Tariff Refund FAQ

Upload your ACE ES-003 entry-summary CSV to Tariffi. Our platform analyzes your entries for IEEPA overpayments (recovered through CAPE) and Section 301 overpayments (recovered separately via USTR exclusions), prepares the filing data, and routes it to a CBP-licensed customs broker partner who files under their own license. No advance fees — you pay a contingency only when CBP approves your refund.

CAPE (Consolidated Administration and Processing of Entries) is CBP's electronic program for processing IEEPA tariff refund declarations. Importers who overpaid IEEPA tariffs submit CAPE declarations through the ACE portal. (Section 301 duties are not refundable through CAPE — that is a separate USTR-exclusion path.) Tariffi automates the data preparation; your licensed customs broker partner transmits the declaration under their ABI filer code.

You may be eligible if you are a U.S. importer of record who paid tariffs under the International Emergency Economic Powers Act on qualifying entries within the CAPE lookback window. Upload your ES-003 entry-summary CSV and Tariffi analyzes each entry's eligibility automatically — no commitment required to check.

Refund timing is governed by federal statute, not by Tariffi. CBP has up to two years to decide a protest under 19 U.S.C. § 1515, though most CAPE Phase 1 claims process faster. After CBP allows your claim, Treasury ACHs the refund directly into your own bank account within 1-3 business days. CIT filings for older entries add court calendar time.

You need your ES-003 entry-summary CSV from the ACE portal — the universal export every U.S. broker and importer of record can produce. Tariffi extracts all required data (entry numbers, HTS codes, duty amounts, liquidation dates) from this single file. No additional paperwork is required to start the process.

Section 301 recovery depends on whether a USTR exclusion covers your HTS codes and how much Section 301 duty you overpaid. Section 301 is NOT recovered through CAPE (which refunds IEEPA only) — it runs through a Post-Summary Correction or § 1514 protest. Upload your ES-003 and Tariffi calculates your estimated Section 301 recovery plus any IEEPA reciprocal (9903.02) amount recoverable through CAPE.

An ES-003 is CBP's standardized entry-summary export from the ACE portal in CSV format. It contains all data needed for CAPE declarations: entry numbers, HTS codes, duty amounts, and liquidation dates. Your customs broker can pull it, or you can export it directly from ace.cbp.gov if you have portal access.

Yes. Federal law (19 U.S.C. § 1641) requires a CBP-licensed customs broker to file CAPE declarations. Tariffi is a data-preparation platform, not a broker — we prepare your declaration data and route it to a licensed broker partner who reviews, approves, and transmits under their own ABI filer code at no extra cost to you.

CAPE Phase 1 does not have a single batch deadline. Each entry has its own 180-day protest window per 19 CFR § 174.12 starting from the liquidation date. Entries that have already passed this window may still qualify through a protective CIT filing. File sooner to capture more entries before their individual windows close.

Tariffi charges a contingency-only fee with three tiers: 10% on unliquidated entries (or entries liquidated within 80 days of engagement), 15% on entries liquidated 80–180 days ago, and 18% on finally liquidated entries requiring CIT protective filing. No retainer, no advance fees, no deposits. If CBP denies your claim, you owe nothing on the denied portion.

No. Tariffi charges zero advance fees, zero retainers, and zero deposits. You pay only a contingency fee when CBP approves your refund and Treasury sends the money. This is not just a policy — it is a legal requirement under 16 CFR § 310.4(a)(2), the federal Telemarketing Sales Rule.

If CBP denies any entry in your CAPE declaration, you owe nothing on the denied portion. Your broker partner (Filer of Record) responds to any CBP Form 28 or Form 29 within the scope of the LPOA at no additional charge. For entries worth contesting, the broker may file a further protest or recommend CIT action.

IEEPA tariffs are imposed under the International Emergency Economic Powers Act during declared national emergencies. Section 301 tariffs are imposed under the Trade Act of 1974 to counter unfair trade practices, primarily targeting Chinese imports across four tranches. They recover differently: IEEPA through CBP's CAPE portal, Section 301 through the separate USTR-exclusion path (PSC or § 1514 protest). Tariffi handles both.

