If you’re pursuing an IEEPA tariff refund, one system holds the keys to your claim: ACE — the Automated Commercial Environment. It’s CBP’s online portal where every U.S. import entry, duty payment, and liquidation record lives. Your entire refund claim is documented in this system, and understanding how to access and use it can mean the difference between a smooth recovery and months of frustration.
Think of ACE as the IRS portal for trade. Just like the IRS tracks your tax filings, payments, and refunds, ACE tracks your import entries, duty payments, and (now) your IEEPA refund eligibility. If you’ve never heard of ACE before, that’s completely normal — most importers interact with it through their customs broker and never see it directly.
This guide explains what ACE is, how it works, why it matters for your IEEPA recovery, and how to get the data you need from it.
What ACE Actually Is
ACE stands for Automated Commercial Environment. It’s the primary system that CBP (U.S. Customs and Border Protection) uses to process and track all goods entering the United States. It replaced the older ACS (Automated Commercial System) and became the single window for all U.S. trade data.
Here’s what ACE handles:
- Entry filing. When your customs broker files an entry for your shipment, they do it through ACE. The entry includes product descriptions, HTS classifications, values, and calculated duties.
- Duty payments. All duty payments to CBP flow through ACE. When you pay estimated duties on an entry, that payment is recorded in ACE.
- Liquidation tracking. When CBP finalizes (liquidates) an entry — typically about 314 days after filing — that liquidation event is recorded in ACE.
- Reports. ACE can generate detailed reports on your entries, duties, classifications, and liquidation status. These reports are the foundation of any IEEPA refund claim.
- Post-entry actions. Post-Summary Corrections (PSCs), protests, and other modifications all flow through ACE.
Every import transaction since ACE’s full deployment is recorded here. For the IEEPA refund period (February 4, 2025, through February 24, 2026), your ACE data tells you exactly how much you paid in IEEPA duties, which entries are affected, and what the liquidation status of each entry is.
Who Uses ACE?
ACE has different access levels for different users:
| User Type | Access Level | What They Can Do |
|---|---|---|
| CBP officers | Full access | Review, process, and modify entries |
| Licensed customs brokers | Broker portal | File entries, pull reports, submit corrections on behalf of importers |
| Importers (direct) | Importer portal | View their own entries, pull limited reports |
| Freight forwarders | Varies | Depends on their role and licensing |
| Other government agencies | Partner agency | FDA, USDA, EPA review entries for their jurisdiction |
Most importers interact with ACE exclusively through their customs broker. The broker has a specialized portal with tools designed for filing and managing entries. But importers can also get direct access to view their own data — and for IEEPA recovery, this can be valuable.
Why ACE Matters for Your IEEPA Refund
Your IEEPA refund claim is built on data, and virtually all of that data lives in ACE. Here’s specifically what you need from the system:
Entry Identification
First, you need to know which of your entries carry IEEPA tariff lines. These are entries with duty codes under HTS headings 9903.01 and 9903.02. The 9903.01 codes cover the “fentanyl” tariffs on imports from China, Canada, and Mexico. The 9903.02 codes cover the “reciprocal” tariffs from Liberation Day and subsequent actions.
ACE can generate a report showing every entry under your importer number that includes these codes. Your customs broker can pull this in minutes.
Duty Amounts
For each affected entry, you need the exact dollar amount of IEEPA duties paid. This isn’t always straightforward — a single entry might have both IEEPA duties and non-IEEPA duties (like Section 301 or Section 232 tariffs). ACE breaks these out by tariff line, so you can isolate the IEEPA-specific amounts.
Liquidation Status
This is arguably the most critical data point. Each entry’s liquidation status determines which recovery path is available:
- Unliquidated entries can be corrected through a Post-Summary Correction (the fastest path).
- Entries liquidated within the past 180 days can be protested.
- Entries liquidated more than 180 days ago require CIT litigation.
ACE shows the liquidation date for each entry, allowing you to calculate your 180-day protest window precisely.
The ES-003 Report: Your Most Important Document
The single most useful ACE report for IEEPA recovery is the ES-003 Entry Summary Details Report. This report provides a line-by-line breakdown of every entry filed under your importer number, including:
- Entry number and date
- Port of entry
- HTS codes for each line item
- Duty rates and amounts for each tariff line
- Liquidation status and date
- Total duties paid per entry
When we conduct an Impact Assessment, the ES-003 is typically the first document we request. It gives us everything we need to calculate your total IEEPA exposure, map your entries to recovery paths, and identify approaching deadlines.
