takes longer and produces less accurate results than starting with ACE data.

Not checking for approaching deadlines. The protest window doesn’t wait for you to get organized. If any of your entries liquidated more than 90 days ago, you may have less time than you think.

Trying to do everything yourself. The DIY vs. professional advisory comparison shows that professional guidance typically pays for itself through avoided mistakes, faster timelines, and higher recovery rates. At minimum, get an assessment before deciding to go it alone.

Overthinking the decision. The first 48 hours are about gathering information, not making final commitments. You’re not signing anything, paying anything, or committing to anything. You’re getting clarity on what you’re owed and how to get it.

Special Situations: What If Your Case Isn’t Standard

Not every importer’s first 48 hours look the same. Here are adjustments for common non-standard situations.

You Changed Brokers During the IEEPA Period

If you switched customs brokers between February 2025 and February 2026, you have entries filed by at least two different brokers. Both need to provide data. Your former broker is still obligated to provide ACE data for entries they filed during your relationship — this is your data, not theirs.

Contact both brokers simultaneously in hour 4, not sequentially. Your former broker may be less responsive since you’re no longer an active client, so set explicit expectations: “I need this data within five business days.”

You’re the Importer of Record but Someone Else Paid the Duties

This happens in consignment arrangements, intercompany transfers, and certain freight forwarding structures. The importer of record has the legal right to the refund, regardless of who actually funded the duty payment. Document the payment flow clearly — your assessment team will need to understand the structure.

You Import Through Multiple Legal Entities

If your company operates through subsidiaries, divisions, or affiliated entities that each have their own importer of record numbers, each entity needs its own data pull and potentially its own assessment. Don’t assume one assessment covers all entities.

You’ve Already Received an Offer From a Claim Buyer

Some importers are contacted by claim purchasers before they’ve even assessed their own exposure. If you’ve received an offer, don’t accept or reject it yet. Get your assessment first — you can’t evaluate an offer without knowing your total exposure and entry statuses. The offer will still be there in two weeks; your protest deadlines may not be.

Your Broker Says They’re Handling It

Great — but verify. Ask specifically: “What actions have you taken on our IEEPA entries? Have you filed any PSCs or protests? Are you registered for CAPE?” If they’re handling it competently, your first 48 hours become about coordination rather than initiation. If their answer is vague, you may need to supplement their work with an independent assessment.

The Psychology of Starting

We’ve seen importers delay for weeks or months for reasons that have nothing to do with logistics. The real barriers are often psychological:

“The amount probably isn’t significant enough.” You don’t know that yet. We’ve seen importers assume their exposure was under $50,000, only to discover it was $400,000 when the data came back. The only way to know is to look.

“I’ll get to it next quarter.” Entries are liquidating, protest windows are closing, and the CAPE queue is filling while you wait for a better time. There’s no better time than now. The true cost of waiting compounds with every passing week.

“The process seems too complicated.” It’s not — it’s just unfamiliar. The first 48 hours as outlined above involve sending emails, gathering documents, and filling out a form. You do harder things before lunch on any given Tuesday.

“What if I do something wrong?” The assessment process has built-in error correction. You’re not filing anything binding in the first 48 hours. You’re gathering information. There’s no wrong way to gather information.

What Happens After 48 Hours

At the end of your first two days, you should have:

• Internal buy-in from your decision maker
• A data request submitted to your customs broker(s)
• An entry inventory spreadsheet started
• An Impact Assessment requested or in progress
• A preliminary understanding of your total IEEPA exposure

From here, the process moves to analysis and decision-making. Your assessment results will clarify the best path for each category of entries. You’ll have specific numbers, specific timelines, and specific recommendations.

The hardest part is already done. You’ve started.

Get your free Impact Assessment →

The assessment is confidential, takes less than 10 minutes to request, and produces a detailed analysis of your IEEPA recovery options. Whether your exposure is $50,000 or $50 million, the first step is the same. Request your assessment today and know exactly where you stand within days — not months.