You know you’re owed an IEEPA tariff refund. The Supreme Court ruled the tariffs unconstitutional. The CIT ordered CBP to process refunds. Now you need to actually file — and that means assembling the right documents.
The good news: the documentation requirements for IEEPA refund claims are well-defined. You’re not building a legal case from scratch. CBP knows what it collected, and the data exists in their systems. Your job is to present that data in a clean, verified format that matches CBP’s records and supports efficient processing.
The bad news: if your documentation is incomplete, inconsistent, or poorly organized, your claim gets flagged for manual review. Manual review means weeks or months of additional delay in a queue that’s already 18-36 months deep. Every document gap is a potential bottleneck.
This guide gives you the complete checklist — organized by priority, with explanations of what each document is, where to get it, and why it matters.
The Priority Matrix
Not every document carries equal weight. Here’s how to think about it:
| Priority | Document | Required For | Where to Get It |
|---|---|---|---|
| Must-Have | ES-003 Entry Summary Query | All paths | Customs broker pulls from ACE |
| Must-Have | CF-7501 Entry Summaries | All paths | Customs broker provides |
| Must-Have | Duty deposit receipts/ACH records | All paths | Customs broker or bank records |
| Must-Have | Active Power of Attorney | PSC, Protest | On file with broker |
| Must-Have | Liquidation notices | Protest, CIT | Customs broker provides |
| Important | HTS classification records | All paths | Customs broker or internal records |
| Important | Commercial invoices | CIT, complex entries | Your purchasing/accounts payable |
| Important | Bill of lading / airway bill | CIT, complex entries | Freight forwarder or broker |
| Helpful | Broker correspondence | Disputed entries | Email records |
| Helpful | Prior protest records | Entries with prior actions | Customs broker |
| Helpful | Bond documentation | Bond-secured entries | Surety or broker |
Let’s go through each one.
Must-Have Documents
ES-003 Entry Summary Query Report
What it is: The ES-003 is a data report pulled from CBP’s ACE (Automated Commercial Environment) portal. It provides a comprehensive view of every entry filed under your Importer of Record (IOR) number during a specified period.
What it shows:
- Entry number and type
- Entry date and port of entry
- HTS codes and tariff classifications
- Assessed duty amounts by tariff code
- Deposit amounts and dates
- Liquidation status (unliquidated, liquidated, or finally liquidated)
- Liquidation date (if applicable)
Why it’s critical: The ES-003 is the foundation of your entire refund claim. It tells you which entries are eligible, which recovery path applies to each entry, and what you’re owed. Without it, you’re guessing.
How to get it: Your customs broker generates this report from their ACE portal access. Request an ES-003 covering all entries from February 4, 2025 through February 24, 2026 — the full IEEPA tariff period. Specify that you need all data fields, not a summary view.
Common issue: Some brokers generate simplified versions of the ES-003 that omit liquidation status or deposit dates. Insist on the full report. If your broker can’t or won’t provide it, that’s a red flag — consider the steps outlined in our broker coordination guide.
Timeline to obtain: Most brokers can generate an ES-003 within 3-5 business days of request. Larger portfolios (1,000+ entries) may take longer.
CF-7501 Entry Summary
What it is: The CF-7501 is the formal Customs Form that constitutes the entry summary for each import transaction. It’s the government’s official record of what was imported, how it was classified, and what duties were assessed.
What it shows:
- Importer of record name and number
- Entry number and type
- Port of entry
- Country of origin
- Detailed HTS classification for each line item
- Duty rates applied (including IEEPA-specific codes)
- Total duties, taxes, and fees assessed
Why it’s critical: The CF-7501 provides the line-item detail needed to verify that IEEPA tariff codes (HTS headings 9903.01 and 9903.02) were applied to specific products. If your entry included both IEEPA-affected and non-IEEPA goods, the CF-7501 is how you distinguish between them.
How to get it: Your customs broker maintains copies of all CF-7501s filed on your behalf. Request copies for every entry during the IEEPA period. Most brokers can provide these electronically.
Pro tip: Cross-reference the CF-7501 duty amounts against your ES-003 data. If they don’t match, investigate before filing. Discrepancies between these documents are the number one cause of manual review flags.
