The Supply Chain VP's Action Plan for IEEPA Recovery

You’ve been managing through the most disruptive tariff environment in decades. IEEPA surcharges changed your sourcing math, strained supplier relationships, and forced operational pivots that nobody planned for. Now the Supreme Court has struck those tariffs down, and everything you paid between February 2025 and February 2026 is potentially recoverable.

As VP of Supply Chain, you’re sitting on the data that makes this recovery possible. Your broker relationships, your ACE access, your entry records — these are the operational foundation of every recovery filing. Finance can model the receivable. Legal can manage the risk. But without supply chain driving the data extraction and broker coordination, nothing moves.

Here’s your action plan. For the full legal and financial context, see the complete guide to IEEPA tariff refunds.

Phase 1: Data extraction and inventory (Week 1)

Everything starts with data. You need a complete picture of your IEEPA exposure before anyone can file anything, model anything, or decide anything.

Pull your ES-003 report

The ES-003 report from the ACE portal is the master dataset. It shows every entry summary filed during the IEEPA period, including HTS codes, duty amounts, and liquidation status. Your customs broker can pull this, or if you have direct ACE access, you can pull it yourself.

What you’re looking for:

• Every entry with HTS 9903.01 or 9903.02 codes — these are the IEEPA surcharge headings
• The liquidation status of each entry: unliquidated, liquidated (with date), or under review
• The total IEEPA duty amount for each entry
• The entry date and entry port

Sort the data into three buckets:

The middle bucket is the most time-sensitive. Entries that have been liquidated are on a countdown — 180 days from liquidation to file a protest. Miss it, and your only option is expensive litigation. Run the date math on every entry and flag anything within 60 days of the deadline for immediate action.

Cross-reference with procurement records

Your ES-003 data tells you what duties were paid. Your procurement records tell you what was bought, from whom, and for what purpose. Cross-referencing these datasets helps you:

• Verify that every IEEPA-eligible entry is captured (no entries missed)
• Connect duty payments to specific suppliers and purchase orders (needed for downstream analysis)
• Identify any entries with country-of-origin questions that might complicate the recovery
• Quantify the impact by supplier, by product category, and by business unit

Quantify the total opportunity

Before bringing this to the C-suite, have the number. Total IEEPA duties paid. Total estimated statutory interest. Total potential recovery. Break it down by recovery path (PSC, protest, CIT) and by timeline (near-term, 18 months, 24+ months).

The Impact Assessment does this analysis for you, but if you want a preliminary number to drive internal urgency, your ES-003 data and a spreadsheet will get you close.

Phase 2: Broker coordination (Week 2)

Your customs broker is the operational executor for PSC filings and protests. They need clear instructions, and you need to manage their workload and priorities.

Broker selection and capacity

If you use a single broker for all entries, the coordination is straightforward. If you use multiple brokers — different brokers for different ports, different product lines, or different origins — you’ll need to coordinate across all of them.

Questions to ask your broker:

• Have you already begun filing PSCs or protests for our IEEPA entries?
• What’s your current capacity for recovery filings? How many can you process per week?
• What’s your fee structure for PSCs and protests? Is this covered under our existing service agreement?
• Are you tracking liquidation events on our entries and alerting us when the protest window opens?

Some brokers have been proactive and have already started filing for their clients. Others are waiting for instruction. Don’t assume your broker is on it — confirm and direct.

Filing prioritization

Not all entries should be filed simultaneously. Prioritize based on:

1. Entries closest to the protest deadline. These have the highest urgency and the highest cost of missing.
2. Highest-dollar entries. Recover the most money fastest.
3. PSC-eligible entries. These process fastest, so file them early to get capital back sooner and secure a better CAPE queue position.
4. Entries with clean documentation. Start with the easy ones to build momentum and avoid delays.

Broker performance monitoring

Set expectations with your broker on filing cadence, status reporting, and issue escalation. Establish a weekly check-in during the active filing period. Track:

• Number of PSCs filed vs. planned
• Number of protests filed vs. planned
• Any CBP rejections or requests for additional information
• Updated liquidation events that change the path for specific entries

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Phase 3: Operational impact analysis (Weeks 2-3)

The recovery isn’t just about getting money back. It changes the operational landscape in ways the supply chain VP needs to understand and communicate.

