IEEPA Refund Recovery
Refund Handbook
Everything you need — from legal background to filing your claim. Select a topic from the menu to get started.
Important: A favorable ruling does not guarantee a refund. Refund eligibility depends on timely filings, procedural compliance, and final court outcomes. Government agencies may contest or delay refunds.
01Context
Legal Background
Why the IEEPA refund opportunity exists, what changed legally, and which tariffs are actually refundable.
What Are IEEPA Tariffs?
The International Emergency Economic Powers Act (IEEPA) granted the President
authority to impose tariffs during a declared national emergency. Starting April 2025, broad
"reciprocal" tariffs were imposed on imports from ~90 countries — ranging from 10% to over 100%
depending on country of origin.
April 2, 2025
Executive Order — "Liberation Day"
Reciprocal IEEPA tariffs imposed on imports from ~90 countries. Chapter
99 supplemental HTS codes (9903.xx.xx) added to entry summaries to identify the IEEPA component.
April – December 2025
Duties Collected by CBP
CBP collects IEEPA duties at the border. Importers pay — often without
knowing the legal basis would later be struck down.
Late 2025
Legal Challenges at CIT
Multiple importers file suit at the Court of International Trade,
arguing IEEPA does not grant tariff authority — a power reserved for Congress.
February 21, 2026
SCOTUS Rules IEEPA Tariffs Unlawful ✓
The Supreme Court indicated that the IEEPA does not grant tariff authority, while decisions regarding potential tariff refunds remain with the lower courts.
Which Tariffs May Qualify for a Refund?
✅ Potentially Refundable
- Reciprocal tariffs (9903.01.25, .43–.76)
- Baseline 10% universal tariff (9903.01.63)
- China-specific IEEPA (9903.02.02–.71)
- Early IEEPA codes (9903.01.20, .24)
❌ Not Refundable
- Section 301 China tariffs (9903.88.xx)
- Section 232 steel & aluminum (9903.80.xx)
- Base MFN / standard duties
- USMCA / Canada / Mexico goods
- Entries outside all filing windows
Fentanyl-related tariffs (separate Executive Order) are pending CBP guidance — their
refundability is not yet confirmed. The calculator flags these separately.
02Qualification
Eligibility Checklist
Work through each criterion. You need to satisfy all of them to have a recoverable refund claim. Click each item to mark it.
✓
You were the Importer of Record (IOR)
Refunds go to whoever paid the duty. If you purchased DDP from a foreign
supplier, they may be the IOR — not you.
✓
Goods entered between April 2025 and February 2026
IEEPA tariffs first applied April 2, 2025. Entries outside this window
have no IEEPA duty component to refund.
✓
Entry contains a refundable Chapter 99 HTS code
Your entry summary must include a 9903.xx.xx supplemental code in the
refundable range. Run your ES-003 through the calculator to verify instantly.
✓
Goods were not USMCA-origin (Canada or Mexico)
USMCA-qualifying goods were exempt from IEEPA tariffs — if they didn't pay
IEEPA duties, there's nothing to refund.
✓
At least one entry is within an active filing window
Either PSC (300 days from entry) or Protest (180 days from liquidation)
must still be open. See the Deadlines section for details.
✓
You have access to your entry summary data
You'll need your ES-003 export from ACE or equivalent from your broker.
See Section 04 for the step-by-step export guide.
Not sure? Upload your ES-003 to the Refund Calculator — it checks every entry automatically
and shows you exactly what qualifies.
03Time-Sensitive
Critical Deadlines
Two separate legal windows exist for recovering IEEPA duties. Which applies to each entry depends on whether CBP has liquidated it yet.
CBP will not refund automatically. No automatic refund program has been
announced. You must proactively file a PSC or protest. Every day of delay closes more entries
permanently.
Route A — Post Summary Correction
Entry Not Yet Liquidated
Electronic amendment through ACE. Fast, low-cost, no attorney required.
300 days from entry date
Route B — Protest (19 U.S.C. §1514)
Entry Already Liquidated
Formal Form 19 protest. Requires licensed broker or attorney.
180 days from liquidation — absolute bar
How to Calculate
Your Deadlines
For any entry — compute all three dates
Est. Liquidation Date
Entry Date + 314 days
Verify the actual date in ACE — CBP may vary
PSC Deadline
Entry Date + 300 days
AND ≥15 days before liquidation
AND ≥15 days before liquidation
Whichever date comes first
Protest Deadline
Liquidation Date + 180 days
Statutory absolute bar — zero exceptions
04Data
Export
Pulling Your ES-003
Step-by-step guide to exporting the right report from CBP's ACE Secure Data Portal. Takes 5–10 minutes.
🔐
ACE Login
CBP portal credentials. Ask your TAO if you don't have access.
📅
Date Range
April 2025 to today — covers all IEEPA-period entries.
🏢
IOR Number
Your IRS/EIN as Importer of Record to filter your entries.
Using a broker? They can pull this in minutes — forward this guide and ask for
ES-003 in CSV format, April 2025 to today.
1
Log into ACE Secure Data Portal
Go to
aceservices.cbp.dhs.gov. Complete MFA. Confirm
you're in the Importer view — your company name should appear in the top nav.
2
Navigate to Trade → Reports
Click Trade in the top nav → Reports
→ Standard Reports → Entry Summary.
3
Find and Open ES-003
Search
ES-003. Select ES-003 — Entry
Summary (not ES-001, which is header-only). Don't click Run yet.4
Set Date Range: 04/01/2025 → Today
Entry Date From:
04/01/2025. Entry Date To: today. Enter
your IOR (IRS/EIN) in the Importer of Record field.5
Confirm These 5 Required Columns
Entry Summary Number · Entry Date ·
HTS Number - Full · Line Tariff Duty Amount ·
Line Tariff Goods Value Amount
Extra columns are fine. Missing ones cause errors.
