IEEPA Tariff Refund Checklist: 15 Items Before You File

Filing an IEEPA tariff refund claim isn’t complicated, but it does require precision. One missed entry, one wrong HTS code, one overlooked liquidation date — and your filing gets kicked back to the end of the queue. With 53 million entry lines competing for CBP’s attention, you don’t want to give them a reason to delay yours.

This is the checklist we use internally when preparing client filings. Every item below is something that, if skipped, has caused real problems for real importers. Walk through all 15 before you submit anything to CBP, whether you’re filing through your customs broker, preparing for CAPE, or working with a recovery firm.

For the full context on why these refunds exist and how the process works, see our complete guide to IEEPA tariff refunds. But if you already know the basics and just need to make sure you’re ready to file, this checklist is for you.

Item 1: Confirm Your Importer of Record (IOR) Status

The refund goes to the Importer of Record on each entry — not the consignee, not the freight forwarder, not the customs broker. Before you spend time preparing a filing, confirm that your company is the IOR on the entries you’re claiming.

This sounds obvious, but it trips up more importers than you’d expect. If you use a buying agent, a sourcing company, or a third-party logistics provider that files entries on their own IOR number, those entries belong to them, not you. Check the IOR number on your entry summaries (CF-7501) and make sure it matches your company’s CBP-assigned IOR number.

If you’re the beneficial owner of the goods but not the IOR, you’ll need to work with the actual IOR to file the claim or arrange an assignment. The eligibility guide covers IOR requirements in detail.

Item 2: Access the ACE Portal

The Automated Commercial Environment (ACE) portal is where your entry data lives. You need access to pull the reports that drive your filing — specifically the ES-003 report that contains entry summaries, duty amounts, and liquidation status.

If you don’t have direct ACE access, your customs broker does. Contact them and request full entry summary data for all entries filed between February 4, 2025, and February 24, 2026. Don’t settle for a summary — you need entry-level detail including HTS codes and duty line items.

If you haven’t logged into ACE in a while, verify your credentials now. Password resets and access requests can take days, and you don’t want to be locked out when deadlines are approaching.

Item 3: Pull Your ES-003 Report

The ES-003 report is the foundation of your entire filing. It contains every entry filed during the period you specify, broken down by entry number, entry date, HTS code, duty type, duty amount, and — critically — liquidation status.

Request the report for the full IEEPA tariff period: February 4, 2025, through February 24, 2026. If you import frequently, this report may contain thousands of entries. That’s normal. You’ll filter it in the next steps.

Make sure the report includes all duty line items, not just totals. The IEEPA surcharge is a separate line item with its own HTS code, and you need to isolate it from other duties to calculate your claim accurately.

Item 4: Verify the Date Range

IEEPA tariffs were in effect from February 4, 2025 (when the first China tariffs under IEEPA were imposed) through February 24, 2026 (four days after the Supreme Court ruling, when the CIT’s injunction took effect). Only entries within this window are eligible for refunds.

Check your data carefully at the edges. An entry filed on February 3, 2025, isn’t covered. An entry filed on February 25, 2026, may or may not have IEEPA duties depending on when the tariff codes were removed from the system. The safe window is February 4, 2025, through February 20, 2026 (ruling date), but entries filed between February 20 and February 24 may also qualify depending on processing dates.

Item 5: Identify All HTS 9903 Entries

IEEPA tariff duties are classified under HTS heading 9903, specifically subheadings 9903.01 (China IEEPA tariffs, fentanyl tariffs) and 9903.02 (reciprocal tariffs, Canada/Mexico tariffs). Filter your ES-003 report for all entries containing these codes.

Here’s where it gets tricky: some entries have both IEEPA duties and other Chapter 99 duties. Section 301 tariffs (also under HTS 9903, but different subheadings) are not IEEPA tariffs and are not part of this refund. Section 232 tariffs (steel and aluminum) are under different authority and also not included.

You must isolate the IEEPA-specific duty codes. Your customs broker should be able to help you distinguish between HTS codes, but if you’re doing this yourself, cross-reference the specific IEEPA tariff proclamations to confirm which subheadings apply.