Technically yes, if you have ACE portal access and a licensed customs broker willing to file. However, preparing the declaration data requires cross-referencing entry-level HTS codes against the CAPE-eligible tariff schedule, calculating duty differentials, and formatting to CBP's specifications. Tariffi automates this and includes broker filing at no extra cost.

Section 301 tariffs primarily affect goods imported from China across four lists covering thousands of product categories: electronics, machinery, textiles, furniture, auto parts, toys, chemicals, and more. IEEPA tariffs can target goods from any country under an emergency declaration. Specific product coverage depends on the HTS codes in each tariff action.

Tariffi is a data-preparation platform with a contingency-only fee (10/15/18%), no advance fees, and broker-compliant architecture per CBP Ruling HQ H326926. We never file with CBP directly — your licensed broker partner is always the Filer of Record. The ES-003-only intake keeps preparation deterministic and auditable under 19 CFR Part 163.

CAPE Phase 2, live since June 29, 2026 (CSMS #68340863), covers entries flagged for reconciliation: consumption entries (types 01, 02, and 06) that carry a reconciliation flag but have no filed Type 09 reconciliation entry. CBP estimates roughly 2.8 million such entries, representing about $28.7 billion in IEEPA duties, are now declarable through CAPE.

CAPE Phase 3 is the expected final phase of CBP's IEEPA refund program, covering finally liquidated entries — approximately $11.4 billion in duties. CBP has indicated late July 2026, but the scope is contested: DOJ is appealing the CIT's universal-refund order, and Phase 3 could be narrowed. A § 1514 protest within 180 days of liquidation is the protective path.

No — effective July 7, 2026 (CSMS #69127837), CBP rejects warehouse entry types 21 and 22 from CAPE with an 'ENTRY TYPE NOT ALLOWED' error. The IEEPA duty is still refundable, but the declaration must cite the withdrawal entries (types 31, 32, 34, or 38), where the duty was actually assessed and paid.

Five checks: legitimate recovery services never charge advance fees (16 CFR § 310.4(a)(2) makes it illegal); CBP never charges you to release a refund; real refunds arrive only by ACH to the importer of record's own verified bank account; attorneys cannot file CAPE Declarations (CBP FAQ) — only the IOR or the licensed broker who filed the entries can; and any broker's license can be verified with CBP.

Upload your ACE ES-003 entry-summary CSV to Tariffi. Our platform analyzes your entries for IEEPA overpayments (recovered through CAPE) and Section 301 overpayments (recovered separately via USTR exclusions), prepares the filing data, and routes it to a CBP-licensed customs broker partner who files under their own license. No advance fees — you pay a contingency only when CBP approves your refund.

CAPE (Consolidated Administration and Processing of Entries) is CBP's electronic program for processing IEEPA tariff refund declarations. Importers who overpaid IEEPA tariffs submit CAPE declarations through the ACE portal. (Section 301 duties are not refundable through CAPE — that is a separate USTR-exclusion path.) Tariffi automates the data preparation; your licensed customs broker partner transmits the declaration under their ABI filer code.

You may be eligible if you are a U.S. importer of record who paid tariffs under the International Emergency Economic Powers Act on qualifying entries within the CAPE lookback window. Upload your ES-003 entry-summary CSV and Tariffi analyzes each entry's eligibility automatically — no commitment required to check.

Refund timing is governed by federal statute, not by Tariffi. CBP has up to two years to decide a protest under 19 U.S.C. § 1515, though most CAPE Phase 1 claims process faster. After CBP allows your claim, Treasury ACHs the refund directly into your own bank account within 1-3 business days. CIT filings for older entries add court calendar time.

You need your ES-003 entry-summary CSV from the ACE portal — the universal export every U.S. broker and importer of record can produce. Tariffi extracts all required data (entry numbers, HTS codes, duty amounts, liquidation dates) from this single file. No additional paperwork is required to start the process.

Section 301 recovery depends on whether a USTR exclusion covers your HTS codes and how much Section 301 duty you overpaid. Section 301 is NOT recovered through CAPE (which refunds IEEPA only) — it runs through a Post-Summary Correction or § 1514 protest. Upload your ES-003 and Tariffi calculates your estimated Section 301 recovery plus any IEEPA reciprocal (9903.02) amount recoverable through CAPE.

