The IEEPA tariff recovery is a data problem before it’s a financial problem. Every filing, every receivable, every refund projection depends on clean, complete, entry-level data that connects customs records to payment records to procurement records. As the operations manager, you’re the one who makes that data flow.
The Supreme Court’s February 2026 ruling invalidated IEEPA tariffs. The CIT’s March 4 order directed CBP to process refunds. Your finance team wants the numbers. Your compliance team wants the filing data. Your C-suite wants a timeline. All of those needs funnel through operations because you’re the one who knows where the data lives, how the systems connect, and how to extract what people need.
This guide covers the data extraction, system integration, process workflow, and team coordination that operations managers need to execute. For the full recovery context, see the complete guide to IEEPA tariff refunds.
Where the data lives
IEEPA recovery data is scattered across at least four systems in most organizations. Your first job is mapping the data landscape.
ACE Portal / Customs broker system
The ACE portal (or your broker’s mirror of it) contains the authoritative customs entry data:
- Entry summaries with HTS line items and duty amounts
- Liquidation status of each entry
- IEEPA-specific duty codes under HTS 9903 headings
- Payment status and CBP processing notes
The ES-003 report is the standard extract. Your customs broker can pull this in bulk.
ERP / Accounting system
Your ERP (SAP, Oracle, NetSuite, QuickBooks — whatever you’re running) contains:
- Duty payment records posted to the GL
- Invoice matching data that ties broker invoices to POs
- COGS allocations that include the duty component
- Vendor master records for brokers and freight forwarders
Trade management system (TMS)
If you have a dedicated TMS (Amber Road, Descartes, Integration Point, etc.), it may contain:
- Entry-level data synced from ACE
- Classification history and ruling records
- Compliance screening records
- Broker communication logs
Procurement / PO system
Your procurement system connects the customs data to business context:
- Purchase orders tied to specific shipments
- Supplier information and country of origin
- Unit pricing that reflects (or doesn’t reflect) tariff pass-through
- Contract terms relevant to tariff adjustments
| System | Key Data Elements | Who Owns It |
|---|---|---|
| ACE / Broker | Entry summaries, HTS codes, duties, liquidation status | Trade compliance / Broker |
| ERP | Duty payments, GL postings, invoice matching | Finance / AP |
| TMS | Classification history, compliance records | Trade compliance |
| Procurement | POs, supplier info, contract terms | Procurement |
Data extraction workflow
Here’s the systematic process for pulling the data everyone needs.
Step 1: Define the scope
The IEEPA tariff period runs from approximately February 4, 2025, to February 24, 2026. You need every entry filed during this period that includes an IEEPA surcharge. But don’t limit your scope too tightly:
- Include entries filed slightly before the start date (some may have been assessed IEEPA duties retroactively)
- Include entries filed slightly after the end date (some late-filed entries may reference goods that arrived during the tariff period)
- Include entries with amended or corrected summaries
Step 2: Extract the ES-003 dataset
Work with your customs broker to pull the complete ES-003 report for the IEEPA period. Request it in a machine-readable format (CSV, Excel, or XML) rather than PDF. You’ll need to filter, sort, and analyze this data.
Key fields to extract:
- Entry number
- Entry date
- Entry type (consumption, warehouse, FTZ)
- HTS line items (specifically 9903.01 and 9903.02 codes)
- Duty amount per HTS line
- Total duty per entry
- Liquidation status (unliquidated, liquidated with date, or suspended)
- Port of entry
- Country of origin
- Importer of record number
Step 3: Extract payment records
Pull duty payment data from your ERP or banking system for the same period. Match payment records to entries using:
- Entry number (if payments are per-entry)
- Statement period (if on the periodic monthly statement program)
- Broker invoice number (if broker prepaid duties)
Step 4: Extract procurement context
Pull purchase orders and supplier data that correspond to the customs entries. The link is usually through the commercial invoice number or bill of lading number, which appears on both the PO acknowledgment and the entry summary.
Step 5: Build the master dataset
Merge the three extracts into a single master dataset with one row per entry. Each row should contain:
- All customs data (entry number, HTS, duties, liquidation status)
- Payment data (payment date, payment amount, payment method)
- Procurement data (PO number, supplier, product description, unit cost)
- Recovery path assignment (PSC, protest, CIT, or immediate capital)
- Deadline dates (180-day protest window expiration)
This master dataset is the single source of truth for the entire recovery effort.
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System integration challenges
In an ideal world, these four data sources would link cleanly. In reality, most companies face at least some of these integration challenges:
Missing entry-to-PO links
The customs entry number and the purchase order number are tracked in different systems with no automatic cross-reference. You may need to use the commercial invoice number, supplier name, or shipment date as a matching key. For consolidated shipments (multiple POs on one entry), the matching is more complex.
