An IEEPA Impact Assessment is a comprehensive analysis of your import entry history that identifies every entry affected by IEEPA tariffs, calculates your estimated recoverable amount including statutory interest, assesses the liquidation status of each entry, flags approaching 180-day protest deadlines, and presents your recovery options side by side. You need this before filing anything — before contacting CBP, before filing protests, before engaging attorneys — because the right recovery path depends entirely on what your data shows.
Why you need an assessment before filing
You may not know which entries are affected. Most importers have hundreds or thousands of entries across the covered period from February 4, 2025, through February 24, 2026. Not all of them include IEEPA duties. An assessment cross-references every entry against HTS headings 9903.01 and 9903.02 to identify exactly which entries carry IEEPA exposure. The eligibility screening tool provides an initial qualification check, but the full assessment evaluates your data at the entry level.
You may not know your entry statuses. The right recovery path depends on whether your entries are unliquidated, liquidated within the 180-day protest window, or liquidated outside the window. Each status corresponds to a different recovery path, and most importers have entries in multiple status categories simultaneously. An assessment maps the status of every affected entry.
You may not know your deadlines. The 180-day protest window under 19 U.S.C. Section 1514 is running on entries that have already been liquidated. The earliest IEEPA entries from February 2025 began liquidating around December 2025, which means the first protest deadlines may arrive as early as June 2026. An assessment identifies which entries are approaching deadline so you can take action before your options narrow.
You may not know your total exposure. Your estimated refund equals the IEEPA duties paid plus statutory interest under 19 U.S.C. Section 1505(c). Without a line-by-line analysis of your ES-003 Entry Summary Details from the ACE portal, any estimate is speculative. An assessment calculates the specific number from your entry data.
What the assessment includes
The result is a branded Impact Assessment document containing your total estimated IEEPA exposure, entry-by-entry breakdown with HTS classifications, liquidation status mapping for each entry, deadline flagging for entries approaching the 180-day protest window, recovery path analysis comparing all four available options, and recommended next steps tailored to your specific portfolio.
The assessment also includes a time-value analysis comparing the estimated government refund timeline (18-36 months through the CAPE system) against immediate capital through claim assignment. For CFOs evaluating the financial reporting implications, our CFO guide to IEEPA recovery provides additional context on balance sheet treatment and WACC-based decision frameworks.
What data you need to provide
The primary document is your ES-003 Entry Summary Details report from CBP’s ACE portal. Your customs broker can export this in minutes. The report should cover the full IEEPA period (February 4, 2025, through February 24, 2026) and include entry numbers, HTS codes, duty amounts, and liquidation dates. Our documentation guide provides a complete checklist of required fields.
If you do not have direct ACE portal access, your customs broker has access and can pull the data on your behalf. If you do not currently work with a customs broker, the assessment can work with CF-7501 entry summary forms or other available import documentation.
How the process works
The assessment process follows three steps, which are detailed on our how it works page. First, you share your import data under mutual NDA. Second, our team analyzes every entry, calculates exposure, and maps recovery options. Third, you receive the completed Impact Assessment document with specific recommendations.
The assessment is designed to give you a complete picture before you commit to any recovery path. Whether you ultimately choose to file through CBP’s CAPE system, engage a trade attorney for CIT litigation, pursue immediate capital, or use a hybrid approach, the assessment provides the data foundation for that decision.
What the assessment costs
Nothing. The Impact Assessment is provided at no cost, covered by mutual NDA, and delivered within approximately 5-10 business days of receiving your entry data.
Customs brokers and trade attorneys
If you advise importers on tariff recovery, the assessment process is designed to complement your existing advisory relationship. The partner referral program provides assessment support at no cost to the referring broker or attorney. You keep the client relationship; we provide the entry-level analysis.
Why timing matters
The CAPE system is expected to launch in mid-April 2026, and CBP has confirmed that claims will be processed in filing order. For a comprehensive overview of every aspect of the recovery process, see our complete guide to IEEPA tariff refunds. Importers who have their data validated before CAPE launches will be positioned to file on day one. The cost of waiting compounds across multiple dimensions: protest deadlines expire, CAPE queue positions deteriorate, and the time value of your refund erodes.
Request a confidential Impact Assessment to understand your exact exposure, deadlines, and options before any of them expire.
