How to Prepare Your Data Before Requesting an IEEPA Assessment

The difference between a five-day assessment turnaround and a two-week turnaround is almost always data preparation. Importers who show up with their broker data organized and their internal records identified get faster, more precise results. Importers who start from scratch after requesting the assessment add a week of broker back-and-forth before the analysis can begin.

You don’t need perfect data. You don’t need every document for every entry. But having the right pieces in the right format before you request your Impact Assessment dramatically improves the experience and the output.

Here’s exactly what to gather, where to find it, and how to organize it.

The Critical Data: ACE Portal Reports

The single most important data source for your IEEPA recovery assessment is your customs data from the ACE (Automated Commercial Environment) portal. Your customs broker has access to this system and can pull the reports you need.

The ES-003 Report

The ES-003 is the entry summary status report. It shows every entry filed during a specified period, along with each entry’s current status — most importantly, whether it’s been liquidated or is still unliquidated.

Why this matters: the liquidation status of each entry determines which recovery path applies. Unliquidated entries can be corrected through Post-Summary Correction — the fastest and simplest path. Liquidated entries require a formal protest within the 180-day window, or CIT litigation if the window has closed. Without the ES-003, we’re guessing at entry statuses, and guessing leads to less accurate recovery projections.

How to get it: Ask your customs broker to pull your ES-003 report from ACE for all entries between February 4, 2025, and February 24, 2026. If you need a ready-to-send request, use our template email for customs brokers.

Format: The report typically comes as a CSV or Excel file. Either is fine. Don’t reformat it — the raw ACE output is what we need.

The Entry Summary Data

Beyond the ES-003, your broker can pull detailed entry summary data that includes:

• Entry numbers
• Entry dates
• Ports of entry
• HTS classification codes
• Duty amounts by tariff line
• Country of origin
• Importer of record information

This data allows us to identify exactly which entry lines carried IEEPA-specific duties under HTS headings 9903.01 and 9903.02, rather than estimating based on product categories and country mix.

How to get it: Same request to your customs broker. Most brokers can pull entry summary detail alongside the ES-003 in a single data extraction.

Multiple Brokers

If you’ve used different customs brokers during the IEEPA period — for different ports, product lines, or time periods — you need data from all of them. This is one of the most common sources of incomplete assessments. Importers forget about a secondary broker who handled a few months of entries, or a broker used for a specific port, and those entries get missed.

Make a complete list before you start:

Send data requests to all brokers simultaneously. Don’t wait for one to respond before contacting the next — that sequential approach adds unnecessary days.

Financial Records

Your internal financial records serve as a cross-reference to validate broker data and fill gaps where ACE data is incomplete.

Customs Duty Payment Records

Your accounts payable or ERP system should show payments to CBP (usually routed through your customs broker). These records confirm the total duties paid and help identify any discrepancies between what ACE shows and what you actually paid.

Where to find it: Look for payments to your customs broker that include duty reimbursement, or direct payments to CBP if you use a periodic monthly statement (PMS) or daily statement. Your controller or AP team can usually pull this with a vendor filter and date range.

What we need: A summary by month showing total customs duties paid during the IEEPA period. Entry-level detail is better if available, but monthly summaries work for the initial assessment.

Broker Invoices

Your customs broker invoices typically itemize duties, taxes, and fees for each entry or group of entries. These serve as a backup data source when ACE data isn’t available or when you need to reconcile discrepancies.

Where to find it: Your AP files, broker’s client portal, or email archives.

What we need: Invoices from the IEEPA period that show entry-level duty amounts. You don’t need to organize or index them — just locate them so they’re accessible if questions arise during the analysis.

Prior Protest Filings

If your broker or trade attorney has already filed any protests on IEEPA entries, we need to know about them. Duplicate filings waste time and can create procedural complications.

Check with: Your customs broker, any trade counsel you’ve engaged, and your internal trade compliance team if you have one.

Organizational Context

Beyond raw data, certain organizational context helps us tailor the assessment to your actual situation.

