Trade law has its own language, and if you’re filing an IEEPA tariff refund claim for the first time, that language can feel impenetrable. ACE, CAPE, PSC, IOR, HTS 9903.01, CF-7501 — it reads like alphabet soup, and every acronym matters because using the wrong term or misunderstanding a concept can delay your refund by months.
This glossary defines every term you’re likely to encounter in the IEEPA tariff refund process, written in plain English. We’ve organized it alphabetically and kept each definition to 2–4 sentences focused on what the term means for your refund. Where a concept connects to a deeper resource, we’ve linked to it.
Bookmark this page. You’ll come back to it.
A
ACE (Automated Commercial Environment)
CBP’s electronic system for processing international trade data. This is where your entry summaries live, where your broker files entries, and where you pull the ES-003 reports that form the foundation of your refund claim. If you’re an active importer, you likely have ACE portal access — log in at ace.cbp.dhs.gov. Your customs broker definitely has access and can pull data on your behalf.
Ad Valorem
A duty calculated as a percentage of the goods’ value, as opposed to a specific duty (which is a fixed dollar amount per unit). Most IEEPA tariffs were ad valorem — for example, the 20% China surcharge was 20% of the declared value of the imported goods. When calculating your refund, you need the entered value and the IEEPA ad valorem rate to determine the IEEPA-specific duty amount.
Accelerated Disposition
A formal request asking CBP to expedite its decision on a protest. If CBP doesn’t respond within 30 days of receiving an accelerated disposition request, the protest is “deemed denied,” which allows the importer to escalate to the Court of International Trade. This is a tactical tool — it converts government delay into an actionable legal option.
Assignment (Claim Assignment)
The legal transfer of your right to receive a tariff refund from CBP to another party, typically a capital provider. In exchange, you receive immediate cash payment at a discount. The assignment is non-recourse, meaning the buyer takes all risk related to timing and government processing. See our immediate capital guide for details.
B
Bond (Customs Bond / Surety Bond)
A financial guarantee required for importing goods into the U.S., ensuring payment of duties, taxes, and fees. A continuous bond covers all entries during a 12-month period. Your bond status doesn’t directly affect your IEEPA refund eligibility, but it confirms you’re a registered importer with CBP.
Broker (Customs Broker)
A licensed professional authorized to conduct customs business on behalf of importers. Your customs broker files entries, classifies goods, calculates duties, and — critically for IEEPA refunds — can file post-summary corrections, protests, and CAPE declarations on your behalf. They’re your primary filing partner for most recovery paths.
C
CAPE (Customs Administrative Processing for IEEPA Entries)
CBP’s dedicated system for processing IEEPA tariff refunds at scale. Projected to launch mid-April 2026, CAPE will accept validated claims from importers and process refunds sequentially. Your position in the CAPE queue depends on when your validated data is submitted — earlier submissions get processed first. This is the primary refund mechanism for most importers.
CBP (U.S. Customs and Border Protection)
The federal agency that collects duties on imported goods and processes refunds. CBP has approximately 2,500 staff handling trade operations, and they’re responsible for processing all 53 million+ IEEPA entry lines through CAPE and other mechanisms. They’re not your adversary in this process — the Supreme Court ruled in your favor, and CBP is executing the refund.
CF-7501 (Entry Summary Form)
The official customs form that documents an import entry, including the imported goods, their classification, value, and duties assessed. Each CF-7501 corresponds to one entry and contains the duty line items you need to identify IEEPA tariffs. Your broker files this form electronically through ACE.
Chapter 99 (HTS Chapter 99)
The section of the Harmonized Tariff Schedule reserved for temporary modifications, including IEEPA tariffs. When you see HTS codes starting with 9903, those are Chapter 99 duties. Not all Chapter 99 duties are IEEPA tariffs — Section 301 and Section 232 tariffs are also in Chapter 99 under different subheadings. You need to isolate the IEEPA-specific codes (9903.01 and 9903.02).
CIT (Court of International Trade)
A federal court with exclusive jurisdiction over customs and international trade cases. Located in New York City, the CIT is where importers can challenge CBP decisions and pursue refunds when administrative remedies are exhausted. The CIT’s March 4, 2026 order directed CBP to process IEEPA tariff refunds. Litigation in the CIT requires an attorney admitted to the CIT bar and is typically the path for entries outside the 180-day protest window.
Claim Value
The total dollar amount of IEEPA-specific duties you paid during the affected period. This is not your total duties paid — it’s only the IEEPA surcharge portion. The refund amount calculator helps you determine this figure.
Get your free Impact Assessment →
D
De Minimis
A threshold below which imports are exempt from duties. For IEEPA purposes, the de minimis exception was initially $800 per shipment, then reduced or eliminated for certain countries. If your individual shipments were below the de minimis threshold and no duties were assessed, there’s nothing to refund on those entries.
Deemed Denied
When CBP fails to respond to a protest with accelerated disposition within 30 days, the protest is automatically considered denied. This isn’t actually a bad outcome — it gives you the right to file a summons in the CIT within 180 days, escalating your claim to federal court.
