If you’re a freight forwarder, you already know which of your clients import from countries that were subject to IEEPA tariffs. You’ve seen the shipment volumes. You’ve managed the logistics on containers that carried goods subject to 10-50% IEEPA surcharges. And right now, many of those clients are sitting on six- and seven-figure refund claims they either don’t know about or haven’t acted on.
The Supreme Court’s ruling in Learning Resources, Inc. v. Trump struck down all IEEPA tariffs and created a $166 billion refund obligation. Over 330,000 importers are eligible. The opportunity for freight forwarders isn’t to file claims yourself — it’s to become the trusted advisor who connects your clients with recovery resources and, in the process, deepens your client relationships and generates referral revenue.
Here’s how to think about it, how to have the conversation, and how to structure the partnership without overstepping regulatory boundaries.
Why Freight Forwarders Are Uniquely Positioned
You occupy a distinctive position in the import supply chain. You’re not the customs broker (who files entries and manages ACE). You’re not the trade attorney (who handles protests and litigation). But you have something neither of them has at the same scale: broad visibility across your entire client base.
You See the Shipments
Your operating system contains shipment records for every client, every lane, every container. You know who’s importing from China, Vietnam, Germany, Mexico, Canada — the countries where IEEPA tariff rates were highest. You can identify, within hours, which of your clients are likely sitting on significant refund claims.
You Have the Relationship
Many importers interact with their freight forwarder more frequently than with their customs broker. You’re the one they call when a shipment is delayed, when a container needs rerouting, when rates need renegotiating. That relationship capital means they’ll listen when you raise the IEEPA refund topic — even if they’ve ignored or missed communications from other sources.
You Understand Their Business
You know which clients are cash-constrained (they negotiate hard on freight rates). You know which ones have seasonal import patterns (they ship heavy in Q3 for holiday inventory). You know which ones have scaled imports dramatically in the past 18 months (they’re likely sitting on larger IEEPA exposure). This context lets you tailor the conversation.
You’re a Trusted Neutral Party
Your clients see you as an operational partner, not someone trying to sell them something. When you raise a financial opportunity, it carries more weight than a cold email from an unknown advisory firm. That trust is an asset — and using it to help clients recover legitimate refunds reinforces it rather than spending it.
How to Identify High-Value Clients
Not every client warrants the same level of outreach. Here’s a framework for prioritizing your IEEPA recovery conversations.
Tier 1: Large Volume, China/Tariffed-Country Origin
Clients importing $5M+ annually from China, Vietnam, Thailand, India, or EU countries with high reciprocal tariff rates. These clients are likely owed $500K-$5M+ in IEEPA refunds. They should hear from you this week.
Tier 2: Moderate Volume, Broad Sourcing
Clients importing $1M-$5M from multiple countries subject to IEEPA tariffs. Their refund claims may range from $100K-$500K. Many of these clients are mid-market companies without dedicated customs or trade compliance staff — exactly the companies most likely to have missed the refund opportunity.
Tier 3: Smaller Volume, Concentrated Origin
Clients importing under $1M but sourcing heavily from high-tariff origins (especially China). Their refunds may be $50K-$100K — meaningful for a small business, even if it’s not a headline number.
| Client Tier | Annual Import Volume | Likely IEEPA Refund | Outreach Priority |
|---|---|---|---|
| Tier 1 | $5M+ from tariffed countries | $500K - $5M+ | Immediate (phone call) |
| Tier 2 | $1M - $5M, broad sourcing | $100K - $500K | This week (email + call) |
| Tier 3 | <$1M, concentrated origin | $50K - $100K | This month (email) |
Having the Conversation
The IEEPA refund conversation is not a sales pitch. It’s a value-add advisory conversation that positions you as a proactive partner. Here’s a framework.
Opening
“You’ve probably heard about the Supreme Court ruling striking down IEEPA tariffs. Based on the shipment volumes I see in our system, your company likely paid a significant amount in IEEPA duties between February 2025 and February 2026. Those duties are now refundable.”
The Key Points
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The ruling is final. This isn’t speculative. The Supreme Court has spoken, and CBP has been ordered to process refunds. The complete guide explains the legal basis.
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Deadlines are running. Entries that have been liquidated have a 180-day protest window that varies by entry. Once it expires, administrative recovery options narrow significantly.