Duty Deposit Records
What it is: Proof that IEEPA duties were actually deposited with CBP — not just assessed, but paid.
What it shows: The amount deposited, the date of deposit, the payment method (ACH, check), and the entry reference.
Why it’s critical: CBP refunds deposits, not assessments. If duties were assessed but covered by bond rather than cash deposit, the refund mechanics differ. You need to confirm that each entry in your claim was cash-deposited.
How to get it: Your customs broker can provide deposit confirmations from ACE. Your accounting department should also have records of payments to the broker for duty deposits — these typically show up as large wire transfers or ACH debits.
Common issue: Some importers use a periodic monthly statement (PMS) payment approach where duties are aggregated and paid monthly. This makes it harder to match deposits to individual entries. Your broker should be able to provide the entry-level breakdowns.
Active Power of Attorney
What it is: A legal document authorizing your customs broker to transact customs business on your behalf, including filing entry corrections and protests.
Why it’s critical: Without a valid POA, your broker cannot file PSCs or protests on your behalf. CBP’s system will reject filings from unauthorized parties.
How to verify: Ask your broker to confirm that your POA is current, on file with CBP, and covers the specific activities needed for IEEPA recovery (entry corrections under 19 CFR 173 and protests under 19 U.S.C. Section 1514).
Common issue: POAs expire. If you signed your POA years ago with a duration limit, it may have lapsed. If you’ve changed brokers, the old broker’s POA may still be active while the new broker’s isn’t properly recorded. Get this sorted now — not when you’re trying to file a time-sensitive protest.
Get your free Impact Assessment →
Liquidation Notices
What it is: Official notification from CBP that an entry has been liquidated — meaning CBP has made a final determination of duties owed and closed the entry.
What it shows: The entry number, liquidation date, final duty amount, and whether any changes were made from the original assessment.
Why it’s critical: Liquidation status determines which recovery path applies. Unliquidated entries go through PSC. Liquidated entries go through protest (within the 180-day window) or CIT litigation (outside the window). Getting the liquidation date wrong means choosing the wrong path — or missing a deadline.
How to get it: Your broker receives liquidation bulletins from CBP and should be tracking liquidation dates for your entries. The ES-003 report also shows liquidation status, but the formal liquidation notice provides the official date that starts the 180-day protest clock.
Critical detail: The 180-day window starts on the date of liquidation as posted in the CBP bulletin, not the date you (or your broker) learned about it. If you weren’t monitoring, the clock may have been running for weeks before you knew.
Important Documents
HTS Classification Records
What they are: Your internal records (or your broker’s records) documenting how each imported product was classified under the Harmonized Tariff Schedule. This includes the decision-making process behind the classification — which matters if CBP questions whether the IEEPA tariff was correctly applied to specific goods.
Why they matter: If CBP questions the HTS classification on any entry, having the classification rationale documented accelerates the review. This is especially important for entries where the IEEPA applicability depends on country of origin (e.g., goods with components from multiple countries).
How to get them: Your broker should have classification workpapers. If your company has an in-house trade compliance team, they may maintain independent classification records.
Commercial Invoices
What they are: The invoices from your foreign suppliers for the imported goods. These show the transaction value, product descriptions, quantities, and country of origin.
Why they matter: Commercial invoices corroborate the entry data. If there’s any question about the value or classification of goods, the commercial invoice is the primary supporting document. For CIT litigation, these are essentially required. For PSCs and protests, they’re a safety net.
How to get them: Your accounts payable department should have copies. If not, request them from your suppliers. For entries filed a year or more ago, locate these now before filing — don’t wait until CBP requests them.
Bills of Lading / Airway Bills
What they are: Shipping documents that show the movement of goods from origin to destination, including carrier, routing, weight, and shipment description.
Why they matter: Like commercial invoices, these corroborate entry data. They’re particularly important for entries where country of origin is at issue — the bill of lading shows where the goods actually shipped from.
How to get them: Your freight forwarder or customs broker should have copies.
Helpful Documents
Broker Correspondence
Any emails, letters, or communications between you and your broker regarding IEEPA tariffs, classification decisions, duty calculations, or filing issues. These can be valuable if disputes arise about what was filed and why.