An ES-003 is CBP's standardized entry-summary export from the ACE portal in CSV format. It contains all data needed for CAPE declarations: entry numbers, HTS codes, duty amounts, and liquidation dates. Your customs broker can pull it, or you can export it directly from ace.cbp.gov if you have portal access.

Yes. Federal law (19 U.S.C. § 1641) requires a CBP-licensed customs broker to file CAPE declarations. Tariffi is a data-preparation platform, not a broker — we prepare your declaration data and route it to a licensed broker partner who reviews, approves, and transmits under their own ABI filer code at no extra cost to you.

CAPE Phase 1 does not have a single batch deadline. Each entry has its own 180-day protest window per 19 CFR § 174.12 starting from the liquidation date. Entries that have already passed this window may still qualify through a protective CIT filing. File sooner to capture more entries before their individual windows close.

Tariffi charges a contingency-only fee with three tiers: 10% on unliquidated entries (or entries liquidated within 80 days of engagement), 15% on entries liquidated 80–180 days ago, and 18% on finally liquidated entries requiring CIT protective filing. No retainer, no advance fees, no deposits. If CBP denies your claim, you owe nothing on the denied portion.

No. Tariffi charges zero advance fees, zero retainers, and zero deposits. You pay only a contingency fee when CBP approves your refund and Treasury sends the money. This is not just a policy — it is a legal requirement under 16 CFR § 310.4(a)(2), the federal Telemarketing Sales Rule.

If CBP denies any entry in your CAPE declaration, you owe nothing on the denied portion. Your broker partner (Filer of Record) responds to any CBP Form 28 or Form 29 within the scope of the LPOA at no additional charge. For entries worth contesting, the broker may file a further protest or recommend CIT action.

IEEPA tariffs are imposed under the International Emergency Economic Powers Act during declared national emergencies. Section 301 tariffs are imposed under the Trade Act of 1974 to counter unfair trade practices, primarily targeting Chinese imports across four tranches. They recover differently: IEEPA through CBP's CAPE portal, Section 301 through the separate USTR-exclusion path (PSC or § 1514 protest). Tariffi handles both.

Technically yes, if you have ACE portal access and a licensed customs broker willing to file. However, preparing the declaration data requires cross-referencing entry-level HTS codes against the CAPE-eligible tariff schedule, calculating duty differentials, and formatting to CBP's specifications. Tariffi automates this and includes broker filing at no extra cost.

Upload your ES-003 entry-summary CSV at tariffi.io/intake/start. Tariffi's analysis engine automatically cross-references each entry's HTS codes against the CAPE-eligible tariff schedule, checks liquidation status, identifies disqualifying factors, and shows you a per-entry breakdown of eligible amounts and applicable fee tiers.

Law firms typically bill $1,000-1,200/hour plus a 15-40% contingency and take 6-18 months. Tariffi charges a tiered 10-18% contingency only, targets 8-12 weeks from filing to Treasury settlement, and never bills hourly. We prep the data; a licensed customs broker files. For CIT litigation, hire a law firm. For CAPE refund recovery, use Tariffi.

CBP/Treasury ACHs the refund directly into your own bank account — the account you keep on file with CBP in ACE. Tariffi is never in the money path: no clearing account, no escrow, no pass-through. After your refund lands, Tariffi collects only its authorized contingency fee (10%/15%/18% by liquidation status) from your account — by invoice or, if you authorize it, a pre-authorized ACH debit — as set out in your Customer Fee Agreement. Refunds typically settle 1-3 business days after CBP's allow-decision.

A CBP protest under 19 U.S.C. § 1514 is the traditional mechanism for challenging individual customs decisions. A CAPE declaration is the streamlined electronic format specifically designed for tariff refund claims, covering multiple entries in a single filing. CAPE is faster and less documentation-intensive than traditional protests for qualifying entries.

ACE (Automated Commercial Environment) is CBP's online portal for processing trade-related transactions. Importers and brokers use ACE to file entry summaries, manage protests, submit CAPE declarations, and configure ACH refund information. You do not need direct ACE access to use Tariffi — your customs broker partner handles ACE transmission.