Get your free Impact Assessment →
How to Access ACE
There are two ways to get your ACE data: through your customs broker (easier) or through direct access (more control).
Option 1: Through Your Customs Broker
This is the path most importers take. Your customs broker already has ACE access and can pull reports on your behalf. Here’s what to ask for:
“Please pull an ES-003 Entry Summary Details report for all my entries from February 1, 2025, through March 1, 2026.” This covers the full IEEPA period with a small buffer on each end.
“Please flag all entries with HTS codes beginning with 9903.01 or 9903.02.” This isolates your IEEPA-affected entries.
“Please include liquidation status and dates for all entries.” This tells you which recovery path applies to each entry.
Most brokers can provide this data within a few business days. Some may charge a fee for the report generation; others include it as part of their standard service. Either way, the cost is minimal compared to the potential refund.
Option 2: Direct ACE Portal Access
Importers can apply for direct access to the ACE Secure Data Portal. This gives you the ability to view your own entry data, run reports, and monitor liquidation status without going through your broker.
To get direct access:
- Visit the ACE portal at ace.cbp.dhs.gov.
- Request an account. You’ll need to provide your importer number (EIN-based), company information, and contact details.
- Complete identity verification. CBP verifies your identity and your association with the importer number.
- Receive credentials. Once approved, you get login credentials for the importer portal.
The approval process can take several weeks, so if you don’t already have access, start the application now while relying on your broker for immediate data needs.
Direct access is particularly useful if you have a large number of entries and want to monitor liquidation status in real time, or if you want to independently verify the data your broker provides. For a comprehensive walkthrough of the full recovery process, see our step-by-step guide.
Understanding ACE Data: What You’re Looking At
When you receive an ACE report or view data in the portal, the information can be dense. Here’s a decoder for the fields that matter most for IEEPA recovery:
Entry Number
A unique identifier assigned to each import transaction. The format is typically a three-character filer code followed by a seven-digit entry number and a check digit (e.g., ABC-1234567-8). This number ties all data for a single shipment together.
Entry Type
The type of entry filed. The most common is “01” (consumption entry), which means the goods entered U.S. commerce. Other types include warehouse entries (21), temporary imports (23), and foreign trade zone entries (06). For IEEPA recovery, consumption entries are the primary focus.
Entry Date
The date the entry was filed with CBP. This is important because liquidation typically occurs about 314 days after this date. If you know the entry date, you can estimate when liquidation will happen (or has happened).
HTS Number
The Harmonized Tariff Schedule code assigned to each product line in the entry. For IEEPA purposes, you’re looking for codes beginning with 9903.01 (fentanyl tariffs) or 9903.02 (reciprocal tariffs). These are the codes that identify IEEPA duties.
A single entry might have multiple HTS lines — some IEEPA, some not. For example, an entry for Chinese goods might have a base duty line, a Section 301 line, and an IEEPA 9903.01 line. Only the 9903 line is refundable.
Duty Amount
The dollar amount of duty assessed on each tariff line. For your refund calculation, you want the sum of all 9903.01 and 9903.02 duty amounts across all your entries.
Liquidation Date
The date CBP officially finalized the entry. If this field is blank or shows “unliquidated,” the entry hasn’t been finalized yet — good news, because it means you can use the fastest recovery path (PSC). If there’s a date, count forward 180 days — that’s your protest deadline.
Liquidation Type
How the entry was liquidated. “As entered” means CBP accepted your original filing. “By rate change” or “by other means” indicates CBP made modifications. For IEEPA entries liquidated “as entered,” the protest argument is straightforward: the entry included tariff codes that have since been invalidated by the Supreme Court.
ACE Reports You Should Request
Beyond the ES-003, there are several other ACE reports that can support your IEEPA recovery:
Entry Summary Report (general). A high-level view of all your entries during a specified period. Useful for getting the big picture before diving into details.
Liquidation Report. Focuses specifically on liquidation dates and status. Good for identifying which entries are approaching or past the 180-day protest window.
Statement of Account. Shows duty payments made to CBP, including periodic monthly statements if you use the ACE Periodic Monthly Statement program. This helps verify that you actually paid the duties you’re claiming a refund for.
Entry Summary Line Detail. The most granular level — every product line on every entry, with HTS codes, values, and duty amounts. This is what you need for line-by-line IEEPA duty isolation.
