Most IEEPA recovery guides assume you have a few hundred entry summaries. That’s a reasonable assumption for a mid-size importer. But what happens when you’re filing 50,000 or more entries per year? When your IEEPA exposure is measured in nine figures? When your customs brokerage operation spans multiple providers across different divisions, and your internal systems were never designed to aggregate tariff data at this scale?
This is the challenge facing America’s largest importers — the retailers, manufacturers, and distributors whose supply chains move billions of dollars in goods through U.S. ports every year. We’ll walk through the scenario of a company we’ll call Continental Industries, a diversified industrial manufacturer and distributor with operations across four business units, three customs brokers, and approximately 52,000 IEEPA-affected entry summaries totaling $145 million in refundable duties.
The principles of IEEPA recovery are the same at any scale. But the execution at enterprise scale introduces challenges that simply don’t exist for smaller importers.
The Enterprise Data Problem
Continental Industries’ first challenge wasn’t legal or procedural — it was informational. They didn’t have a single view of their IEEPA exposure.
Each of Continental’s four business units managed its own import operations semi-independently. The Automotive Parts division used one customs broker. The Electronics Components division used another. The Industrial Machinery division used a third, and the Consumer Products division used the same broker as Automotive but under a different account structure. Each division tracked tariff costs differently — some in their ERP, some in spreadsheets, some not at all.
Pulling an ES-003 report from each broker was straightforward in theory but complex in practice. The reports came in different formats, covered different date ranges, and used inconsistent field naming conventions. Just normalizing the data into a single master file took Continental’s trade compliance team two weeks.
The numbers that emerged were staggering:
| Business Unit | Entries | IEEPA Duties | Brokers |
|---|---|---|---|
| Automotive Parts | 18,200 | $52,000,000 | Broker A |
| Electronics Components | 14,800 | $41,000,000 | Broker B |
| Industrial Machinery | 9,500 | $28,000,000 | Broker C |
| Consumer Products | 9,500 | $24,000,000 | Broker A (separate account) |
| Total | 52,000 | $145,000,000 | 3 brokers |
The Supreme Court ruling made clear that every dollar of these duties was refundable. But converting $145 million in theoretical refunds into actual cash required an operation that Continental had never built.
Why Standard Recovery Approaches Don’t Scale
A mid-size importer with 400 entries can have their customs broker file PSCs and protests manually, reviewing each entry individually. At 52,000 entries, manual review is impossible. Continental needed to automate the categorization, validation, and filing process — or spend months working through entries one at a time while their CAPE queue position fell further behind.
The specific scaling challenges:
Data validation. At 52,000 entries, even a 1% error rate means 520 entries with issues. Continental needed automated cross-referencing between ES-003 data, broker records, and internal PO data to flag discrepancies at scale.
Liquidation status tracking. With entries spread across 12 months, the split between unliquidated and liquidated entries was constantly changing. Entries that were unliquidated when the project started would liquidate during the weeks it took to prepare filings. Continental needed real-time status monitoring.
Deadline management. The 180-day protest window was approaching closure on their earliest entries. With 18,200 entries from the Automotive division alone, identifying which specific entries had the tightest deadlines required sorting and prioritization logic that manual review couldn’t deliver.
Multi-broker coordination. Filing through three different brokers meant three different workflows, three different timelines, and three different levels of capability. Broker B was highly automated and could process bulk filings efficiently. Broker C was a smaller regional firm that handled Industrial Machinery entries manually.
Building the Recovery Operation
Continental’s approach was to treat IEEPA recovery as a project — with a project manager, a timeline, milestones, and accountability. Their VP of Global Trade Compliance was assigned ownership, and a cross-functional team was assembled from trade compliance, finance, IT, and each business unit’s operations team.
Phase 1: Data Consolidation (Weeks 1-3)
The first phase was getting a unified data set. Continental’s IT team built an extraction pipeline that pulled ES-003 data from all three brokers, normalized the field names, and loaded everything into a database. Each entry was enriched with:
- Liquidation status (unliquidated, liquidated with open protest window, liquidated with closing window)
- IEEPA tariff rate applied (20% or 34%)
- HTS classification at the line level
- Country of origin
- Business unit assignment
- Original broker
This database became the single source of truth for the entire recovery operation. Every decision — prioritization, filing strategy, financial planning — was driven by queries against this data set.
