IEEPA Tariff Recovery Guide: Step-by-Step for U.S. Importers

Start with your entry history. You need: (1) your entry summary numbers from CBP Form 7501; (2) the HTS codes on each entry, specifically any Chapter 99 IEEPA codes (9903.01.xx or 9903.02.xx); (3) the liquidation status and liquidation date for each entry; and (4) whether any entries are flagged for reconciliation and whether a Type 09 has been filed. Following the Learning Resources v. Trump ruling that opened refunds for 330,000 importers of record, export your entry data from ACE using the Entry Summary Detail Report (ES-003). Filter by Chapter 99 IEEPA HTS codes to identify affected entries. Entries that are unliquidated or liquidated within 80 days belong in Phase 1. Reconciliation-flagged entries without a Type 09 belong in Phase 2 — provided you file the CAPE Declaration before the Type 09. Finally liquidated entries (more than 80 days) require a CIT case for Phase 3.

Before filing your CAPE Declaration, verify that valid U.S. bank account information is enrolled in your ACE Secure Data Portal account. Refunds cannot disburse without it — as confirmed by 8,384 certified refunds currently stuck at Treasury for this exact reason. Log into your ACE account, navigate to the banking/payment section, and confirm your ACH routing and account number are active. If you are designating a third party to receive your refund under CBP Form 4811, that designee's banking information must be enrolled, and Form 4811 must be properly executed and on file with CBP before your CAPE Declaration is filed. ACE requires a U.S. bank account — foreign bank accounts cannot receive ACH refunds directly.

Download the CAPE Declaration upload template from the ACE Secure Data Portal (CAPE tab). The template is a single-column CSV with 'Entry Number' in Row 1 and your entry numbers in subsequent rows. Each Declaration is limited to 9,999 entries — submit multiple Declarations if needed. Before uploading, verify: (1) all entry numbers exist in ACE; (2) all entries have at least one dutiable IEEPA Chapter 99 HTS code; (3) no entry number appears more than once across all Declarations; (4) entry types are eligible for the active phase (no Types 21/22 after July 7, 2026; no entries with a filed Type 09 if filing under Phase 2); (5) your ACH information is confirmed. CAPE Declarations cannot be amended once accepted — additional entries require a new Declaration. TariffIQ™ performs all these checks automatically before handing you the validated file.

Upload your validated CSV in the CAPE tab of your ACE Secure Data Portal account. ACE performs two sequential validation series. File-level validation confirms the submitter is the IOR or authorized broker, the file includes entry numbers, and the format is correct. If the file fails, the entire Declaration is rejected — download the Validation Result File to identify issues, correct them, and resubmit. Entry-level validation checks each individual entry. Entries that fail validation are rejected individually while valid entries continue to process — you can review per-entry results in the CAPE Claim Status section. Once entries are accepted, ACE removes IEEPA HTS codes and reliquidates. Treasury ACH payments are batched by IOR and liquidation date — processing times vary by volume. Monitor your CAPE Claim Status and ACE accounts regularly.