Import Profile Summary

A one-paragraph description of your import operations is surprisingly useful. Something like:

“We import consumer electronics primarily from China and Vietnam. Annual import value approximately $15 million. Single customs broker (XYZ Customs) covering all entries at Port of Long Beach and Port of Newark. No prior trade compliance actions or protests filed.”

This context helps us anticipate the types of entries we’ll see, the likely IEEPA duty rates, and potential complications before we open the data file.

Business Priorities

Understanding what matters to you shapes the analysis. Specifically:

• Is speed important? If you need capital quickly, we’ll weight the immediate capital option more heavily in the analysis.
• What’s your cost of capital? This drives the present-value calculations. If you know your WACC or credit line rate, share it. If not, we’ll use a reasonable estimate and you can adjust.
• Are there specific entries you’re worried about? Entries approaching protest deadlines, entries with classification questions, or entries with missing documentation — flag these upfront.
• Who’s the decision maker? If the person requesting the assessment needs to present results to a CFO or board, we’ll structure the deliverable accordingly. See our guide on presenting IEEPA recovery to your board.

Authorized Contacts

Let us know who we can communicate with about your assessment:

• Primary contact for day-to-day questions
• Customs broker contact (if you’d like us to coordinate data requests directly)
• Decision maker who will review the final assessment

Having authorized contacts identified upfront prevents the back-and-forth of “let me check if I can share this with your broker” that slows many assessments down.

The Preparation Checklist

Here’s a printable checklist to work through before requesting your assessment:

Must Have (Assessment Cannot Proceed Without These)

• Company name, contact information, and authorized contacts
• Estimated annual import volume during IEEPA period
• Primary countries of origin
• General product categories imported
• Customs broker name(s) and contact information

Strongly Recommended (Significantly Improves Quality and Speed)

• ES-003 report from ACE (requested from broker)
• Entry summary data with HTS codes and duty amounts
• Liquidation status for all entries
• Total IEEPA duties paid (from AP records or broker invoices)
• List of any prior protest filings or recovery actions

Helpful Context (Enhances the Analysis)

• Import profile summary (one paragraph)
• Business priorities (speed vs. maximum recovery)
• Cost of capital / WACC estimate
• Known complications (multiple brokers, documentation gaps, etc.)
• Decision timeline and decision maker identification

Nice to Have (Not Required but Useful If Available)

• Monthly duty payment summaries from AP
• Broker invoices for the IEEPA period
• Commercial invoices for high-value entries
• Bill of lading copies
• Any correspondence from CBP regarding your entries

Data Organization Tips

You don’t need to create elaborate file structures. A simple approach works best.

Single Folder Method

Create one folder — physical or digital — labeled “IEEPA Recovery.” Put everything in it. Don’t sub-sort at this stage. The assessment team will tell you if specific documents need to be organized differently.

Naming Conventions

If you’re sending multiple files, name them clearly:

• ES003_CompanyName_Feb2025-Feb2026.csv
• Entry_Summary_Detail_CompanyName.xlsx
• AP_Duty_Payments_CompanyName_2025-2026.pdf
• Broker_Invoices_CompanyName_Q1-Q4_2025.zip

Clear file names prevent confusion when multiple people are handling the data.

Spreadsheet Format

If you’re creating a summary spreadsheet to accompany your broker data, use these columns:

Leave any unknown fields blank — don’t guess or fill in placeholders. Blank fields are better than wrong data.

What to Do If Your Broker Is Slow

Broker response times vary. Some pull ACE data in hours; others take a week. If your broker isn’t responding promptly, here are your options:

Escalate within the brokerage. If your primary contact isn’t responsive, ask to speak with a supervisor or the firm’s trade compliance lead. IEEPA recovery is a priority for brokers too — see the customs broker guide to IEEPA recovery revenue.

Start with internal records. Submit your assessment request with whatever you have — AP records, broker invoices, even rough estimates. We can begin the analysis with internal data and refine when ACE data arrives. The assessment doesn’t have to wait for perfect data.

Consider direct ACE access. If you’re the importer of record, you may be able to request direct access to ACE for your entries. This is unusual for most importers but worth exploring if your broker relationship is strained.