Liquidation is CBP's final determination of the duties, taxes, and fees owed on a customs entry. Once an entry is liquidated, the 180-day protest window starts. Unliquidated entries get the lowest Tariffi fee tier (10%), recently liquidated entries are 15%, and entries liquidated beyond 180 days require CIT filing at 18%.

An LPOA authorizes a licensed customs broker to act on your behalf for specific customs transactions — in this case, filing CAPE declarations. You sign the LPOA directly with the broker partner (not with Tariffi) during intake. It is limited in scope to CAPE filings and does not give the broker authority over your other customs business.

An HTS (Harmonized Tariff Schedule) code is a 10-digit classification that identifies the tariff rate applied to an imported product. HTS codes determine whether your entries carried IEEPA tariffs (recoverable through CAPE) or Section 301 tariffs (recoverable separately via USTR exclusions). Tariffi cross-references your ES-003 HTS codes against the IEEPA CAPE schedule and the Section 301 exclusion schedule automatically.

Yes. Your dashboard at tariffi.io/dashboard shows real-time claim status including entry-level progress, broker review status, CBP submission confirmation, and payout tracking. Every status milestone also triggers an email notification. If you have not received an update in 90 days, contact support — silence usually means we are waiting on CBP.

No. Tariffi focuses exclusively on tariff overpayment recovery — CAPE declarations for IEEPA refunds and USTR-exclusion claims for Section 301. Duty drawback (19 U.S.C. § 1313) is a separate CBP program for recovering duties on goods that are re-exported or destroyed. If your entries have existing drawback claims, Tariffi flags the conflict to avoid duplicate filing issues.

No problem. Tariffi supports multi-file upload from multiple brokers. Upload ES-003 exports from each broker who filed entries on your behalf. Our platform groups entries by IOR number across all files and routes CAPE declarations to the appropriate broker partner for each set of entries based on the original Filer Code.

Yes. Tariffi uses AES-256 encryption at rest, TLS 1.2+ in transit, role-scoped database access with audit logging, and 7-year data retention per 19 CFR Part 163. ES-003 files are archived to cold storage with year-segmented paths and lifecycle deletion policies. Pre-signed download URLs expire after 60 seconds.

Form 28 (Request for Information) is CBP asking for additional documentation to evaluate your entry. Form 29 (Notice of Action) is CBP notifying you of a proposed change to your entry, including a potential denial. Your broker partner (Filer of Record) responds to both within the LPOA scope at no additional charge through Tariffi's engagement.

A CIT (Court of International Trade) protective filing is a legal action filed in federal court to preserve your refund rights on entries whose 180-day protest window has closed. It is the mechanism for older liquidated entries that can no longer use the standard CBP protest process. Tariffi facilitates CIT filings at the 18% contingency tier.

Yes. You can revoke the LPOA and terminate the Contingency Fee Agreement by written notice at any time before the CAPE declaration is filed with CBP. Once filed, the broker is the Filer of Record and the engagement continues through the claim lifecycle. Contact support@tariffi.io to initiate cancellation.

The Filer of Record is the CBP-licensed customs broker whose name, license number, and ABI filer code appear on a CAPE declaration or protest filed with CBP. The Filer of Record bears professional responsibility for the filing under 19 CFR Part 111. At Tariffi, the broker partner is always the Filer of Record — we prepare data but never file.

After CBP allows your declaration, Treasury ACHs the refund directly into your own bank account (on file with CBP in ACE) within 1-3 business days. Tariffi never holds the money — once it lands, we collect only our authorized contingency fee from your account — by invoice or, if you've authorized it, ACH debit — per your Customer Fee Agreement. You get email notifications at each step.

CAPE Phase 2, live since June 29, 2026 (CSMS #68340863), covers entries flagged for reconciliation: consumption entries (types 01, 02, and 06) that carry a reconciliation flag but have no filed Type 09 reconciliation entry. CBP estimates roughly 2.8 million such entries, representing about $28.7 billion in IEEPA duties, are now declarable through CAPE.

CAPE Phase 3 is the expected final phase of CBP's IEEPA refund program, covering finally liquidated entries — approximately $11.4 billion in duties. CBP has indicated late July 2026, but the scope is contested: DOJ is appealing the CIT's universal-refund order, and Phase 3 could be narrowed. A § 1514 protest within 180 days of liquidation is the protective path.

