The legal result is only the beginning.
Recovery now turns on claims administration.
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.
What we own end-to-end:
- Entry and tariff identification across all customs brokers
- Liquidation and reliquidation tracking against statutory deadlines
- Refund allocation and payment administration to the right party
- Documentation and audit defense with full chain of custody
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.
Select Your Recovery Profile
The recovery pathway changes based on your position in the supply chain.
Importers of Record
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 →Consignees and Downstream Parties
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 →IORs Acting on Behalf of Downstream Customers
Many importers act as IOR on behalf of customers, affiliates, or ultimate consignees. Refund entitlement, allocation, and disbursement become complex.
- Coordinate the recovery filing on behalf of the IOR, working with qualified counsel where required
- Serve as third-party administrator for refund allocation and payment flows
- Coordinate disbursement of proceeds to downstream beneficiaries
- Obtain appropriate legal releases and acknowledgments
- Structure compliant sharing of recoveries between IOR and ultimate consignees
Customs Brokers
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.
- Offer IEEPA recovery as a value-added service
- Avoid legal exposure associated with protest filings
- Provide clients a consistent, white-glove experience
- Participate in compliant commercial arrangements where permitted
Why Importers of Record should not manage this alone
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.
For consignees and downstream parties
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.
A new tariff matrix, layered on existing customs procedure
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 |