Get your free Impact Assessment →

Item 6: Separate IEEPA Duties from Other Duties

This is the most common error we see in self-prepared filings. Importers often claim their total duties paid on an entry rather than just the IEEPA portion. If your entry had $50,000 in total duties but only $20,000 was IEEPA surcharge, your claim is for $20,000 — not $50,000.

To separate IEEPA duties, you need to:

1. Identify the base duty rate for each HTS code (the rate that applied before IEEPA tariffs were added)
2. Identify the IEEPA surcharge rate for each applicable code
3. Calculate the IEEPA-specific amount by applying only the surcharge rate to the entered value

For imports from China, this is particularly important because Section 301 tariffs (7.5%–25%) were already in place before the IEEPA surcharge (an additional 20%) was added. Only the 20% IEEPA component is refundable under this process. The refund amount calculator helps you separate these layers.

Item 7: Check Liquidation Status Per Entry

Your recovery path depends on whether each entry has been liquidated. This is not a company-level determination — it’s entry by entry. You might have 100 unliquidated entries and 200 liquidated ones.

Your ES-003 report shows liquidation status and date for each entry. Review every entry and categorize it. This determines which recovery path applies to which entries.

Entries typically liquidate approximately 314 days after filing. Entries filed in February–May 2025 may have already liquidated. Entries filed from mid-2025 onward are more likely to still be unliquidated. But “more likely” isn’t “definitely” — check each one.

Item 8: Calculate 180-Day Deadlines for Liquidated Entries

For every liquidated entry, the 180-day protest window starts on the date of liquidation. Calculate the deadline for each entry and sort them by urgency. Entries with deadlines in the next 30–60 days need immediate attention.

Create a deadline calendar:

• Entries with < 30 days remaining: File protests immediately
• Entries with 30–90 days remaining: Prioritize for next batch of filings
• Entries with 90–180 days remaining: Schedule for filing, monitor regularly
• Entries past 180 days: Administrative protest is no longer available

Missing even one deadline means that entry moves from the administrative protest path (low cost, straightforward) to CIT litigation (expensive, slow). The cost of waiting explains why staying ahead of these deadlines saves real money.

Item 9: Estimate Your Total IEEPA Tariff Exposure

Before you file anything, add up all the IEEPA-specific duties across every eligible entry. This number is your total exposure — the maximum you can recover through the refund process.

Knowing this number matters for three reasons:

1. It determines your recovery strategy. A $50K claim warrants a different approach than a $5M claim.
2. It lets you evaluate tradeoffs. Should you sell part of the claim for immediate capital? The answer depends on the total.
3. It sets expectations. You need to know what you’re working toward to allocate time and resources appropriately.

If your total exposure exceeds $500,000, you likely qualify for immediate capital options and should consider a hybrid strategy. The Impact Assessment gives you a precise figure backed by line-by-line analysis.

Item 10: Gather Supporting Documentation

Beyond the ES-003 report, assemble the following for each entry you plan to file:

• Commercial invoices matching the entry summary data
• Bill of lading / airway bill numbers
• Packing lists (for complex or multi-line entries)
• Prior disclosure documents (if any were filed)
• Customs broker correspondence related to duty payments

You may not need all of these for every filing type. PSCs and CAPE filings are primarily data-driven and may not require physical documentation. But having the records organized means you can respond quickly if CBP requests verification. Incomplete responses to CBP inquiries cause the most common processing delays.

Item 11: Contact Your Customs Broker

Your customs broker is your primary filing agent for PSCs and protests, and they’ll likely handle your CAPE filing as well. Contact them now — not after CAPE launches — and discuss:

• Their capacity to handle your filing volume
• Whether they have experience with IEEPA-specific claims
• Their fee structure for refund-related filings
• Their timeline for pulling data and preparing submissions

Some customs brokers are already overwhelmed with IEEPA refund requests. If yours doesn’t have the capacity or expertise, consider engaging a specialized recovery firm. The important thing is to have a filing partner identified and engaged before deadlines hit.

If your broker has questions about the process, point them to our 7-step filing guide which covers the mechanics from the broker’s perspective.

Item 12: Determine Your Optimal Recovery Path

With your entry data categorized by liquidation status and your total exposure calculated, you can now map each entry to the right recovery path:

The four recovery paths guide provides a detailed comparison, including timelines, costs, and tradeoffs for each path. Most importers with significant claims use a combination of paths.