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Amount matters. Based on what you’ve been shipping, the refund could be significant enough to warrant attention. Even a rough estimate based on shipment value and origin country can give them a ballpark.
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Action is straightforward. They don’t need to become customs experts. They need their customs broker to pull ACE data, or they can request a free Impact Assessment that maps their entire entry portfolio.
What to Avoid
Don’t represent that you can file claims on their behalf (unless you’re also a licensed customs broker). Don’t provide specific legal advice about protest deadlines or CIT litigation options. Don’t guarantee refund amounts. Your role is awareness and connection — not customs brokerage or legal services.
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The Referral Partnership Model
The most efficient way for freight forwarders to participate in IEEPA recovery is through referral partnerships with advisory firms, customs brokers, or claims specialists who handle the actual recovery work.
How It Works
- You identify eligible clients using your shipment data
- You introduce the client to a recovery partner (like Tariff Solutions)
- The partner handles everything — data analysis, Impact Assessment, filing, or claim assignment coordination
- You receive a referral fee for qualified introductions that result in recovery engagements
What’s in It for You
Revenue. Referral fees for IEEPA recovery introductions are meaningful because the underlying claim values are large. A referral that leads to recovery on a $1M claim generates a fee that’s significant for any forwarding operation.
Client retention. The forwarder who helps a client recover $500,000 in tariff overpayments becomes a hero. That’s a relationship-deepening event that pays dividends in client loyalty for years. Your competitors aren’t having this conversation with your clients. You should be.
Differentiation. In a market where freight forwarding is increasingly commoditized on price, advisory value-adds like IEEPA recovery referrals set you apart. You’re not just moving boxes — you’re watching out for your clients’ financial interests.
What’s in It for Your Client
Recovered capital. The refund itself — potentially hundreds of thousands or millions of dollars — is the obvious benefit.
Awareness. Many importers genuinely don’t know they qualify. You’re solving an awareness problem that’s costing them real money. The analysis of why 90% haven’t filed explains the barriers in detail.
Speed. Clients you refer to a recovery partner get started immediately. They don’t have to research the process, figure out the filing requirements, or navigate CBP procedures on their own.
Regulatory Boundaries: What You Can and Can’t Do
Freight forwarders operate under a different regulatory framework than customs brokers. Understanding the boundaries is important.
What You CAN Do
- Raise awareness about the IEEPA ruling and refund opportunity with your clients
- Provide general information about the refund process based on publicly available sources
- Share educational resources like blog posts, guides, and FAQs about IEEPA recovery
- Make introductions to licensed customs brokers, trade attorneys, or advisory firms who handle recovery
- Receive referral fees for qualified introductions (check your specific agreement terms)
- Pull your own shipment data to estimate a client’s likely IEEPA exposure based on origin countries and volumes
What You CANNOT Do
- File customs entries, protests, or post-summary corrections on behalf of clients (this requires a customs broker license under 19 U.S.C. Section 1641)
- Provide specific legal advice about protest deadlines, CIT litigation, or claim assignment structures
- Access or modify ACE portal data on behalf of a client (this is the customs broker’s domain)
- Guarantee refund amounts or make specific representations about recovery timelines
The line is clear: you’re the connector and advisor, not the filer. This actually works in your favor — you add value without taking on operational or regulatory risk.
Building Your IEEPA Recovery Outreach Program
Here’s a practical playbook for launching IEEPA recovery outreach across your client base.
Week 1: Data Review
Pull your shipment records for the IEEPA period (February 4, 2025 — February 24, 2026). Identify all clients who received shipments from tariffed countries. Sort by estimated import value to create your tier list.
Week 2: Tier 1 Outreach
Call your highest-value clients directly. Use the conversation framework above. The goal isn’t to close anything — it’s to raise awareness and offer to connect them with a recovery partner. Have your referral partner’s information ready to share.
Week 3: Tier 2 Outreach
Email your mid-tier clients with a brief summary of the opportunity and an offer to discuss. Follow up by phone with those who respond. Consider hosting a short webinar or sending a recorded video explanation that multiple clients can view on their own time.
