For importers who paid materially more in 2025 under challenged IEEPA orders, our Managed Recovery program delivers the deadline-aware, audit-defensible administrative path to recovery, coordinated with your customs brokers and qualified counsel.
Recent rulings created a significant recovery opportunity with respect to challenged IEEPA tariff collections. The practical burden now falls on affected stakeholders to identify entries, assemble the record, and navigate the administrative pathway to recovery.
For many importers, the hardest part is not claiming the refund. It is receiving and administering it without triggering downstream disputes, payment errors, or control failures.
Our Managed Recovery program provides the end-to-end administrative capacity to ensure your business doesn't leave millions on the table due to procedural bottlenecks.
The recovery pathway changes based on your position in the supply chain.
You paid the duties to CBP directly. We provide comprehensive, end-to-end administrative support: coordinating with your customs broker, preparing claim-ready entry schedules, and where formal filings are required, coordinating with qualified customs counsel.
View Importer Roadmap →You absorbed the economic burden through landed costs or chargebacks, but you don't control the ACE entry data. We help you quantify the burden, document entitlement, and structure the path to recovery.
View Consignee Roadmap →Many importers act as IOR on behalf of customers, affiliates, or ultimate consignees. Refund entitlement, allocation, and disbursement become complex.
We work with brokers to create centralized, scalable IEEPA recovery programs for their importer clients. Brokers stay focused on brokerage; we assume responsibility for the administrative side.
For many businesses, the refund does not end with recovering money from the government. It begins with the harder question: who is actually entitled to that money once it arrives.
In many supply chains, the Importer of Record made the customs entry, but downstream consignees, customers, affiliates, or commercial counterparties may have absorbed all or part of the tariff burden through pricing, reimbursements, chargebacks, or contract structure.
An importer that attempts to manage this process informally faces material exposure: under-distributing funds to parties with legitimate claims, over-distributing without sufficient support, missing statutory deadlines, or creating avoidable disputes with key commercial partners.
In many transactions, the party listed as Importer of Record was not the party that ultimately bore the economic cost of the tariff. Consignees, distributors, customers, and other downstream parties may have funded those amounts through landed-cost pricing, reimbursements, contractual pass-throughs, or related commercial arrangements.
Those parties face a practical problem: they do not control the customs entry and they do not possess the full broker file. We help economically affected parties assemble the documentary record necessary to trace the tariff burden to specific entries and prepare structured demands or allocation proposals.
In 2025, the Executive Branch invoked the International Emergency Economic Powers Act to impose significant additional duties on imports, including targeted tariffs on Canada, Mexico, and China and broadly applied "reciprocal" baseline duties affecting numerous trading partners.
These measures have materially increased landed costs for U.S. importers and are now the subject of major litigation challenging whether IEEPA authorizes tariffs of this scope. Because duties are assessed and refunds governed by strict customs procedures (specifically liquidation timelines), businesses must evaluate refund-preservation steps early, even while appellate review continues.
| Origin | Illustrative Rate | Scope & Notes | Timing |
|---|---|---|---|
| China | +10% to +25% | Product- and instruction-specific; refer to CBP guidance for definitive scope. | Phased, early 2025 |
| Canada & Mexico | ~25% | Subject to specific eligibility rules and CBP instructions regarding exceptions. | Effective early 2025 |
| Global "Reciprocal" | ~10% baseline | Ad valorem duty on imports from trading partners lacking specific exclusions. | Spring 2025 |
Specific treatment varies based on HTSUS classification and program eligibility.
Machinery, auto parts, steel and aluminum derivatives.
Electronics, apparel, household goods.
Refined petroleum products, solar components.
High-volume "de minimis" shipments, subject to aggregation rules.
They require affirmative steps before liquidation becomes final.
Liquidation is the final computation of duties. Once liquidated, an importer generally has 180 days to file a Protest (CBP Form 19). If this window is missed, the duty assessment becomes final and unreviewable.
We manage the Protest Calendar for clients: filing protective protests to keep entries alive administratively while litigation proceeds. We may also use Post-Summary Corrections or request extensions of liquidation where strategic to avoid premature finality.