Phase 2: Prioritization and Triage (Weeks 3-4)
With data consolidated, Continental’s team ran a triage analysis that sorted entries into priority tiers:
Tier 1 — Critical deadline (3,200 entries, $9.1M): Liquidated entries with protest windows closing within 60 days. These needed immediate protest filings to preserve recovery rights. Missing the deadline would force these into CIT litigation, costing potentially $1-2 million in legal fees on top of years of delay.
Tier 2 — Unliquidated, ready to file (31,400 entries, $87M): Entries eligible for Post-Summary Correction with complete documentation. These represented the fastest government refund path and the largest portion of the portfolio.
Tier 3 — Liquidated, standard window (12,800 entries, $36.5M): Entries requiring protest filings but with comfortable deadline margins. These could be filed in batches over 4-6 weeks without deadline risk.
Tier 4 — Documentation issues (4,600 entries, $12.4M): Entries where data discrepancies, missing documents, or classification questions needed resolution before filing.
Phase 3: Execution (Weeks 4-12)
The Tier 1 entries were filed first. Continental’s three brokers were given explicit priority instructions — drop everything else and file these 3,200 protests. The filings were completed in 10 business days.
Tier 2 filings (PSCs) began in Week 5 and continued through Week 10. The volume was enormous — 31,400 entries processed in batches of 500-1,000 per week across three brokers. Broker B’s automated systems handled their allocation efficiently. Broker C, the smaller regional firm, struggled with the volume and fell behind schedule, eventually requiring Continental to bring in supplemental filing support.
Tier 3 protests were filed in Weeks 8-12, running in parallel with the later Tier 2 batches.
Tier 4 entries required individual investigation. Continental assigned a team of three analysts to work through the 4,600 problem entries, resolving discrepancies, obtaining missing documents from suppliers, and correcting classification errors. This work extended into Month 4 and is still ongoing for approximately 800 entries.
The Financial Engineering Layer
At $145 million in expected refunds, Continental’s recovery wasn’t just a trade compliance project — it was a major financial event that required board-level planning.
Impact on Financial Statements
Continental’s controller needed to determine how to account for the expected refunds under ASC 450 and related guidance. The key questions:
- When can the refund be recognized as a receivable? For PSC entries already accepted by CBP, recognition was relatively straightforward. For protest entries still in queue, the probability assessment required legal analysis.
- How should the refund be classified on the balance sheet? Current vs. non-current depended on expected collection timeline — CAPE queue estimates of 12-18 months put some tranches in the non-current category.
- What’s the tax treatment? The $145 million in refunds would flow through Continental’s income statement, creating a significant tax event that needed to be coordinated with their tax planning. See our tax implications guide for the general framework.
Working Capital Strategy
Continental’s CFO saw the IEEPA recovery as an opportunity to optimize the company’s capital structure. The $87 million in PSC refunds would arrive within 2-3 months — a massive cash infusion that needed to be planned for.
The company decided to:
- Use PSC refunds ($87M) to pay down their revolving credit facility, saving approximately $5.2 million per year in interest at their current borrowing rate
- Assign $15M of protest claims to immediate capital providers at a negotiated discount, generating approximately $12.75 million in near-term cash for a strategic acquisition that was time-sensitive
- Hold remaining protest claims ($33.5M) for full-value government recovery through CAPE
The government filing vs. immediate capital analysis looked different at this scale. Continental had the financial sophistication to optimize the blend — taking immediate capital where the use of proceeds justified the discount and waiting for full value where they could afford to.
Multi-Entity Coordination
Continental Industries is a single company, but many enterprise importers operate through multiple legal entities. Continental’s four business units all imported under the same IOR number, which simplified their filing. But they had a subsidiary — Continental Mexico S.A. de C.V. — that imported components into the U.S. under its own IOR number for a contract manufacturing operation in El Paso.
The subsidiary’s IEEPA exposure was $3.2 million across 1,800 entries. Because it was a separate legal entity with a separate IOR, its refund claims had to be filed independently. Continental’s trade compliance team coordinated the subsidiary’s filings in parallel with the parent company’s, but the subsidiary required its own ES-003 reports, its own broker coordination, and its own financial treatment.
This is a common issue for corporate groups — each IOR files separately, even if the entities are under common ownership. If you have subsidiaries, divisions, or affiliates that import independently, each one needs its own recovery process.
Broker Performance and Accountability
One of the unexpected outcomes of Continental’s recovery project was that it exposed significant performance differences among their three customs brokers.
Broker B processed their allocation of 14,800 entries with minimal errors and ahead of schedule. Their systems were built for high-volume automated filing, and their trade compliance team proactively flagged issues before they became problems.