Week 4: Tier 3 and Ongoing
Email your remaining client base. Set up a recurring check-in to identify new clients or clients whose situations have changed. Monitor CAPE launch timing and share updates with clients who have engaged.
Ongoing: Track and Follow Up
Maintain a simple tracker of which clients you’ve contacted, their response, and their status. Clients who said “not now” in March may be more receptive in April when CAPE launches and the refund process becomes more tangible. The cost of waiting analysis provides compelling data points for follow-up conversations.
Measuring Success
Track three metrics for your IEEPA outreach program:
- Client reach rate: What percentage of your IEEPA-eligible clients have you contacted?
- Engagement rate: Of those contacted, how many have taken a next step (requested data, scheduled a call, connected with a recovery partner)?
- Recovery facilitated: Total estimated IEEPA refund value across clients you’ve connected with recovery resources.
These metrics demonstrate the value of your advisory role to both your clients and your own management team. They also help you identify which communication approaches and client segments generate the highest response rates, so you can optimize your outreach over time.
Handling Client Objections
When you raise the IEEPA refund topic, you’ll encounter predictable pushback. Here’s how to address the most common objections.
”Our customs broker would have told us”
Maybe. But with 330,000 affected importers, brokers are overwhelmed. Many are prioritizing their largest accounts. Some aren’t sure how to structure the recovery themselves. Your client’s broker may well get to it — eventually. But the 180-day protest window doesn’t wait for anyone’s prioritization schedule. Ask your client: “Has your broker specifically told you which entries have IEEPA duties and what the liquidation status is?” If the answer is no, they need to follow up.
”It’s not worth the effort for our volume”
This objection usually comes from importers who haven’t done the math. A company importing $2 million annually from China at a 20% IEEPA surcharge is owed approximately $400,000. That’s not immaterial for any mid-market business. Help them do the rough calculation: annual import volume from tariffed countries multiplied by the applicable IEEPA rate. The refund calculator guide makes this straightforward.
”We’ll deal with it next quarter”
This is the most costly objection. Every month of delay erodes queue position, risks protest deadlines, and costs time value on the refund. The cost of waiting analysis shows that a 3-month delay on a $500,000 claim can cost $12,000-$30,000. That number usually gets attention.
”I don’t want to deal with the government”
Good news — they don’t have to. Immediate capital through claim assignment bypasses government processing entirely. The importer gets paid directly by the claim buyer within 21 days. No CAPE, no queue, no waiting.
Case Study: How One Forwarder Identified $12M in Client Claims
Consider a mid-size freight forwarder with 300 active import clients. They ran a report on their shipment data for the IEEPA period and found that 180 clients had received shipments from tariffed countries. Of those, 45 had estimated IEEPA exposure exceeding $100,000. The top 10 clients alone accounted for $8 million in estimated refundable duties.
Within two weeks, the forwarder had contacted all 45 high-value clients. Thirty-two were unaware of the refund opportunity. Eighteen engaged with the recovery partner. The total estimated recovery across those 18 clients: approximately $12 million in IEEPA refunds that would otherwise have gone unrecovered — or at least significantly delayed.
The forwarder earned referral fees on the engagements. More importantly, they deepened 18 client relationships with a high-value advisory conversation that none of their competitors initiated.
The Competitive Advantage of Acting Now
The IEEPA refund window has a finite timeline. Protest deadlines are running. CAPE launch is imminent. The importers who act first recover fastest. And the freight forwarders who raise this issue first earn the gratitude — and the loyalty — of clients who would otherwise have missed the opportunity.
Your competitors are focused on rates and transit times. You can differentiate by watching out for your clients’ bottom line in ways they didn’t expect. That’s the kind of value that cements long-term partnerships.
The opportunity is time-sensitive. Protest windows are closing on a rolling basis. CAPE queue position is first-come, first-served. And the window for establishing yourself as the IEEPA recovery resource in your market narrows every week. The forwarders who act in February and March 2026 will capture the lion’s share of the referral opportunity. Those who wait until summer will find that their clients have already been contacted by someone else.
If you’re ready to explore a referral partnership for IEEPA recovery, the partner program provides the framework, resources, and support to get started. If you’d rather start by understanding the opportunity for a specific client, an Impact Assessment is the fastest way to quantify what they’re owed.
[Find out what your clients are owed — no cost, no obligation.]
