Somewhere in your files — or in your customs broker’s records — there’s a form that documents every import shipment you’ve ever brought into the United States. It’s called the CF-7501, officially known as the Entry Summary. It’s the single most important customs document you’ll deal with during IEEPA tariff recovery, and most importers have never actually read one.
That’s about to change. This guide walks you through the CF-7501 field by field, showing you exactly how to find the information that matters for your IEEPA refund claim. By the end, you’ll be able to pick up any CF-7501 from the last year and quickly identify whether it contains IEEPA tariff lines, how much you paid, and what your refund position looks like.
No customs expertise required. We’ll translate everything into plain English.
What the CF-7501 Is (and Why It Exists)
The CF-7501 is the official form used to declare imported goods to U.S. Customs and Border Protection (CBP). “CF” stands for Customs Form. Every commercial import into the United States requires one. Your customs broker prepares and files it electronically through the ACE system, but the underlying data structure follows the CF-7501 format.
Think of it as a detailed receipt and declaration combined. It tells CBP:
- Who is importing (you, the importer of record)
- What is being imported (product descriptions and classifications)
- Where it came from (country of origin and export)
- What it’s worth (declared value)
- How much duty is owed (calculated based on classification and value)
The form has been in use for decades, though the modern version is filed electronically. If you ask your broker for copies of your entry summaries, you may receive them as PDF printouts of the electronic filing or as data extracts from the ACE system. Either way, the fields are the same.
For IEEPA recovery purposes, the CF-7501 is where you’ll find proof of exactly how much you paid in IEEPA duties on each shipment. This forms the basis of your refund claim, whether you’re pursuing a Post-Summary Correction, a formal protest, or another recovery path.
The Header Section: Who, When, and Where
The top portion of the CF-7501 contains identifying information. Here are the fields that matter for IEEPA recovery:
Entry Number (Block 1)
A unique identifier for this specific import entry. The format is a three-character filer code, a seven-digit number, and a single check digit (e.g., ABC-1234567-8). This is how CBP tracks the entry through its entire lifecycle — from filing to liquidation to (potentially) refund.
Why it matters: You’ll reference this number in every recovery action — PSCs, protests, and claim documentation. Each entry number corresponds to one CF-7501 and one potential refund claim.
Entry Type (Block 2)
A two-digit code indicating the type of entry. The most common is 01 (consumption entry), meaning the goods are entering U.S. commerce and duties are being paid. Other codes include 21 (warehouse), 23 (temporary import), and 06 (FTZ admission).
Why it matters: Most IEEPA refund claims involve type 01 entries. If you see other entry types, the recovery mechanics may differ slightly.
Entry Date (Block 5)
The date the entry was filed with CBP. This is the starting point for the liquidation clock — CBP has approximately 314 days from this date to liquidate the entry.
Why it matters: This date helps you estimate when liquidation occurred (or will occur), which determines your recovery path and deadline.
Port Code (Block 4)
The U.S. port where the goods entered. This is a four-digit code (e.g., 2704 for Los Angeles, 1001 for New York/Newark, 5301 for Houston).
Why it matters: Different ports may have different processing timelines for PSCs and protests. Large ports with high IEEPA volume may experience longer processing times.
Importer of Record (Block 9/10)
Your company name and importer number (typically your EIN). This is the entity responsible for the entry — and the entity entitled to any refund.
Why it matters: This confirms you’re the party with the refund claim. If you see a different company’s name here, that company holds the claim, not you. See our guide on who qualifies for IEEPA refunds for more detail.
The Line Item Section: What You Imported
The middle section of the CF-7501 contains the detailed breakdown of every product in the shipment. This is where the IEEPA tariff information lives. Each line item includes:
HTS Number (Block 27)
The Harmonized Tariff Schedule classification code for the product. This is a 10-digit number that determines the duty rate. For IEEPA recovery, you’re scanning for specific codes:
- 9903.01.xx — These are the “fentanyl” IEEPA tariffs applied to imports from China, Canada, and Mexico.
- 9903.02.xx — These are the “reciprocal” Liberation Day tariffs applied to imports from virtually every country.
Any line item with an HTS code starting with 9903.01 or 9903.02 represents an IEEPA tariff charge that is now refundable.
A single entry might have multiple line items — some with IEEPA codes and some without. For example, an entry for Chinese electronics might show:
| Line | HTS Code | Description | Duty Rate |
|---|---|---|---|
| 1 | 8471.30.0100 | Laptop computers (base duty) | 0% |
| 2 | 9903.88.0301 | Section 301 additional duty | 25% |
| 3 | 9903.01.25 | IEEPA fentanyl tariff | 20% |
In this example, only line 3 is the IEEPA duty — that’s the refundable amount. Lines 1 and 2 are non-IEEPA duties that remain in effect.
