IEEPA Reciprocal Tariff Recovery

Calculate Your Tariff Refunds
with Clarity

Upload your Entry Summary (ES-003) CSV from CBP's ACE portal to instantly estimate your IEEPA tariff refund potential — filtered by HTS code and protest deadline status.

Upload Your Entry Summary Data

Step 1 of 1 · CSV format

Drag & Drop Your ES-003 Entry Summary

Export your Entry Summary report from CBP's ACE portal, then upload it here
to instantly see your IEEPA refund potential by entry and deadline status.

Drag & Drop supported · CSV only

Not sure about the file format? Download the sample ES-003 CSV to see the expected column structure, then try it live.

⚠️ Disclaimer: This calculator provides an estimate only and is for informational purposes. Results are based solely on the information entered and certain simplifying assumptions. It is not a determination of eligibility, a guarantee of refund, or a binding calculation. Refund rights, procedures, and amounts remain subject to government review, statutory requirements, filing deadlines, and potential legal developments. Use of this calculator does not constitute legal or tax advice and does not create an attorney-client relationship. You should consult qualified counsel regarding your specific circumstances.

Analyzing your entries…

Potential Refund Value

↑ 0% of total duties paid

Claim Your Potential Refund

Total Entered Value

Total Duties Paid

Across all tariff types

Non-Refundable

Base duties / expired entries

Deadline Status

Refund Eligibility by Protest Window

Eligibility is determined by each entry's position in the CBP liquidation lifecycle. Entries are estimated to liquidate ~314 days after the entry date. The protest window closes 180 days after liquidation — entries past this point cannot be recovered through standard CBP procedures.

PSC route — unliquidated, file within 300 days of entry

Protest route — liquidated ≤180 days ago

Expired window — liquidated >180 days ago (not recoverable)

Entry Detail

Highest Value Refund Opportunities

Entry Number	Entry Date	Est. Liquidation	IEEPA Duty	Status

Next Steps

How to Claim Your Refunds

Verify Entry Status

Check liquidation status in CBP's ACE portal. PSCs must be filed within 300 days of entry and 15 days before liquidation.

File PSC or Protest

File a Post Summary Correction if unliquidated, or a 19 U.S.C. §1514 protest within 180 days of liquidation. Missing the 180-day deadline is an absolute bar.

Await CBP Guidance

CBP is issuing formal refund procedures post-SCOTUS ruling. Monitor CSMS bulletins at cbp.gov and consult a licensed customs broker.

Ready to move forward? Book a free consultation with our customs specialists to begin your refund claim.

Claim Your Potential Refund

Reference Guide

IEEPA Tariff Catalog

Chapter 99 HTSUS codes related to IEEPA reciprocal tariffs, sourced directly from CBP CSMS bulletins.

Tariff-Imposing Codes

Potentially Refundable

HTS Code	Rate	Description	Effective	Source	Status
9903.01.25	10%	Universal reciprocal tariff — all countries (baseline)	Apr 5, 2025	CSMS #64649265	Refundable
9903.01.43–.62	Varies	Country-specific elevated rates (20 countries)	Apr 9, 2025	CSMS #64680374	Refundable
9903.01.63	34%	China-specific rate (suspended; .25 used in practice)	Apr 9, 2025	CSMS #64680374	Refundable
9903.01.64–.76	Varies	Additional country-specific reciprocal rates	Apr 9, 2025	CSMS #64680374	Refundable
9903.02.02–.71	Varies	Per-country rates under new EO (70 country codes)	Aug 7, 2025	CSMS #65829726	Refundable
9903.01.20 / .24	10%	IEEPA Fentanyl duties on China (two tranches)	Feb–Mar 2025	EO 14195	Refundable*
9903.02.01	40%	Transshipment evasion penalty rate	Aug 7, 2025	CSMS #65829726	Case-by-case

* Fentanyl duties are separate from reciprocal tariffs — refundability subject to scope of SCOTUS ruling.