6
Run Report → Export as CSV
Click Run Report → Export → CSV. Save
the file. Do not open in Excel first — it strips leading zeros from HTS codes.
7
Upload to the Refund Calculator
Drag-and-drop your CSV onto the calculator upload screen. Your estimate
appears in seconds. Data never leaves your browser.
05Recovery
Paths
Filing Routes
Three mechanisms exist to recover IEEPA duties — which applies depends on your entry's liquidation status and how much time has passed.
Route 1 — Post Summary Correction (PSC)
Fastest
& Cheapest
300 days
From entry date
4–8 wks
CBP processing
Low cost
Broker fee only
An electronic amendment to the original entry removing the IEEPA HTS code, filed through ACE. CBP reviews and issues a refund via ACH. No attorney required — your existing broker can handle this.
Identify qualifying entriesUse the calculator to find all
entries within the PSC window.
→
Engage brokerProvide entry numbers, HTS codes, and duty
amounts.
→
Broker files in ACEAmended entry removes the IEEPA line.
→
CBP refundsTypically 4–8 weeks.
Route 2 — Protest (19 U.S.C. §1514)
Liquidated
Entries
180 days
From liquidation — no extensions
3–6 mo
CBP processing
Moderate
Broker or attorney
Once CBP liquidates an entry, file Form 19 at the CBP port that handled the original entry. The 180-day statutory deadline is absolute — no exceptions exist under any circumstances.
Verify the actual liquidation date in ACE — the 180-day clock runs from the
real date, not an estimate. Missing it by one day extinguishes your claim permanently.
Route 3 — CIT Litigation
Last
Resort
Only when both PSC and protest windows have closed. Requires filing at the U.S. Court of International Trade under 28 U.S.C. §1581. Trade attorney required. Litigation can be expensive, and the process may take several years to resolve. Any recovery is subject to final court decisions and procedural requirements.
Filing an imperfect PSC or protest immediately is almost always better than letting windows
expire and ending up here.
06What to
Expect
After You File
Timelines for PSC and protest outcomes, and the most common reasons CBP denies claims — so you can avoid them.
PSC Timeline
Day 1
PSC Submitted in ACE
Broker files the amended entry. You receive a PSC submission number — keep it
for tracking.
Days 1–5
Automated Validation
ACE runs automated checks. Simple PSCs may be approved at this stage with no
human review.
Weeks 2–8
CBP Officer Review (if flagged)
CBP may issue a CF-28 (Request for Information). Respond promptly — delays
here extend your timeline.
Weeks 4–12
Refund Issued via ACH
Given expected IEEPA filing volume, processing may be slower than normal.
Track status in ACE.
Protest Timeline
Day 1
Form 19 Filed at CBP Port
Protest submitted. 180-day window preserved from this date. You receive a
protest number.
Months 1–6
CBP Review Period
CBP has up to 2 years to decide, but straightforward IEEPA protests are
expected to move faster given the clear SCOTUS ruling.
Decision
Allowed or Denied
Allowed → refund via ACH. Denied → 180 days to file at CIT. A denial is not
final — it starts the litigation track if the amount warrants it.
Top Reasons CBP Denies Claims
Timing
Filed after the PSC or protest deadline — the most common and most
preventable reason.
Wrong HTS
HTS code cited is not in CBP's published refundable IEEPA code list.
Cross-reference CSMS bulletins before filing.
Wrong IOR
Filer is not the Importer of Record on the original entry. CBP only refunds
the party that paid.
Amount Mismatch
Claimed amount doesn't match CBP records. Verify against the original
CBP-7501 form, not your internal records.
Already Liquidated
PSC filed after CBP liquidated the entry. If this happens, a protest must be
filed instead.
07Reference
Key Terms Explained
Plain English definitions for the terminology you'll encounter throughout the refund process.
ACEAutomated
Commercial Environment — CBP's web portal for all trade filings, reports, and duty
payments.
CBPU.S. Customs and
Border Protection — the agency that collects duties and processes refund claims.
CEECenter of
Excellence and Expertise — CBP's processing centers that review PSCs and protests.
CHBCustoms House
Broker — licensed professional who files CBP entries and amendments on your behalf.
CITCourt of
International Trade — federal court hearing trade lawsuits, including denied protest
appeals.
CSMSCBP System
Messaging Service — official bulletins announcing HTS code lists and procedural guidance.
ES-003Entry Summary
Report (line-level) — the ACE report containing every import line item, HTS code, and duty
amount.
HTS CodeHarmonized
Tariff Schedule code — 10-digit number classifying goods for tariff purposes. IEEPA uses
supplemental Chapter 99 codes.
IEEPAInternational
Emergency Economic Powers Act — the statute used to impose the tariffs now ruled unlawful by
SCOTUS.
IORImporter of Record
— the legal entity responsible for the entry. Only the IOR can receive a duty refund.
LiquidationCBP's final
accounting of duties on an entry. Typically ~314 days after entry date. Triggers the 180-day
protest window.
MFN DutyMost Favored
Nation duty — the standard base tariff rate, unaffected by the SCOTUS ruling.
POAPower of Attorney —
authorizes a broker to file on your behalf. Must be signed by an authorized company
officer.
ProtestFormal
challenge to CBP's liquidation decision, filed on Form 19 within 180 days under 19 U.S.C.
§1514.
PSCPost Summary
Correction — electronic amendment to an unliquidated entry filed through ACE. Fastest refund
path.
TAOTrade Account Owner
— primary ACE account administrator at your company, manages user access.
Ready to Get Started?
Calculate Your Refund Estimate
Upload your ES-003 CSV and see your potential recovery broken down by entry and deadline status — free, instant, and completely private.