Broker A handled 27,700 entries (Automotive + Consumer Products) competently but slowly. Their batch processing capabilities were adequate but not optimized for this scale of filing.
Broker C, handling 9,500 Industrial Machinery entries, fell behind schedule repeatedly and had a 3.2% error rate on initial filings — meaning roughly 300 entries had to be corrected and refiled. At Continental’s scale, a 3.2% error rate across the entire portfolio would have meant 1,660 problem entries.
Continental’s trade compliance VP told me: “The IEEPA recovery process was the most rigorous test our brokerage relationships have ever been through. It’s one thing to file entries day to day. It’s another thing entirely to remediate an entire year of entries under deadline pressure. We learned a lot about which brokers can operate at scale.”
If you’re an enterprise importer, the quality of your customs broker’s IEEPA work is a major variable in your recovery. Consider auditing their performance early in the process rather than discovering problems after deadlines have passed.
Current Status and Projected Recovery
As of late March 2026, Continental’s recovery status looks like this:
| Category | Entries | Duties | Status |
|---|---|---|---|
| PSC filed and accepted | 28,200 | $78M | Refunds processing — first tranche received |
| PSC filed, pending CBP processing | 3,200 | $9M | In CBP queue |
| Protests filed (Tier 1) | 3,200 | $9.1M | Awaiting CAPE processing |
| Protests filed (Tier 3) | 12,800 | $36.5M | Awaiting CAPE processing |
| Claims assigned to immediate capital | — | $15M | $12.75M received |
| Documentation issues (in progress) | 3,800 | $10.2M | Analyst team working through |
| Documentation issues (unresolved) | 800 | $2.2M | Pending supplier documentation |
| Total | 52,000 | $145M | ~$100M filed or received |
Continental expects to recover approximately $140 million of their $145 million exposure, with the difference attributable to the immediate capital discount and a small number of entries that may prove unrecoverable due to documentation gaps.
Lessons for Enterprise-Scale Data Management
Continental’s recovery highlighted a gap that exists in most large companies: there’s no single system that provides a real-time view of customs duty exposure across the enterprise. ERP systems track purchase orders and invoices. Broker systems track entries and duties. But the two don’t always talk to each other, and neither provides the kind of portfolio-level analysis that IEEPA recovery requires.
Post-recovery, Continental invested in building a customs data warehouse that consolidates entry data from all brokers and links it to internal procurement data. The goal is simple: if another tariff event occurs, Continental wants to know its exposure within 48 hours — not 3 weeks.
This kind of infrastructure isn’t just for IEEPA. It supports ongoing compliance, duty optimization, drawback programs, and FTZ management. The IEEPA recovery was the catalyst, but the benefit is permanent.
The Role of Technology at Scale
Continental’s trade compliance VP noted that the companies best positioned for IEEPA recovery were those with existing trade management software — platforms like Descartes, Integration Point, or TradeEdge that provide automated entry tracking, classification management, and compliance monitoring. These systems can generate the equivalent of an ES-003 report in minutes rather than weeks, and they maintain real-time liquidation status tracking that eliminates the risk of missed protest deadlines.
If you’re an enterprise importer without trade management software, the IEEPA experience is a compelling business case for investing in one. The cost of the software is typically a fraction of the recovery it enables in a single tariff event.
What Enterprise Importers Should Take Away
If you’re managing IEEPA recovery at scale — thousands or tens of thousands of entries — here are the critical lessons from Continental’s experience:
Treat it as a project, not a task. Assign ownership, build a team, set milestones. Recovery at scale doesn’t happen through normal-course broker interactions.
Consolidate data first. You can’t prioritize what you can’t see. Build a single data set across all brokers and entities before making any filing decisions.
Automate wherever possible. Manual review at 50,000 entries is a path to missed deadlines and errors. Invest in data normalization and automated categorization.
Triage ruthlessly. Deadline-sensitive entries first, always. The cost of missing a protest window at enterprise scale can be measured in millions.
Evaluate broker capability early. Not every broker can handle high-volume remediation. Know their limitations before you’re mid-process.
The first step for any enterprise recovery is the same as for any size importer — understanding what you’re owed. Get your free Impact Assessment →
At enterprise scale, the Impact Assessment isn’t just a financial summary — it’s the project charter for a recovery operation that will touch trade compliance, finance, IT, and senior leadership. The sooner you start, the better your filing position when CAPE launches, and the sooner $145 million — or whatever your number is — starts flowing back to your balance sheet. Request your ES-003 reports from every broker today.