Exemption Codes

NOT Refundable — Duty Already Waived

HTS Code	Description	Notes	Status
9903.01.26	Canada — USMCA qualified goods	Duty-free at border	Exempt
9903.01.27	Mexico — USMCA qualified goods	Duty-free at border	Exempt
9903.01.28	In-transit exception (loaded pre-Apr 5)	Expired Jun 16, 2025	Expired
9903.01.29	Column 2 countries (Belarus, Cuba, NK, Russia)	Higher Column 2 rates apply	Exempt
9903.01.30	Humanitarian donations (food, clothing, medicine)	Duty-free	Exempt
9903.01.31	Informational materials (publications, media)	Duty-free	Exempt
9903.01.32	Annex II exclusions (pharma, semis, copper, lumber)	Expanded Apr 11 & Nov 2025	Exempt
9903.01.33	Section 232 products (steel, aluminum, autos)	Subject to Sec 232 duties instead	Exempt
9903.01.34	US-origin content portion (≥20% US value)	Only non-US content taxed	Exempt
9903.02.78	Agricultural exclusions (Nov 2025 expansion)	237 HTS categories	Exempt

Sources

Key CBP Guidance

CSMS #64649265

Reciprocal Tariffs, April 5, 2025 Effective Date — baseline 10% universal rate

CSMS #64680374

Reciprocal Tariffs, April 9, 2025 — country-specific elevated rates

CSMS #65829726

Reciprocal Tariff Updates Effective August 7, 2025 — new per-country 9903.02.xx codes

CBP IEEPA FAQ

cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ — ongoing updates

SCOTUS — Feb 21, 2026

Learning Resources v. Trump — IEEPA tariffs ruled unlawful 6–3. EO terminating them signed same day.

IEEPA Refund Recovery

Refund Handbook

Everything you need — from legal background to filing your claim. Select a topic from the menu to get started.

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 affirms: IEEPA does not grant tariff authority. President signs EO terminating the tariffs. CBP begins issuing refund guidance via CSMS bulletins.

Which Tariffs Are Refundable?

✅ 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 EO) 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.

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

Whichever date comes first

Protest Deadline

Liquidation Date + 180 days

Statutory absolute bar — zero exceptions

⚠️ 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.

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.

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.

Navigate to Trade → Reports

Click Trade in the top nav → Reports → Standard Reports → Entry Summary.

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.

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.

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.

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.

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. Costs typically start at $50,000+ in legal fees and can take years.

⚖️ Filing an imperfect PSC or protest immediately is almost always better than letting windows expire and ending up here.

06Professional Help

Working With a Broker

Who you need, what to ask before engaging, and exactly what to hand over to get filings moving fast.

Broker vs. Attorney — Which Do You Need?

🏢 Customs Broker (CHB)

Licensed professional who handles CBP filings. Can file both PSC amendments and Form 19 protests on your behalf.

Best for: PSC filings, standard protests, if you have an existing broker relationship

~$50–$200 per entry or flat rate for bulk

⚖️ Trade Attorney

Customs and international trade lawyer. Handles complex protests, denied protest appeals, and CIT litigation.

Best for: Large refund amounts, denied protests, CIT litigation, complex classification disputes

$300–$600/hr or 15–30% contingency

5 Questions to Ask Before Engaging

Have you filed IEEPA-related PSCs or protests before?

Experience with the specific IEEPA HTS codes and CSMS bulletins (#64649265, #64680374, #65829726) means fewer errors and faster processing.

What is your fee structure — per entry, flat rate, or contingency?

For small refunds, contingency (pay only on recovery) may be better. For large refunds, flat fee often works out cheaper. Get it in writing before any filing.

Can you verify actual liquidation dates in ACE before filing?

Critical. The 180-day protest clock runs from the real liquidation date. A broker with ACE access can pull exact dates — don't rely on estimates.

What happens if CBP denies the protest?

Denied protests can be escalated to Request for Further Review (RFR) and then CIT. Understand whether your broker handles this escalation path and at what cost.

How many entries can you process per week?

If dozens of entries are approaching deadlines simultaneously, confirm capacity before engaging. Volume throughput matters as much as expertise.

What to Hand Over on Day One

📄

ES-003 CSV export

Or the calculator output showing qualifying entries

🔢

Entry summary numbers

All entries with IEEPA duty amounts — the calculator outputs these

🏢

Power of Attorney

Signed by authorized officer authorizing broker to file on your behalf

📬

ACH payment instructions

Bank account for CBP refund deposit — must match the IOR on record

07What 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.

08Reference

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.