If the IEEPA tariffs are ultimately held invalid, the only proper administrative mechanism for a refund is a formal customs protest (CBP Form 19), not a Post Summary Correction. This distinction is dispositive of refund rights.
A narrow, pre-liquidation tool intended to correct errors that existed at filing: clerical mistakes or classification errors. IEEPA duties don't fit this framework.
Established by Congress under 19 U.S.C. § 1514 specifically for this situation: challenging CBP's final duty determination after liquidation based on questions of law.
U.S. Customs and Border Protection has signaled that its collection of the 2025 IEEPA tariffs constitutes a ministerial act. Under this theory, CBP maintains it merely implemented executive directives without exercising independent discretion.
Based on Federal Circuit precedent, CBP may assert that its implementation of the tariffs is not a 'protestable decision.' Consequently, CBP may deny protests on jurisdictional grounds without addressing the underlying legality of the executive orders, arguing those determinations reside exclusively with the judiciary.
Despite administrative positioning, the framework under 19 U.S.C. § 1514 and § 1515 remains clear: once a protest is properly filed and allowed, any duties collected in excess of what is required by law must be refunded. For unliquidated entries, CBP is mandated to refund duties not legally owed at the time of final liquidation.
Importers must prepare for a non-linear refund environment. Our Managed Recovery program accounts for three potential pathways:
A refund strategy often turns on whether a timely and properly authorized filing is made for the applicable entries. CBP filings are governed by customs procedures and deadlines, and the work must be handled by parties authorized to represent the importer before U.S. Customs and Border Protection.
A CBP filing is submitted by the importer through an authorized representative: typically a licensed customs broker acting within the scope of its license, or an attorney representing the importer.
Our Managed Recovery program is structured accordingly: we coordinate the administrative and data side of the recovery, and where formal legal representation is required, we coordinate with qualified customs counsel separately engaged by the client. This division of labor ensures your legal team focuses on the law while we focus on data, documentation, and administration.
Proceed with caution when evaluating tech-only providers, pop-up operators, and high-volume mills. Many may be unaware that only attorneys or properly authorized licensed customs brokers can submit and prosecute CBP filings on a client's behalf.
If a firm sells "automation" but cannot clearly explain who is legally representing you before CBP, who is signing and filing on your behalf, and under what authority, that is a red flag. A proper program is explicit about representation, credentials, and accountability, not just software workflows.
On November 28, 2025, Costco Wholesale Corporation filed suit in the U.S. Court of International Trade challenging the legality of the IEEPA tariff orders.
Plaintiffs argue that IEEPA grants the President authority to regulate international economic transactions during emergencies but does not authorize the imposition of sweeping tariff regimes absent clear Congressional delegation. This separation-of-powers argument is central to the claim for refunds.
Depending on posture, importers may pursue CIT jurisdiction under 28 U.S.C. § 1581(a) following a protest decision or, in limited circumstances, § 1581(i) where appropriate.
We coordinate with specialized customs counsel to manage this escalation. In many cases, counsel can file protective complaints stayed pending the outcome of the lead test cases, minimizing active legal costs while preserving your place in line for a refund.
Actual recovery requires a disciplined execution phase, often involving thousands of individual entries.
Following a favorable court ruling or protest approval, CBP may reliquidate entries to refund the excess duty.
Under 28 U.S.C. § 2644, interest may be payable on refunded duties depending on the posture of the claim. We verify these calculations against statutory rates.
We trace refunds back to specific entries and payment sources, ensuring funds are returned to the correct entity. Especially complex for clients using multiple brokers or financing.
The IEEPA tariff environment involves evolving appellate decisions, thousands of entries, and strict statutory deadlines. It demands a disciplined operational framework, not just software.
A missed protest window extinguishes your claim forever. Our system monitors these daily and flags entries against the liquidation calendar.
We consolidate data from multiple brokers into a single source of truth for your duty exposure, with reconciliation across ACE feeds.
Chain of custody for every document, ensuring you are ready if CBP scrutinizes the refund claim later in the lifecycle.
Provide your details for a high-level assessment. The form is private, brief, and reviewed by a team that handles deadline-driven recoveries every day.