You have two parallel paths. First, if the entry liquidated within the last 180 days, file a protest under 19 U.S.C. § 1514 now — that preserves the claim no matter what. Second, CAPE Phase 3 (expected late July 2026) is slated to cover finally liquidated entries, though its scope is contested in the government's Federal Circuit appeal. Tariffi tracks both clocks per entry.

'Unable to calculate duty' is among the most common CAPE rejection codes. It means CBP's systems could not compute the refund for that entry from its own records — typically because of complex duty structures, a pending Post-Summary Correction, or data that does not match CBP's records. It is usually correctable: fix the underlying issue and refile.

No — effective July 7, 2026 (CSMS #69127837), CBP rejects warehouse entry types 21 and 22 from CAPE with an 'ENTRY TYPE NOT ALLOWED' error. The IEEPA duty is still refundable, but the declaration must cite the withdrawal entries (types 31, 32, 34, or 38), where the duty was actually assessed and paid.

Almost always a stale Form 4811 notify-party designation: if your broker (or a former agent) was ever designated to receive refunds in ACE, CBP routes payments there until it is revoked. Ask your broker to forward the funds, then revoke the stale designation through your CBP Center of Excellence and Expertise. Tariffi never uses a notify-party — your refund goes to your own account.

Usually it is not a shortfall — it is how CBP pays. Refunds arrive in partial tranches as entries liquidate on different dates, and CBP consolidates payments into lump sums grouped by importer of record and liquidation date, so one deposit rarely maps to one entry. Duplicate REV-603 notices can also make totals look off. Reconcile per entry before assuming money is missing.

Five checks: legitimate recovery services never charge advance fees (16 CFR § 310.4(a)(2) makes it illegal); CBP never charges you to release a refund; real refunds arrive only by ACH to the importer of record's own verified bank account; attorneys cannot file CAPE Declarations (CBP FAQ) — only the IOR or the licensed broker who filed the entries can; and any broker's license can be verified with CBP.

A named Tariffi underwriter owns your portfolio kickoff: eligibility scan across all your Filer Codes, recovery-probability heatmap per entry vintage, and a single readout before any filing goes to broker review. Underwriter-led is for importers with multi-broker portfolios where standard self-serve intake would miss cross-broker edge cases.

Yes. Tariffi's partnership architecture is broker-agnostic — we route each entry's preparation to the licensed broker who already has the ABI Filer Code for that entry. No broker-switch disruption. If a broker we have not partnered with yet owns some of your filings, we onboard them on your timeline.

Yes. Tariffi provides a diligence pack on request that includes broker-partnership regulatory evidence (19 CFR Part 111, CBP Rulings HQ H326926 and H350722), a FASB ASC 450-30 contingent-recovery memo template, and the full engagement-letter redline — all under NDA.

Enterprise importers ($5M+ duty paid) receive custom-priced contingency below the standard 10/15/18% tiers, a co-advisory engagement structure that accommodates existing tax or trade counsel, and a dedicated underwriter. Volume-based fee negotiation starts at the first conversation. Contact enterprise@tariffi.io.

Tariffi provides a complete diligence package under NDA: broker-partnership regulatory evidence (19 CFR Part 111, CBP Rulings HQ H326926 and H350722), FASB ASC 450-30 contingent-recovery memo template, engagement letter redline, security posture documentation (AES-256, TLS 1.2+, 7-year retention), and reference contacts from comparable engagements.

Yes. Tariffi's enterprise engagement structure accommodates co-advisory arrangements where your existing Big 4 tax or trade team owns the workpaper review. A licensed customs broker partner transmits to CBP under their own license per 19 CFR Part 111. The engagement letter accommodates a side arrangement with your advisor.

Related-party imports under IRC section 482 have additional customs valuation considerations that affect CAPE eligibility. Tariffi's analysis engine flags related-party entries for special handling, and the licensed broker partner applies enhanced review. Enterprise engagements include coordination with your transfer-pricing advisors if needed.

AES-256 encryption at rest, TLS 1.2+ in transit, role-scoped database access with audit logging, 7-year data retention per 19 CFR Part 163, and broker tenant isolation at the database layer. Under NDA we share penetration-test summaries and subprocessor attestations. Additional certifications disclosed as they become available.