Entered Value (Block 28)
The declared customs value of the goods on each line. This is the base number that the duty rate is applied to. For ad valorem (percentage-based) duties, the duty amount equals the entered value multiplied by the duty rate.
Why it matters: The entered value on your IEEPA tariff lines determines the dollar amount of your refund. If the entered value is $100,000 and the IEEPA rate was 20%, your refund for that line is $20,000 (plus interest).
Duty Amount (Block 31)
The actual dollar amount of duty assessed on each line item. This is the bottom line — the money you paid to CBP for this specific tariff line.
Why it matters: This is your refund amount, line by line. Sum up all the duty amounts on lines with 9903.01 or 9903.02 HTS codes, and you have your IEEPA refund total for this entry (before interest).
Relationship and Special Programs (Various Blocks)
There are additional blocks related to trade agreements, special programs, and other preferential treatment. These generally don’t affect IEEPA recovery but may be relevant if your entries involved any exclusion or exemption programs that were in effect during the IEEPA period.
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The Totals Section: The Bottom Line
The bottom of the CF-7501 summarizes everything:
Total Entered Value (Block 31)
The sum of all line item values. This is the total customs value of the entire shipment.
Total Duty (Block 31)
The total duty assessed across all line items. This includes base duties, Section 301 duties, Section 232 duties, IEEPA duties, and any other applicable tariffs. The total duty is what you paid as your estimated duty deposit when the entry was filed.
For IEEPA recovery: You need to separate the IEEPA portion from the total. This requires looking at the individual line items, not just the total. A CF-7501 showing $150,000 in total duty might include $50,000 in Section 301 duties (not refundable) and $100,000 in IEEPA duties (refundable). The line-item detail is essential.
Other Fees (Block 39)
Merchandise Processing Fees (MPF), Harbor Maintenance Fees (HMF), and other charges. These are generally not affected by IEEPA recovery — they were assessed under separate authority and are not part of the refund.
Reading a CF-7501: A Worked Example
Let’s walk through a realistic example. Say your company imports consumer electronics from Vietnam. Here’s what the key fields might look like on a CF-7501 from July 2025:
Header:
- Entry Number: XYZ-5678901-2
- Entry Type: 01 (Consumption)
- Entry Date: July 15, 2025
- Port: 2704 (Los Angeles)
- Importer of Record: Your Company, Inc. (EIN: 12-3456789)
- Country of Origin: Vietnam
Line Items:
| Line | HTS | Description | Value | Rate | Duty |
|---|---|---|---|---|---|
| 1 | 8518.30.2000 | Headphones | $200,000 | 0% | $0 |
| 2 | 9903.02.86 | IEEPA reciprocal tariff (VN) | $200,000 | 46% | $92,000 |
| 3 | 8523.51.0000 | Flash memory drives | $150,000 | 0% | $0 |
| 4 | 9903.02.86 | IEEPA reciprocal tariff (VN) | $150,000 | 46% | $69,000 |
Totals:
- Total Entered Value: $350,000
- Total Duty: $161,000
- MPF: $575 (maximum per entry)
IEEPA Recovery Analysis:
- Lines 2 and 4 are IEEPA tariff lines (HTS 9903.02.86)
- Total IEEPA duties: $92,000 + $69,000 = $161,000
- Entry date July 15, 2025 → estimated liquidation around May 2026
- As of April 2026, likely still unliquidated → PSC path available
This single entry has a $161,000 IEEPA refund claim. Multiply by the number of shipments you received during the IEEPA period, and you can see how the total adds up quickly.
Common CF-7501 Patterns for IEEPA Entries
Different types of imports show different patterns on the CF-7501. Here’s what to look for:
China Imports: Multiple Tariff Layers
Chinese imports often have the most complex CF-7501s because multiple tariff programs stack on top of each other. You might see:
- Base duty line (varies by product)
- Section 301 line (9903.88.xx at 7.5-25%)
- IEEPA fentanyl tariff line (9903.01.xx at 20-60%)
Only the 9903.01 line is part of the IEEPA refund. The Section 301 line stays. Be careful not to confuse the two — they both start with 9903 but use different subheadings.
Non-China Imports: Usually Cleaner
For imports from countries like Vietnam, Taiwan, Japan, or the EU, the CF-7501 is typically simpler. These countries weren’t subject to Section 301 duties (in most cases), so the IEEPA reciprocal tariff (9903.02.xx) may be the only additional tariff line beyond the base rate.