Workaround: Start with the broker’s file, which often includes the commercial invoice number. Match that to the PO system. Where automatic matching fails, use date ranges and supplier names to narrow the manual matching.
PMS payment aggregation
If your company pays duties through the periodic monthly statement program, one bank debit covers all entries for the month. You can’t trace a single payment to a single entry from the bank data alone.
Workaround: Use the ES-003 data to identify IEEPA duties per entry. The sum of IEEPA duties for all entries in a given PMS period should correspond to the IEEPA portion of that month’s aggregate payment. This gives you entry-level allocation even when the payment is aggregated.
Historical data gaps
Some companies don’t retain detailed customs data beyond the current year. If your broker’s data retention is longer than your internal retention, the broker may be the best source for older entries from early in the IEEPA period.
Workaround: Request a full data extract from your broker going back to February 2025. Supplement with any internal records available. The ACE portal retains entry data for at least five years.
Multi-broker complexity
If you used different brokers for different ports, origins, or product lines during the IEEPA period, you’ll need to extract data from each broker separately and merge the datasets. Watch for:
- Different data formats across brokers
- Duplicate entries if both brokers handled parts of the same shipment
- Gaps if neither broker tracked certain entries
Process workflow design
Once you have the data, you need a repeatable workflow for processing the recovery. Here’s a standard framework:
Intake and validation
- Receive master dataset (from data extraction process above)
- Validate completeness: does every known import from the IEEPA period appear?
- Validate accuracy: do duty amounts match between ACE data and payment records?
- Flag exceptions: entries with missing data, discrepancies, or complications
Path assignment
- Assign each entry to a recovery path based on liquidation status
- Prioritize entries approaching the 180-day protest deadline
- Identify entries that may benefit from immediate capital rather than government processing
Filing execution
- Transmit PSC instructions to broker for unliquidated entries
- Transmit protest instructions to broker for liquidated entries in the window
- Refer entries outside the window to legal for CIT evaluation
- Track filing confirmations and CAPE queue positions
Monitoring and close-out
- Monitor for liquidation events on remaining unliquidated entries
- Track refund payments as they arrive
- Reconcile received refunds against expected amounts
- Close out entries as refunds are received
- Report progress to finance and management weekly
Exception handling
- Investigate CBP questions or requests for additional information
- Resolve documentation gaps with broker or procurement
- Escalate denied claims to legal
- Document every exception and its resolution
Team coordination framework
As operations manager, you’re the hub connecting at least four teams. Here’s the coordination structure:
Daily stand-up (during active filing period)
A 15-minute check-in with:
- Your broker (filing progress, any CBP pushback)
- Trade compliance (liquidation events, deadline alerts)
Weekly coordination meeting
A 30-minute meeting with:
- Finance (receivable status, cash flow updates)
- Trade compliance (filing progress, exception log)
- Procurement (documentation requests, supplier coordination)
- Legal (CIT entries, downstream exposure)
Monthly management report
A one-page status report covering:
- Total entries identified vs. filed vs. recovered
- Dollar amounts: total eligible, filed, recovered, pending
- Deadlines: entries approaching the 180-day window
- Exceptions: open issues and resolution timelines
Escalation path
Define a clear escalation path for issues that operations can’t resolve:
- Data discrepancies → Trade compliance and broker
- Payment questions → AP and finance
- Documentation gaps → Procurement and broker
- Legal complications → General counsel
- Strategic decisions → CFO or CEO
Technology considerations
If your company has more than 100 IEEPA-period entries, manual tracking becomes unwieldy. Consider these technology approaches:
Spreadsheet with structured template. For smaller portfolios (under 500 entries), a well-designed Excel or Google Sheets workbook with tabs for the master dataset, filing tracker, reconciliation, and exception log may be sufficient.
Customs management platform. If you already have an ACE-integrated TMS, check whether it supports recovery tracking. Some platforms have added IEEPA-specific modules.
Project management tool. For larger portfolios, a project management tool (Asana, Monday.com, or similar) can track individual entries as tasks, with deadlines, assignments, and status workflows.
Automated alerts. Set up automated alerts for:
- Entries approaching the 180-day protest deadline (30-day and 7-day warnings)
- New liquidation events
- Incoming CBP refund payments
- Exception items that have been open for more than 5 business days
Quality control checkpoints
Build quality control into the process at three critical points:
Checkpoint 1: Data validation. Before any filings begin, verify that the master dataset is complete and accurate. Cross-check total IEEPA duties against finance’s records. Confirm liquidation statuses are current. This prevents filing on wrong entries or missing eligible entries.