Drawback
A refund of duties paid on imported goods that are subsequently exported or used in the manufacture of exported products. Drawback is a different program from IEEPA tariff refunds and operates under different rules (19 U.S.C. Section 1313). You can potentially claim both drawback and IEEPA refunds on the same entries if the conditions for both are met, but they’re separate processes.
Duty
A tax imposed on imported goods. “Duty” is the general term; “tariff” typically refers to the rate or the policy. Your total duty payment on an entry may include MFN duties, Section 301 duties, Section 232 duties, and IEEPA duties. Only the IEEPA portion is refundable under this process.
E
Entry
A single import transaction filed with CBP. Each entry has a unique entry number, an entry date, and associated duty assessments. One shipment can contain multiple entries, and one entry can contain multiple line items. Your refund is calculated at the entry level — each entry’s IEEPA duties are a separate refund line item.
Entry Date
The date an entry was filed with CBP, not the date the goods arrived at port. The entry date determines whether the entry falls within the IEEPA tariff period (February 4, 2025 – February 24, 2026) and affects the liquidation timeline.
Entry Summary
The detailed record of an import entry filed through ACE, documented on CF-7501. Contains all the data needed for your refund claim: HTS codes, duty amounts, values, country of origin, and liquidation status.
ES-003 Report
A specific report available through the ACE portal that provides comprehensive entry summary data. This is the single most important document for your IEEPA refund claim — it contains every entry filed during a specified period with all duty line items and liquidation status. Your customs broker can pull this report on your behalf.
F
Fentanyl Tariffs
Tariffs imposed under IEEPA authority ostensibly to combat fentanyl trafficking, primarily targeting imports from China, Canada, and Mexico. These were separate proclamations from the broader IEEPA tariffs but used the same legal authority and are equally affected by the Supreme Court ruling. Classified under HTS 9903.01.
Finally Liquidated
An entry that has been liquidated and the protest period has expired, or where all protests and appeals have been resolved. Finally liquidated entries cannot be protested through administrative channels and typically require CIT litigation for refund recovery, though CAPE may provide an alternative path.
G–H
Harmonized Tariff Schedule (HTS)
The classification system used by CBP to categorize imported goods and determine duty rates. Every product imported into the U.S. has an HTS code. IEEPA tariff codes under headings 9903.01 and 9903.02 are applied in addition to the product’s base HTS classification.
HTS 9903.01
The tariff heading for China-specific IEEPA duties, including the 20% surcharge and fentanyl-related tariffs. When you see this code on your entry summaries, it’s an IEEPA duty that’s refundable under the Supreme Court ruling.
HTS 9903.02
The tariff heading for reciprocal IEEPA duties, including tariffs on Canada, Mexico, and the countries targeted by the April 2025 reciprocal tariff proclamations. Rates varied from 10% to 145% depending on the country.
I
IEEPA (International Emergency Economic Powers Act)
The federal statute (50 U.S.C. Sections 1701–1707) that President Trump used as legal authority to impose tariffs in 2025. The Supreme Court ruled in February 2026 that IEEPA does not authorize the imposition of tariffs, making all duties collected under this authority unconstitutional and refundable. See our Supreme Court ruling analysis.
Impact Assessment
A comprehensive analysis of your import portfolio that identifies IEEPA tariff exposure, calculates refund amounts, maps entries to recovery paths, and recommends an optimal strategy. Our Impact Assessment is free and covered by NDA. See the detailed walkthrough for what’s included.
IOR (Importer of Record)
The entity legally responsible for an import entry and the recipient of any refunds associated with that entry. The IOR is identified by a unique number assigned by CBP. Refunds go to the IOR, not to the consignee, freight forwarder, or end customer.
Injunction
A court order that stops a government action. The CIT’s preliminary injunction and subsequent orders following the Supreme Court ruling stopped CBP from collecting IEEPA tariffs and directed the processing of refunds.
L
Liberation Day
April 2, 2025 — the date President Trump announced broad reciprocal tariffs under IEEPA authority, targeting imports from dozens of countries with rates ranging from 10% to 145%. These tariffs took effect on April 9, 2025, and dramatically expanded IEEPA tariff exposure beyond China, Canada, and Mexico.
Liquidation
The final computation of duties on an import entry by CBP. After liquidation, the duty amount is fixed, and the 180-day protest window begins. Entries typically liquidate approximately 314 days after filing. Unliquidated entries can be corrected through PSC; liquidated entries require protest or litigation for refund.
Liquidation Date
The specific date CBP liquidated an entry. This date starts the 180-day protest clock. You need to know this date for every liquidated entry to calculate your protest deadline.
M–N
MFN (Most Favored Nation) Rate
The standard duty rate applied to imports from countries with normal trade relations with the U.S. MFN rates are the baseline — IEEPA tariffs were applied on top of MFN rates. Your IEEPA refund covers only the IEEPA surcharge, not the underlying MFN duty.