Request the assessment anyway. Don’t let broker delays prevent you from starting the process. We work with the data available and iterate as more comes in. The cost of waiting compounds daily — starting with imperfect data is better than waiting for perfect data.

Common Data Pitfalls

Having processed hundreds of assessments, we see these mistakes repeatedly.

Overlooking Entries at the Period Boundaries

The IEEPA period runs February 4, 2025, through February 24, 2026. Entries filed on or very near those boundary dates sometimes get misclassified. Entries that arrived at the port before February 4 but were entered after that date may carry IEEPA duties. Entries filed in the last days of the period may have been processed differently. Pull data with a buffer — start from January 2025 and extend through March 2026 — to catch everything.

Confusing Duty Types

IEEPA duties appear under HTS headings 9903.01 and 9903.02. Some entries also carry Section 301 or Section 232 duties. Only the IEEPA-specific duties are refundable under the Supreme Court ruling. If your data doesn’t distinguish between duty types, your broker can help separate them.

Assuming All Entries Are With One Broker

We see this constantly: an importer provides data from their primary broker, and the assessment reveals a gap — entries during a month when a different broker handled a plant relocation, or entries through a secondary port covered by a regional broker. Check your AP records for payments to any customs-related vendors you might have forgotten about.

Not Checking for Existing Actions

If your broker has already filed PSCs or protests on some entries, those need to be excluded from or flagged in the assessment to avoid duplicate filings. Always ask before you submit.

Your Data Is Safe

We understand the sensitivity of import data. Your entry data contains commercially valuable information — product classifications, sourcing patterns, cost structures, supplier relationships. We protect it accordingly.

All data is transmitted via encrypted channels, stored in access-controlled systems, and handled only by authorized assessment team members. We execute mutual NDAs upon request and can accommodate specific data security requirements your organization may have. For a detailed overview of our security practices, see our guide on NDA and data security requirements.

The Data Preparation Timeline

Here’s a realistic timeline for data preparation, from initial request to assessment-ready:

Total: approximately 5-7 business days from first request to assessment-ready data package. This timeline assumes reasonably responsive brokers. Add 3-5 days if your broker is slow.

Parallel Processing

The most important efficiency: submit your Impact Assessment request on Day 1, simultaneously with your broker data request. The assessment team can begin intake, scheduling, and preliminary analysis while you’re gathering data. By the time your broker data arrives, the assessment team is ready to start analysis immediately rather than beginning their intake process.

This parallel approach can save 5-7 days compared to the sequential approach of gathering all data first, then requesting the assessment.

What to Do With Imperfect Data

Real-world data is messy. Here’s how to handle common imperfections without letting them delay your assessment.

Estimated Duty Amounts

If you can’t get entry-level IEEPA duty amounts from your broker quickly, estimate from your AP records. Look at total customs duties paid during the IEEPA period and estimate the IEEPA portion based on your country mix and product types. The assessment team can refine these estimates when precise data arrives.

Unknown Liquidation Statuses

If you don’t have your ES-003 report yet, assume that entries filed more than 10 months ago are likely liquidated and entries filed within the last 8 months may still be unliquidated. This is an approximation based on the average 314-day liquidation cycle. Precise statuses matter for strategy — but approximate statuses are sufficient for initial assessment scoping.

Gaps in Entry Records

If you know some entries are missing from your data — perhaps from a broker transition period or a secondary broker you haven’t contacted yet — note the gap in your submission. Include your best estimate of the missing entries (e.g., “approximately 15 additional entries from May-July 2025 through secondary broker, estimated $85,000 in IEEPA duties”). The assessment will be clearly marked as preliminary for those entries.

Start Now, Refine Later

The most important thing to remember about data preparation is this: don’t let it become a reason to delay. The assessment process is designed to be iterative. You can start with whatever you have today and add data as it becomes available.

Every day you spend perfecting your data package before requesting an assessment is a day closer to potential protest deadline expirations, a day further back in the CAPE queue, and a day of time value erosion on your refund.

Get your free Impact Assessment →

Gather what you can, submit the request, and let the assessment process guide you to whatever additional data is needed. That’s what it’s designed for. Start today — your refund clock is already running.