Item 13: Prepare Your Filing Package

For each recovery path, assemble the specific filing requirements:

For PSCs:

• Entry numbers and dates
• Specific HTS codes to correct
• Corrected duty calculations
• Broker authorization

For Protests:

• Protest form (CBP Form 19)
• Legal basis citation (the Supreme Court ruling and CIT order)
• Entry-level duty calculations
• Supporting documentation

For CAPE:

• Validated entry-level data in the required format (format to be published at launch)
• IEEPA duty calculations separated from other duty types
• IOR verification

For Immediate Capital:

• NDA execution with the buyer
• Entry-level data for validation
• Claim assignment agreement review

Item 14: Secure an NDA Before Sharing Data

Your entry data contains sensitive commercial information: what you import, from where, in what quantities, and at what values. Before sharing this data with anyone — a recovery firm, a claim buyer, an attorney — get a signed NDA.

A legitimate firm will offer an NDA before asking for your data. If they don’t, ask for one. If they refuse, walk away. The guide to evaluating recovery firms covers what to look for in NDAs and data protection commitments.

Your data is valuable. Treat it accordingly.

Item 15: Submit — Or Get Professional Help

If you’ve made it through items 1–14, you’re ready to file. For importers with straightforward portfolios (under 100 entries, single recovery path, active broker relationship), self-filing is entirely feasible. Your broker handles the mechanics; you just need to provide the data and authorization.

For importers with complex portfolios — hundreds or thousands of entries across multiple liquidation statuses, multiple recovery paths, or claims large enough to warrant immediate capital consideration — professional help often pays for itself. The time savings alone can be significant, and a specialized firm catches errors that lead to rejections and delays.

That’s exactly what our Impact Assessment is designed to do. We analyze your complete entry portfolio, calculate your total exposure, categorize every entry by status and optimal recovery path, and produce a clear action plan. It’s free, it’s covered by NDA, and it takes the guesswork out of a process where precision matters.

Common Mistakes That Derail Filings

Even with a checklist, importers make predictable errors. Here are the most common ones we see — and how to avoid them.

Claiming total duties instead of IEEPA-only duties

This is the number one filing error. Your entry may show $75,000 in total duties, but only $30,000 of that is the IEEPA surcharge. Filing for $75,000 gets your claim rejected. Always separate IEEPA duties from MFN, Section 301, and Section 232 components.

Using outdated liquidation data

Liquidation status changes daily. An entry that was unliquidated when you pulled your ES-003 report two weeks ago may have liquidated since. Always re-verify liquidation status within 48 hours of filing. A PSC filed on a liquidated entry will be rejected, and you’ll need to start the protest process instead — adding months to your timeline.

Filing protests without checking the 180-day math

Some importers assume they have more time than they do. The 180-day window starts on the liquidation date shown in ACE, which may differ from the date you received notification. Double-check the exact liquidation date for every entry before calculating your protest deadline.

Forgetting to include all entries

Many importers have entries across multiple customs broker relationships or multiple IOR numbers (for companies with subsidiaries). A partial filing recovers partial money. Audit all broker relationships and all IOR numbers to make sure every IEEPA entry is accounted for.

Not filing protective protests while waiting for CAPE

Some importers plan to file everything through CAPE and skip protests entirely. The risk: if CAPE doesn’t cover certain entry categories, or if processing takes longer than expected, having a protective protest on file preserves your administrative remedy. It costs nothing to file and protects against downside scenarios.

How to Use This Checklist

Print this out (or save it to your desktop) and work through it in order. Items 1–3 are prerequisites for everything that follows. Items 4–9 are the analysis phase. Items 10–14 are preparation. Item 15 is execution.

If you get stuck on any item — especially items 5 and 6 (identifying and separating IEEPA duties) — don’t guess. Wrong data in your filing is worse than a delayed filing. Get help from your customs broker, a trade attorney, or a recovery firm that specializes in IEEPA claims.

The clock is ticking on multiple fronts: protest deadlines are expiring, the CAPE queue is forming, and entries are liquidating daily. But rushed, sloppy filings will cost you more time than careful preparation. Do it right the first time.