Checkpoint 2: Filing accuracy. Before each batch of PSCs or protests is transmitted to the broker, review the filing instructions for accuracy. Confirm entry numbers, duty amounts, and legal basis. A filing error doesn’t just delay recovery — it can create compliance issues.
Checkpoint 3: Refund reconciliation. When refund payments arrive, verify amounts against expected recovery before applying cash. Investigate any variance before closing the entry. This catches CBP errors and ensures your receivable balance is accurate.
Lessons from high-performing recovery operations
Companies that have executed IEEPA recovery most efficiently share several operational characteristics worth emulating:
Centralized data ownership. The best-performing companies designated a single person or team as the owner of the master recovery dataset. This person controlled data quality, resolved discrepancies, and served as the single point of contact for all stakeholders. Distributed ownership creates gaps and duplication.
Standardized communication cadence. Weekly status emails with a consistent format — entries filed this week, cumulative filings, deadlines approaching, exceptions outstanding — keep all stakeholders informed without requiring meetings for routine updates. Save meetings for decision-making and problem-solving.
Parallel processing. The fastest operations file PSCs and protests simultaneously rather than sequentially. While the broker processes PSC filings on unliquidated entries, the compliance team prepares protest packages for liquidated entries. The two workstreams can run in parallel with different teams.
Proactive exception management. Rather than waiting for CBP to flag documentation issues, top-performing operations review entries for potential complications before filing. Entries with ambiguous country of origin, classification questions, or incomplete documentation are flagged and researched proactively. This prevents delays in the processing queue.
Automated deadline monitoring. Manual tracking of the 180-day protest window is error-prone, especially for companies with hundreds or thousands of entries. The best operations use automated alerts that trigger at 90 days, 60 days, 30 days, and 7 days before each deadline. This is non-negotiable for high-volume importers.
Clear escalation protocols. When an issue arises that operations can’t resolve — a CBP denial, a missing document, a classification dispute — the escalation path is predefined. Everyone knows who to call, what information to provide, and what the expected response time is. No issue should sit unresolved for more than 5 business days.
Post-recovery process improvement
Once the IEEPA recovery is substantially complete, operations should conduct a retrospective:
What data was hardest to obtain? If commercial invoices from 2025 were difficult to locate, that points to a document retention problem. Fix it now for future reference.
Where did the systems break down? If matching entry numbers to PO numbers required extensive manual work, invest in system integration or data architecture improvements.
Which brokers performed best? Rate your customs brokers on data quality, filing accuracy, responsiveness, and proactive communication. Use this assessment for broker consolidation or performance improvement conversations.
How accurate were the timeline estimates? Compare actual CBP processing times against your projections. This data improves future forecasting for any government receivable.
What would you do differently? Document the answer and file it where the next operations manager can find it. Institutional memory matters.
Getting the process started
Don’t wait for perfect data to start the process. Start with what you have and iterate:
- Today: Request the ES-003 report from your customs broker
- This week: Begin building the master dataset
- Next week: Identify entries approaching the 180-day deadline and instruct the broker to file
- Within 30 days: Complete the data extraction, path assignment, and filing instructions
The Impact Assessment accelerates this entire process by providing the entry-level analysis in a standardized format. Instead of building the master dataset from scratch, you get it delivered — with liquidation status, path assignments, deadline mapping, and estimated recovery amounts already calculated.
Scaling the process for large portfolios
Companies with more than 1,000 IEEPA-period entries need a scaled approach:
Batch processing. Rather than filing entries one at a time, batch them into groups of 50-100 for broker transmission. Group by recovery path (all PSCs together, all protests together) and by priority (deadline-sensitive first, then highest-dollar, then remainder).
Parallel workstreams. Split the work between multiple team members or between the internal team and external advisors. One person handles PSC-eligible entries while another manages protest-eligible entries. A third handles exceptions and documentation gaps.
Milestone-based tracking. For large portfolios, use milestones rather than entry-level status for management reporting: “Phase 1: All PSCs filed (complete). Phase 2: Priority protests filed (75% complete). Phase 3: Remaining protests (in progress). Phase 4: CIT evaluation (pending).”
Resource allocation. Estimate the internal time required for the recovery: data extraction (1-2 weeks), filing coordination (2-4 weeks), ongoing monitoring (2-4 hours/week for 24 months). If this exceeds available capacity, budget for temporary help or external support.
The Impact Assessment is specifically designed to accelerate the data extraction and analysis phases for large-portfolio companies, reducing what might take weeks of internal work to a streamlined, standardized output.
Request your free Impact Assessment and get the data your operations team needs →