Prior Protest Records
If any of your IEEPA-affected entries have been the subject of prior protests (for reasons other than IEEPA), those records are important. CBP may need to reconcile the prior protest with the new IEEPA refund claim.
Bond Documentation
If any entries were secured by surety bond rather than cash deposit, the bond documentation shows the terms and any amounts paid by the surety. This affects refund mechanics and potentially involves the surety in the recovery process.
Organizing Your Documentation Package
Once you’ve assembled everything, organize it in a way that makes review easy — both for your own tracking and for CBP’s processing.
Recommended structure:
IEEPA Refund Claim - [Company Name]
├── ES-003 Report (full period: Feb 2025 - Feb 2026)
├── Entry Summaries (CF-7501)
│ ├── Unliquidated entries (PSC candidates)
│ ├── Liquidated - within protest window
│ └── Liquidated - outside protest window
├── Duty Deposit Records
│ ├── ACE deposit confirmations
│ └── Bank/payment records
├── Liquidation Records
│ ├── Liquidation bulletins
│ └── Deadline tracker (180-day windows)
├── Supporting Documents
│ ├── Commercial invoices (by entry)
│ ├── Bills of lading (by entry)
│ └── HTS classification records
├── Authorization
│ ├── Power of Attorney (current)
│ └── Broker engagement letter
└── Correspondence
└── Broker communications re: IEEPA
This structure maps directly to the 7 steps to file your IEEPA refund and ensures you have everything organized before CAPE launches.
Document Requirements by Recovery Path
Different paths require different depth of documentation:
| Document | PSC | Protest | CIT | Immediate Capital |
|---|---|---|---|---|
| ES-003 | Required | Required | Required | Required |
| CF-7501 | Required | Required | Required | Required |
| Deposit records | Required | Required | Required | Required |
| POA | Required | Required | Attorney handles | Not needed |
| Liquidation notices | Not applicable | Required | Required | Helpful |
| Commercial invoices | Helpful | Helpful | Required | Helpful |
| Bills of lading | Not needed | Helpful | Required | Not needed |
| HTS classification | Helpful | Important | Required | Helpful |
| Broker correspondence | Not needed | Helpful | Important | Not needed |
For immediate capital through claim assignment, the documentation requirements are lighter because the buyer performs their own validation. You primarily need the ES-003, CF-7501s, and deposit records. The buyer’s team handles the rest.
The Five Most Common Documentation Mistakes
Based on hundreds of claims we’ve reviewed, these are the documentation gaps that cause the most delays:
1. Incomplete ES-003 data. Importers (or their brokers) pull a partial ES-003 that covers some but not all entries during the IEEPA period. Missing entries mean missed refunds. Always pull the full period.
2. Mismatched deposit amounts. The ES-003 shows one deposit amount, the CF-7501 shows another, and the bank records show a third. These discrepancies must be resolved before filing or CBP will flag the entry for manual review. The usual cause is timing differences between assessment, deposit, and bank clearing.
3. Expired or missing POA. The broker tries to file and the system rejects it because the POA isn’t current. This is a solvable problem but it takes time — and time is what you don’t have if protest deadlines are approaching.
4. No liquidation tracking. The importer doesn’t know which entries have been liquidated or when. Without this data, you can’t identify which entries are approaching the 180-day protest deadline — and you may miss windows without realizing it.
5. Mixing IEEPA and non-IEEPA entries. Submitting entries that don’t include IEEPA tariff codes wastes processing time and can delay your entire claim. Verify that every entry in your filing actually includes HTS headings 9903.01 or 9903.02.
Avoiding these common mistakes is straightforward if you take the time to verify your data before filing.
When to Start Assembling Documents
Now. Not when CAPE launches. Not when your broker gets around to it. Now.
The importers who will be first in the CAPE queue are the ones who have their documentation validated and ready to submit the day the system opens. Data preparation takes 2-4 weeks for a typical portfolio. If CAPE launches in mid-April 2026 as projected, you need to be pulling data today.
If you’re not sure where to start, an Impact Assessment provides a structured framework. We pull and analyze your ACE data, identify every qualifying entry, categorize by recovery path, flag approaching deadlines, and calculate your expected recovery — all documented in a report you can hand directly to your broker for filing.
