For CBP-licensed customs brokers
Your IEEPA refund specialist
that files nothing.
Think of Tariffi like a duty-drawback specialist — but for the CBP CAPE refund program. We handle the massive historical data prep your firm isn’t staffed for. Your license. Your ABI. Your client relationship. Generate massive advisory revenue with a flat per-filing data-service fee (per 19 CFR § 111.36) paid from our corporate operating account — never a percentage, and never touching client duty funds.
License Protection
Advisory revenue without ever touching client duty funds.
The platform is engineered to keep your 19 CFR Part 111 customs broker license clean while generating a new revenue stream on historical IEEPA filings. Two distinct commercial relationships, per 19 CFR § 111.36(c):
Relationship 1
Importer → Tariffi
Importer contracts Tariffi directly for data-preparation software. Tariffi charges a contingency software fee on recovered Treasury capital. This is B2B SaaS revenue — not customs-business revenue, not a broker fee.
Relationship 2
Tariffi → you
Tariffi pays you a flat per-filing data-service fee from our corporate operating account. Standard B2B marketing-commission accounting. You never touch client duty funds; we never inject ourselves into a customs-business fee split.
The compliance shield: if CBP audits you on § 111.36(b) kickback lines, the answer is narrow and defensible — “I receive a flat per-filing data-service fee from Tariffi’s operating account — not a percentage of any client’s Treasury refund.”
Why brokers partner with Tariffi
Limited scope: refund filings only
Tariffi prepares IEEPA refund data — nothing else. We never clear freight. We never solicit your clients for entry-filing work. We never touch ABI. You download the validated CAPE CSV from our broker portal, review it, and upload it to ACE under your own license and filer code. Your day-one client relationship is untouched.
Flat per-filing fee — not a percentage
You earn a flat data-service fee for each CAPE filing you review and transmit. Not a percentage of the refund. Not a revenue share. Structured to comply with 19 CFR § 111.36, which prohibits brokers from sharing customs-business fees with unlicensed parties.
We handle the data prep you don’t want to
Client onboarding, ACE ES-003 ingestion, HTS validation (6-digit AI guidance per H350722, your final 10-digit call), UEV calculation, 9,999-entry chunking, CAPE declaration formatting. You get a clean, validated CSV ready for ACE upload.
How the partnership works
Your Client Starts Intake On Tariffi
SME uploads their ACE ES-003 export (the universal CBP-sanctioned format). We handle all data normalization — no PDFs, no broker-specific CSVs required.
We Prepare The CAPE Declaration
HTS validation (6-digit AI-assisted, your final 10-digit call per H350722), UEV calculation, 9,999-entry chunking.
You Review + Download The CSV
Log into your Tariffi broker portal. Download the 4-column CBP ACE CSV. Verify entry count + HTS codes.
You File Via Your Own ACE Portal
Upload the CSV to ACE under your license and filer code. Confirm transmission. You earn a flat per-filing fee.
Your compliance posture is protected
19 CFR Part 111: You exercise responsible supervision (§ 111.28) and maintain accuracy standards (§ 111.29) on every filing. Tariffi provides data; you make the filing judgment.
19 CFR § 111.36: Your fee is a flat data-service fee paid by Tariffi from its own revenue pool. It does NOT come from the importer’s contingency fee, and it is NOT a percentage of any customs-business revenue. Two separate commercial relationships, two separate fee streams.
CBP Ruling HQ H326926: Confirms the boundary between licensed customs business (your domain) and data-preparation services (ours). The LPOA is between the importer and you directly —Tariffi is not a party.
CBP Ruling HQ H350722: AI/OCR platforms may suggest HTS at the 6-digit HS level. Tariffi’s platform caps classification guidance at 6 digits; all final 10-digit HTSUS determinations are your call. If our suggestion and your judgment differ, we hold — we do not file.
Broker FAQ
Questions brokers actually ask
No. Your license, your ABI transmission, your ACE portal. Tariffi prepares the CAPE-formatted declaration data and broker-review artifacts; you sign and transmit. Per 19 USC § 1641 and CBP Ruling HQ H326926, only a licensed customs broker may conduct customs business — and Tariffi is not one.
Tariffi works like a drawback specialist — focused on historical refund recovery, never daily freight clearance — but for IEEPA CAPE refunds, not 19 USC § 1313 drawback. Two important differences:
- Comstock & Holt and Charter Brokerage are themselves CBP-licensed brokers and file drawback claims under their own Filer Code. Tariffi is not CBP-licensed. Your license is what makes each CAPE filing possible.
- Traditional drawback specialists often charge a percentage of the recovered duties. Tariffi pays you a flat per-filing data-service fee under 19 CFR § 111.36(c) — never a percentage of the refund or the advance, and never a referral bounty. The two-fee structure (importer contingency to Tariffi; flat data-service fee to you) keeps us inside § 111.36(b)’s prohibition on fees “inuring to the benefit of” unlicensed parties.
No. Our scope is limited to IEEPA refund filings under the CAPE program. We do not offer daily customs entry services, freight forwarding, or drawback outside IEEPA. Every broker partnership is governed by a contractual non-solicit covering referred importers. If a referred importer wants to consolidate their daily brokerage with us, we decline and refer them back to you.
The broker of record signs and transmits, which under Part 111 puts you on the hook at CBP. Three mitigants:
- All 10-digit HTSUS statistical-suffix calls are your determinations per CBP Ruling HQ H350722. Tariffi caps AI classification at the 6-digit HS heading/subheading level.
- The partnership agreement includes Tariffi’s indemnification for data-prep errors traceable to our platform (dollar cap set per agreement).
- We ship a full audit trail (7-year retention per 19 CFR Part 163) with every filing so you can reconstruct the decision chain in a CBP inquiry.
No. Each broker partner has an isolated tenant — you see only the CAPE filings assigned to your filer code. No cross-broker visibility, no aggregated client lists. Tenant isolation is enforced at the database layer with role-scoped access and audit logging.
Tariffi is purpose-built for the IEEPA refund opportunity created by the Supreme Court ruling and CBP’s CAPE rulemaking — a finite specialty. If that window closes without a follow-on tariff-refund program, we wind down refund operations. We do not pivot into daily freight or entry filing. Your client’s broker is you, before IEEPA and after.
Verify your Filer Code
Enter your CBP filer code — we’ll match it against the official CBP Permitted Customs Brokers Listing and surface your firm. Flat per-filing data-service fee per 19 CFR § 111.36.