NDA (Non-Disclosure Agreement)
A legal agreement protecting your import data when shared with a recovery firm, claim buyer, or other third party. Any legitimate firm will offer an NDA before requesting your entry data. If they don’t, ask for one. If they refuse, walk away.
Non-Recourse
A transaction structure where the buyer of your claim assumes all risk. In a non-recourse claim assignment, if CBP delays or reduces the refund, the buyer absorbs the loss — you keep your payment with no clawback. This is the standard structure for immediate capital offers.
P
Post-Summary Correction (PSC)
A modification to an entry summary that hasn’t been liquidated yet. For IEEPA refunds, a PSC removes the IEEPA tariff codes from unliquidated entries, and CBP recalculates duties without the surcharge. This is the fastest government refund path — processing takes days to weeks. Only available for unliquidated entries.
Protest (CBP Protest)
A formal challenge under 19 U.S.C. Section 1514 to the liquidation of an entry. For IEEPA refunds, a protest requests reliquidation without IEEPA duties. Must be filed within 180 days of liquidation. Processing takes 18–36 months. Can be filed with an accelerated disposition request.
Protest Window (180-Day Window)
The 180-day period after liquidation during which an importer can file a formal protest. This is a hard deadline — once it passes, administrative protest is no longer available for that entry. The window is calculated per entry based on that entry’s specific liquidation date.
R
Reciprocal Tariffs
Tariffs announced on Liberation Day (April 2, 2025) targeting imports from countries with trade surpluses with the U.S. Rates ranged from 10% (baseline) to 145% (certain countries). All imposed under IEEPA authority and therefore covered by the Supreme Court ruling. Classified under HTS 9903.02.
Reliquidation
The process of re-computing duties on an already-liquidated entry. When CBP approves a protest on an IEEPA entry, the entry is reliquidated without IEEPA duties, and the difference is refunded. This is the mechanism by which most protest-based refunds are issued.
S
Section 232 Tariffs
Tariffs on steel (25%) and aluminum (10%, later 25%) imposed under Section 232 of the Trade Expansion Act of 1962, based on national security. These are NOT IEEPA tariffs and are NOT affected by the Supreme Court ruling. Don’t include Section 232 duties in your IEEPA refund calculation.
Section 301 Tariffs
Tariffs on Chinese imports (7.5%–25%) imposed under Section 301 of the Trade Act of 1974, related to intellectual property practices. These are NOT IEEPA tariffs and are NOT affected by the Supreme Court ruling. On imports from China, you need to separate the Section 301 component from the IEEPA surcharge — only the IEEPA portion is refundable.
Statutory Interest
Interest paid by CBP on refunds under 19 U.S.C. Section 1505(c). The rate is set quarterly by the IRS. When CBP processes your IEEPA refund, statutory interest accrues from the date of overpayment. Recent rates have averaged approximately 4–5% annually. This interest partially compensates for the time value of money, but typically falls below most companies’ cost of capital.
Supreme Court Ruling
The February 20, 2026, decision in Learning Resources, Inc. v. Trump, where the Supreme Court ruled 6-3 that the President does not have authority under IEEPA to impose tariffs. This ruling is the legal foundation for all IEEPA tariff refunds. See our detailed analysis.
T–U
Tariff Classification
The process of assigning an HTS code to an imported product, which determines the applicable duty rate. For IEEPA refunds, the relevant classification is the Chapter 99 additional code (9903.01 or 9903.02) that was added to the product’s base classification.
Tariff Engineering
The practice of modifying a product’s design or composition to qualify for a lower duty classification. Not directly relevant to IEEPA refunds (the surcharge applied broadly regardless of classification), but may be relevant for ongoing duty optimization.
Unliquidated Entry
An entry where CBP has not yet made the final duty computation. Unliquidated entries can be corrected through PSC to remove IEEPA duties, making this the fastest government refund path. Check your ES-003 report for liquidation status — entries with “unliquidated” status are your highest priority for immediate filing.
V–W
WACC (Weighted Average Cost of Capital)
Your company’s blended cost of debt and equity capital. WACC is the key number in the government refund vs. claim sale analysis — it determines how much the delay in receiving your refund actually costs you. If your WACC exceeds CBP’s statutory interest rate, every day of delay erodes your refund’s real value.
WTO (World Trade Organization)
The international body governing trade rules between nations. WTO principles like most-favored-nation treatment are relevant background to the IEEPA tariff debate, but the Supreme Court ruling was based on domestic constitutional law (the scope of IEEPA authority), not WTO rules.
How to Use This Glossary
You’ll encounter most of these terms when reading about the refund process, working with your customs broker, or reviewing your entry data. When a term comes up that you don’t recognize, come back here.
For a structured walkthrough of the entire refund process using these terms in context, read our complete guide to IEEPA tariff refunds. For a step-by-step filing roadmap, see the 7-step filing guide. And for a checklist to make sure you haven’t missed anything, use the 15-item filing checklist.
If the jargon is still overwhelming — or if you’d rather skip the glossary and just get your numbers — our Impact Assessment translates all of this into a clear, actionable report specific to your company.
