What is the purpose of an IEEPA refund checklist?

An IEEPA refund checklist helps importers get operationally ready before they pursue duty recovery. In practice, that means making sure you can access ACE data, receive ACH refunds, isolate the affected entry lines, and distinguish IEEPA duties from other tariff layers such as Section 301 and Section 232.

What is the ACE Secure Data Portal used for in an IEEPA refund project?

The ACE Secure Data Portal is the practical starting point because it gives the importer or broker access to entry data, reports, and account configuration needed to analyze refund eligibility. If the account is not active or permissions are incomplete, the refund work usually stalls before it starts.

Why do I need ACH refunds configured in ACE?

If refunds are approved, ACH setup is the cleanest way to receive them. Many importers discover late in the process that refund banking instructions were never configured or were configured for a different entity. Verifying ACH early prevents a successful claim from turning into a payment operations problem.

What is ES-003 in this context?

ES-003 is commonly used as the report pull importers rely on to review entry-level data and isolate affected imports. In a refund workflow, it helps identify relevant entry numbers, dates, duty amounts, and coding patterns that need to be reviewed with counsel or the customs broker.

Why is it important to separate IEEPA duties from Section 301 and Section 232?

Because they are legally and operationally different tariff layers. A refund or correction analysis that lumps them together can overstate or understate the recoverable amount. You want a line-by-line breakdown showing base duty, IEEPA, Section 301, Section 232, and any other applicable duties separately.

An HTS (Harmonized Tariff Schedule) code is a 10-digit classification number used by US Customs and Border Protection to identify imported goods and determine applicable duty rates. The first 6 digits are standardized internationally under the Harmonized System, while the last 4 digits are specific to the United States.

How are US tariff rates determined?

US tariff rates are set by Congress and administered by CBP. The base MFN (Most Favored Nation) rate applies to most trading partners. Additional special tariffs — such as Section 301 (China), Section 232 (steel and aluminum), and Section 122 (temporary global surcharge, 10–15% per Proclamation 11012) — may apply on top of the base rate. Note that Section 122 does not stack with Section 232: goods already subject to §232 actions are excluded from the §122 surcharge.

What are Section 301 tariffs?

Section 301 tariffs are additional duties imposed on Chinese goods under the Trade Act of 1974, in response to unfair trade practices. They range from 7.5% to 100% depending on the product category and apply on top of the standard MFN duty rate. Four separate lists cover approximately $370 billion of annual imports.

How do I find the tariff rate for my product?

Use the search bar on this site to describe your product in plain English — our AI identifies the correct HTS code and shows all applicable duty rates including base MFN, Section 301, Section 232, and any other overlays. You can also browse by HTS chapter or product category.

What is a landed cost?

Landed cost is the total cost of importing a product to its destination, including the product price (FOB), ocean or air freight, insurance, US Customs duties, Merchandise Processing Fee (MPF), Harbor Maintenance Fee (HMF), and any other applicable surcharges. It represents the true cost of an imported good before domestic distribution.

Import Operations Checklist

IEEPA Refund Checklist: How to Prepare ACE, Pull the Right Data, and Separate Recoverable Duty

This is not a generic tariff explainer. It is a practical prep list for importers and brokers getting ready to analyze potential IEEPA duty refunds. The goal is simple: make sure your ACE access, refund plumbing, entry data, and broker workflow are in place before you try to calculate what may be recoverable.

What this checklist is for

In real refund work, the biggest delays usually are not legal theory. They are operational. The ACE portal is not set up, the importer cannot receive ACH refunds, the broker has not pulled the right report, or the duty stack has been exported in a way that mixes IEEPA with Section 301, Section 232, MPF, and ordinary customs duty.

This page is designed to prevent that. Use it as a readiness checklist before filing corrections, preparing PSCs, or estimating the amount at stake.

The checklist

1. Confirm ACE Secure Data Portal access

Make sure the importer of record has an active ACE Secure Data Portal account and the right permissions. If outside counsel, consultants, or finance staff need visibility, confirm that access paths and roles are already set up before the refund analysis begins.

2. Verify ACH refund instructions in ACE

Check that ACH refund setup is complete for the correct legal entity. Do this early. A surprising number of refund projects hit avoidable delays because payment instructions were never activated or were attached to an outdated account profile.

3. Pull ES-003 and retain the raw export

Pull the ES-003 report and preserve the original export before anyone starts filtering, cleaning, or reformatting it. That raw dataset becomes the working source for identifying affected entries, dates, amounts, and coding patterns.

4. Identify IEEPA-coded entries and lines

Go line by line and isolate entries that carry the relevant IEEPA coding. The initial filter should focus on the affected Chapter 99 numbers, including 9903.01.xx and 9903.02.xx patterns, then be validated against the actual entry record and supporting broker documentation.

5. Separate IEEPA duty from Section 301 and Section 232

Do not work from a single blended duty number. Build a clean breakdown showing base duty, IEEPA duty, Section 301, Section 232, and any other overlays separately. If the numbers are not separated, the refund estimate is not reliable.

6. Flag unliquidated entries for PSC review

Coordinate with the customs broker to identify entries that remain unliquidated and may be candidates for PSC action. Those entries usually need to be handled differently from already liquidated entries, both tactically and on timing.

7. Reconcile entry data against broker workpapers

Before estimating recoverable duty, compare the ACE export against broker-side entry summaries, payment records, and any internal landed-cost files. Refund projects go sideways when the ACE dataset and the broker file are assumed to match but do not.

8. Build a recoverability worksheet

Create a working file that tracks entry number, entry date, importer, HTS code, Chapter 99 code, declared value, IEEPA duty paid, other duties paid, liquidation status, and next action. That worksheet becomes the control panel for the project.

The key mistake to avoid

The most common analytical mistake is treating total duty paid as if it were one bucket. It is not. If your entry carried ordinary customs duty plus IEEPA plus Section 301 or Section 232, each layer needs to be reviewed separately. Otherwise you cannot tell what portion is potentially recoverable.

That is exactly where a line-by-line HTS and tariff overlay tool helps. The operational question is not just, “what did we pay?” It is, “what did we pay under which authority?”

How USTariffRates helps

Use USTariffRates to separate tariff layers by HTS code before you build the refund estimate. That means checking whether the product carried base duty only, or whether it also stacked with Section 301, Section 232, or other overlays. The cleaner that breakdown is at the start, the faster the refund analysis goes.

Separate IEEPA vs. Section 301 vs. Section 232 by HTS code

Search any HTS code to see the tariff stack and build a cleaner refund worksheet.

Search tariff rates Estimate refund amount Open claim workspace

Section 301 Tariffs

China tariff lists, rates, and the product-level surcharge that often needs to be separated from IEEPA.

Section 232 Tariffs

Steel, aluminum, and copper surcharges that may stack separately from IEEPA duties.

Landed Cost Calculator

Model the full duty stack before you estimate what portion may be recoverable.

De Minimis Updates

Track adjacent import-policy changes that affect customs operations and entry treatment.