Zero-Duty Products with IEEPA Surcharges
Many products — especially electronics and technology — enter the U.S. at a 0% base duty rate. Their CF-7501s show the oddity of the IEEPA period: the only duty charged was the IEEPA tariff. When that tariff is removed, the total duty on the entry drops to zero. For these entries, your IEEPA refund equals your total duty paid.
What to Do If You Can’t Find Your CF-7501s
Don’t panic if you don’t have copies of your entry summaries on file. There are several ways to reconstruct the data:
Your customs broker has copies. Brokers are required to maintain entry records for five years. Contact your broker and request copies of all CF-7501s (or equivalent ACE data exports) for the IEEPA period.
ACE portal. If you have direct access to CBP’s ACE Secure Data Portal, you can pull your own entry data. The ES-003 Entry Summary Details report provides the same information as the CF-7501 in a tabular format.
Your accounting records. Duty payments show up on your broker’s invoices and on your company’s accounts payable records. While these don’t provide line-item detail, they can help you estimate your total exposure.
CBP records. Under the Freedom of Information Act (FOIA), you can request your own entry records from CBP. However, this is slow — FOIA responses can take months — so it’s a last resort.
The IEEPA tariff refund glossary can help you decode any unfamiliar terms you encounter on these documents.
From CF-7501 to Refund Claim
Understanding your CF-7501 is step one. Here’s how it connects to the actual recovery:
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Collect all CF-7501s (or ACE data) for the IEEPA period. February 2025 through February 2026.
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Identify IEEPA lines. Scan for HTS codes starting with 9903.01 or 9903.02.
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Sum IEEPA duties. Add up the duty amounts on all IEEPA lines across all entries. This is your gross refund claim.
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Add interest. Statutory interest at approximately 4-5% annually accrues from the date of duty deposit to the date of refund. Our complete guide explains how interest is calculated.
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Check liquidation status. For each entry, determine whether it’s been liquidated and when. This maps each entry to a recovery path.
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Take action. PSCs for unliquidated entries. Protests for recently liquidated entries. Litigation or claim assignment for the rest.
If that sounds like a lot of work across dozens or hundreds of entries, it is. That’s why an Impact Assessment exists — to do this analysis comprehensively and present you with clear numbers and a clear recovery strategy.
Tips for Managing CF-7501s Across Large Portfolios
If you have dozens or hundreds of entries from the IEEPA period, reviewing each CF-7501 individually isn’t practical. Here are strategies for managing the volume:
Batch analysis. Request your ACE data in a tabular format (spreadsheet or CSV) rather than individual CF-7501 PDFs. This allows you to filter and sort by HTS code, isolating all 9903.01 and 9903.02 lines across your entire portfolio in minutes.
Prioritize by value. Not all entries are created equal. A $5,000 entry and a $500,000 entry both need attention, but the large entry has 100 times the refund potential. Sort your entries by IEEPA duty amount and work from the top down.
Prioritize by deadline. Entries with approaching protest deadlines need immediate attention regardless of value. A $10,000 refund you can recover through a protest is worth more than a $50,000 refund you miss because the window closed.
Group by status. Separate your entries into unliquidated (PSC path), liquidated within 180 days (protest path), and liquidated beyond 180 days (litigation path). Each group requires different action and has different timelines.
Use automated tools. The scale of the IEEPA refund event — affecting 330,000 importers and millions of entries — has driven development of automated analysis tools that can process ACE data extracts and identify IEEPA lines, calculate refund amounts, and flag deadlines across an entire portfolio. An Impact Assessment leverages these capabilities.
Reconcile with accounting records. Cross-reference your CF-7501 duty amounts with your accounts payable records (specifically, payments to your customs broker for duty). This reconciliation ensures you’re not missing entries and that the duty amounts match what you actually paid.
The CF-7501 in the Digital Age
While we’ve been talking about the CF-7501 as a “form,” modern customs processing is almost entirely electronic. Your broker files entries through the ACE system, and the data flows digitally from classification to payment to liquidation. The CF-7501 format is the underlying data structure, but you may never see a physical form.
What you’ll typically receive from your broker is one of the following:
- ACE data extract — a spreadsheet or database export containing all the CF-7501 fields in tabular format. Best for analysis.
- PDF printout — a formatted version of the electronic filing that looks like a traditional form. Easier to read for individual entries.
- Broker system report — your broker’s proprietary system may present entry data in their own format, which maps to CF-7501 fields.
Any of these formats contains the information you need for IEEPA recovery. The key fields — entry number, HTS codes, duty amounts, and liquidation status — are present in all of them.
The CF-7501 is your evidence. The Supreme Court ruling is your legal basis. The recovery paths are your mechanism. Put them together, and you have a refund claim.