Landed cost recalculation

Every sourcing decision you made during the IEEPA period was based on a landed cost that included the surcharge. If those costs are recovered, your historical cost analysis changes — and your forward-looking sourcing models need to be updated.

Work with procurement to recalculate landed costs without the IEEPA component. This analysis informs:

• Whether sourcing shifts away from China are still economically justified
• Supplier performance evaluations (some suppliers may look more competitive with the tariff removed)
• Budget variance explanations for the IEEPA period
• Forward cost projections for similar product categories

Supplier relationship review

The tariff period strained many supplier relationships. Some suppliers granted concessions. Others raised prices. Some were dropped entirely in favor of alternative-country sourcing. The recovery creates an opportunity — and in some cases an obligation — to revisit these relationships.

Suppliers who helped absorb the tariff: Consider whether the recovery triggers any contractual adjustment. At minimum, acknowledge their partnership during a difficult period.

Suppliers dropped during the tariff period: If you shifted sourcing away from a Chinese supplier specifically because of IEEPA tariffs, the recovery changes the math. You may want to re-engage, especially if the alternative supplier has quality or lead time drawbacks.

New suppliers qualified during the tariff period: The investment in qualifying new suppliers in Vietnam, India, Mexico, or elsewhere has strategic value beyond IEEPA. Maintain these relationships as part of a diversified supply base, regardless of the recovery.

Inventory position assessment

If your company built strategic inventory before the tariffs took effect, or drew down inventory during the tariff period to avoid paying surcharges, the recovery affects your inventory strategy:

• Pre-tariff inventory builds: These goods were imported duty-paid at normal rates. No IEEPA recovery applies, but the strategic value of that inventory was proven.
• IEEPA-period inventory: Goods imported and duty-paid during the tariff period. The IEEPA component of those duty payments is recoverable. If this inventory is still on hand, the carrying cost effectively drops.
• Current inventory strategy: With IEEPA tariffs gone and the recovery in process, your forward inventory strategy should reflect the new cost environment. Adjust safety stock levels, reorder points, and lead time buffers accordingly.

Phase 4: Cross-functional alignment (Week 3)

IEEPA recovery is a team sport. Supply chain needs to coordinate with finance, legal, and the C-suite to ensure everyone is aligned.

With finance

Provide the entry-level data finance needs for receivable recognition and cash flow modeling. Key deliverables from supply chain to finance:

• Complete ES-003 dataset with IEEPA entries identified
• Duty amounts by entry, sorted by recovery path
• Filing dates and estimated processing timelines
• Any entries with complications (classification questions, documentation gaps)

Finance will use this data to book the receivable, model cash flow impact, and assess tax implications.

With legal

Escalate any entries that fall outside the protest window and may require CIT litigation. Provide the complete entry files and broker records. Flag any entries with:

• Country-of-origin questions
• Classification disputes
• Missing documentation
• Downstream customer exposure (entries tied to products sold with tariff surcharges)

Legal also needs to review any third-party agreements related to the recovery — broker service agreements, claims advisory engagements, and potential claim assignment contracts.

With the C-suite

Prepare a clear operational status report for leadership. Include:

• Total recovery opportunity (dollar amount by path)
• Filing progress (entries filed vs. total eligible)
• Timeline estimates (when capital is expected to arrive)
• Resource requirements (broker fees, potential legal costs, internal staff time)
• Strategic implications (sourcing decisions, supplier relationships, inventory strategy)

The board briefing format works well for executive communication — concise, numbers-focused, action-oriented.

Phase 5: Ongoing monitoring (Month 2 onward)

IEEPA recovery isn’t a one-time project. It requires ongoing monitoring until every dollar is recovered.

Liquidation tracking

New entries from the IEEPA period are liquidating continuously. Each liquidation event:

• Starts the 180-day protest clock for that entry
• May change the optimal recovery path (from PSC to protest)
• Requires a filing action to preserve recovery rights

Set up a systematic process to monitor liquidation events. Your broker should be able to provide automated alerts when entries liquidate. Don’t rely on periodic batch reviews — entries can slip through the cracks.

CAPE queue monitoring

Once filings are submitted, they enter CBP’s CAPE processing queue. Monitor your position in the queue and update timeline estimates accordingly. If processing slows, adjust your cash flow projections and consider whether immediate capital makes sense for larger claims.