Your broker may use different names for these reports depending on their ACE interface, but the underlying data is the same.
Common ACE Challenges in IEEPA Recovery
The ACE system is powerful but not always user-friendly. Here are common issues importers encounter:
Multiple Broker Relationships
If you’ve used different customs brokers during the IEEPA period (or switched brokers), your entries may be split across different broker accounts. Each broker can only see entries they filed. To get a complete picture, you need to request data from every broker who filed entries on your behalf during the affected period, or use your direct ACE importer access to see all entries under your IOR number.
Data Volume
Large importers may have thousands of entries during the IEEPA period. Processing this data manually is impractical. Automated tools and analytics are essential for extracting the IEEPA-specific duty lines and calculating the total claim value. This is one of the reasons an Impact Assessment is valuable — it handles the data processing at scale.
Classification Complexity
Some entries may have IEEPA tariff lines that are difficult to identify because of how they were classified at the time of entry. During the IEEPA period, classification guidance from CBP evolved, and some brokers applied the tariff codes differently. An experienced analyst can identify IEEPA lines even when the classification isn’t immediately obvious. The IEEPA tariff refund glossary can help clarify unfamiliar terms and codes.
Suspended Liquidation
Some entries may be in “suspended liquidation” status, meaning CBP has paused the liquidation process. This has been common for IEEPA entries as CBP processes the implications of the Supreme Court ruling. Suspended entries haven’t been finalized, which generally puts them in the PSC-eligible category — but the exact handling depends on CBP’s current processing procedures.
ACE and the Recovery Timeline
Here’s how ACE data maps to the IEEPA recovery timeline:
Now (April 2026): Pull your ACE data. Identify all IEEPA entries. Map liquidation status. Calculate total exposure.
Immediate priority: Entries that were liquidated in late 2025 or early 2026 have 180-day protest windows that are closing soon. ACE data tells you exactly which entries these are and when the deadlines fall.
Short-term (next 3-6 months): File PSCs for unliquidated entries. File protests for liquidated entries within the window. Both actions are initiated through ACE by your customs broker.
Medium-term (6-18 months): Monitor CBP’s processing of your PSCs and protests through ACE. Liquidation and reliquidation events will appear in the system as they’re processed.
Long-term: Receive refunds. ACP processing of corrections and protests feeds into CBP’s refund disbursement process. The money flows back through the same system that collected it.
What to Do Right Now
Your ACE data is the foundation of your entire IEEPA recovery. Without it, you’re guessing at your exposure, guessing at your deadlines, and guessing at your claim value. With it, you have precision.
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Contact your customs broker today. Request the ES-003 report for the IEEPA period. If you used multiple brokers, contact all of them.
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Consider applying for direct ACE access if you don’t already have it. Visit ace.cbp.dhs.gov to start the process.
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Review the data. Look for 9903.01 and 9903.02 HTS codes. Add up the duty amounts. Check liquidation dates.
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Flag deadlines. Any entry liquidated more than 90 days ago is already past the halfway point of its protest window. Prioritize these.
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Get a comprehensive assessment. If the data is overwhelming — or if you want someone to handle the analysis, deadline tracking, and path mapping for you — request an Impact Assessment. We’ll take your ACE data and turn it into a clear recovery plan. For those new to this process, our beginner’s guide provides helpful orientation.
ACE Security and Data Privacy
A common concern importers have about ACE is data security. Your import data contains commercially sensitive information — what you buy, from whom, at what price, in what volume. Here’s what you should know:
ACE access is controlled. Only you, your licensed customs broker (with your power of attorney), and CBP personnel can access your data. Other importers cannot see your entries.
Broker access is limited to their filings. If you use Broker A for one shipment and Broker B for another, each broker can only see the entries they filed — unless you grant them broader access through a power of attorney.
Direct importer access shows all your entries. This is one advantage of getting your own ACE login — you see everything filed under your IOR number, regardless of which broker filed it. This can be valuable if you’ve used multiple brokers during the IEEPA period.
Data in ACE is government record. The information in ACE is subject to federal recordkeeping requirements and is protected under applicable privacy laws. However, it can be accessed by CBP for enforcement purposes, and certain aggregate data is publicly available through trade statistics.
For IEEPA recovery specifically, the data you’re accessing is your own — your entries, your duties, your refund claims. There’s no privacy concern with accessing your own records to pursue a legitimate refund.
The data is there. The refund right is established. The question is whether you’ll access it in time to use the most efficient recovery paths.