Documentation maintenance

Keep all recovery-related documents organized and accessible. The required documents include entry summaries, commercial invoices, broker communications, filing confirmations, and correspondence with CBP. Retain everything for at least five years after the final refund is received.

Exception management

Not every entry will process smoothly. Expect some CBP questions, some documentation requests, and potentially some partial denials. Have a process for escalating exceptions — from your broker to your trade compliance team to legal if necessary.

Risk management and contingency planning

Even with a clear legal ruling and CBP processing underway, the supply chain VP should plan for contingencies:

Processing delays. CBP may face staffing or system constraints that extend processing timelines. If your cash flow plan depends on refunds arriving within a specific window, have a contingency: can you bridge with a credit facility? Should you convert a portion to immediate capital to ensure near-term liquidity?

Partial denials. Some entries may face CBP questions about documentation, classification, or country of origin. Have a process for responding to CBP inquiries quickly — broker response time directly affects how long these entries stay in limbo.

Documentation gaps. Despite best efforts, some entries may have missing or incomplete documentation. Prioritize these entries for manual research now rather than discovering gaps when CBP requests supporting documents.

Vendor disputes. Suppliers or customers may contest the allocation of recovered duties. If these disputes delay the internal processing of recovery funds, have a position documented and approved by management and legal before the conversations begin.

System changes. If you’re upgrading ERP, TMS, or other systems during the recovery period, ensure that historical entry data is migrated and accessible. Don’t let a system cutover break access to IEEPA-period records.

Building institutional knowledge

The IEEPA recovery effort generates institutional knowledge that the supply chain function should capture and retain:

Data mapping. You now know how customs entry data flows between ACE, your broker, your ERP, and your procurement system. Document these data flows. The next time a recovery opportunity arises — or the next time an auditor asks for entry-level detail — you won’t have to rediscover the connections.

Broker capabilities assessment. You’ve now tested your broker’s responsiveness, data quality, and filing accuracy under pressure. Document the results. If certain brokers performed exceptionally well or poorly, this informs your broker strategy going forward.

Cross-functional coordination model. The weekly meetings, the data handoffs, the escalation paths — document what worked. If you need to stand up a similar cross-functional effort for a future trade disruption, customs audit, or compliance project, you have a proven framework.

Deadline management systems. Whatever system you used to track the 180-day protest window and other deadlines should become a permanent part of your compliance infrastructure. Liquidation monitoring shouldn’t stop when the IEEPA recovery is complete.

Contact network. You’ve built relationships with customs attorneys, claims advisors, and potentially institutional capital providers during this process. Maintain those relationships — they’re part of your supply chain resilience toolkit.

Measuring success

Track these metrics to measure IEEPA recovery performance:

Start today

The supply chain VP’s advantage in IEEPA recovery is access — to data, to brokers, to the operational infrastructure that makes filing possible. Use that advantage. Don’t wait for finance or legal to drive this process. They need your data before they can do anything.

Request an Impact Assessment to get the entry-level analysis that drives every downstream action — from broker instructions to receivable recognition to executive reporting.

The multi-site, multi-division challenge

Large companies with multiple business units, multiple import entities, and multiple customs brokers face a coordination challenge that the supply chain VP is uniquely positioned to solve:

Consolidation of recovery data. Each division or business unit may have its own import program with its own broker. The VP must ensure that every division participates in the recovery and that no entries are missed simply because a division wasn’t aware of the opportunity.

Standardized filing approach. Establish a company-wide approach to recovery path selection, filing prioritization, and deadline management. Different divisions shouldn’t be making contradictory decisions — one division filing PSCs while another ignores them, for example.

Aggregated reporting. The CEO, CFO, and board want a single consolidated number. Aggregate divisional data into a company-wide recovery report. Track total exposure, total filed, total recovered, and total pending at the enterprise level.

Shared services leverage. If your company has a shared services center that handles trade compliance or customs brokerage, that center should lead the recovery coordination. If not, the VP should appoint a recovery project lead who has cross-divisional authority and visibility.

Best practice sharing. If one division has already developed an efficient recovery workflow, share it with other divisions. The first division to file becomes the template for the rest.

The supply chain VP’s ability to see across divisions, coordinate resources, and drive accountability makes this role the natural leader for enterprise-wide IEEPA recovery. Own it.

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