Tariffi prepares CAPE declaration data from importers' ES-003 files and routes it to your broker portal for review. You remain Filer of Record on every filing under your own ABI filer code. Tariffi never touches CBP servers. You earn a flat per-filing filer integration fee per 19 CFR § 111.36(b) — never a percentage.

No. Tariffi is a data-preparation platform — we never access CBP servers or file anything under your license. You review every CAPE declaration in your broker portal, approve it with your professional judgment, and transmit it via your own ABI filer code through ACE. You are always the Filer of Record.

Brokers receive a flat per-entry filer integration fee per 19 CFR § 111.36(b). Tariffi pays the fee from its own funds — the importer owes the broker nothing — and payment is contingent on the refund being recovered. It is never a percentage of the importer's refund, never a referral bounty, and never a revenue share.

No. Tariffi's architecture is designed specifically to protect your license. You remain Filer of Record, apply all professional judgment, and transmit via your own ABI filer code. Compensation is a flat per-filing fee per 19 CFR § 111.36(b) — no percentage splits that would trigger § 111.36(b) scrutiny. Our structure follows CBP Ruling HQ H326926.

Each broker partner has an isolated tenant — you see only CAPE filings assigned to your Filer Code. Tenant isolation is enforced at the database layer with role-scoped access and audit logging. No cross-broker visibility, no aggregated client lists, and the partnership agreement bars Tariffi from soliciting your clients for customs brokerage services.

The Filer of Record is the CBP-licensed customs broker whose name, license number, and ABI filer code appear on a CAPE declaration or protest filed with CBP. The Filer of Record bears professional responsibility for the filing under 19 CFR Part 111. At Tariffi, the broker partner is always the Filer of Record — we prepare data but never file.

Potentially, yes — through merchant-run distribution programs. When importers and retailers recover tariff overpayments, they can partner with Tariffi to pass a share of those savings to consumers who purchased affected products. Distributions launch merchant by merchant as refunds arrive: participating merchants notify their eligible customers directly, so watch for emails from brands you shop with.

IEEPA and Section 301 tariffs added 7.5% to 25% to the cost of affected imported goods, primarily from China. On a $100 purchase, that means $7.50 to $25 in embedded tariff costs passed through as higher retail prices. Your actual exposure depends on what you bought, when, and from which retailers.

For consumers: there is nothing to file today. Consumer distributions are merchant-initiated — participating retailers identify eligible customers from their own purchase records and notify them directly as programs launch, so watch for emails from brands you shop with. For businesses: if you are a U.S. importer of record, upload your ES-003 at tariffi.io/intake/start for a free eligibility analysis.

Tariff passthrough is when importers pass the cost of tariffs through to downstream buyers via higher wholesale and retail prices. Studies show that Section 301 and IEEPA tariffs are largely passed through to U.S. consumers, meaning the economic burden falls on end purchasers, not the foreign exporters the tariffs target.

Tariffi's consumer refund distribution is a voluntary program, not litigation. Participating retailers and importers opt in to distribute refunds as their programs launch. There are no legal fees, no court proceedings, no settlement timelines, and no attorney contingency. Once a merchant's program is live and you claim, payouts typically arrive within days — not years.

A small liquidity retention fee of 7.5% is applied to consumer refund distributions when a participating merchant's program pays out. This covers the costs of matching purchases to tariff-affected products, processing refund payments, and maintaining the consumer distribution platform. There are no upfront fees, and the fee is deducted automatically from your refund amount.

Section 301 tariffs primarily affect goods imported from China across four lists covering thousands of product categories: electronics, machinery, textiles, furniture, auto parts, toys, chemicals, and more. IEEPA tariffs can target goods from any country under an emergency declaration. Specific product coverage depends on the HTS codes in each tariff action.

When a participating merchant's distribution program pays out, consumer refunds are delivered via ACH direct deposit, digital wallet (Venmo, PayPal, etc.), or prepaid virtual card — depending on your preference and the merchant's distribution channel. Once you claim, payouts typically arrive within a few business days. There are no paper checks and no waiting for a court settlement.

Five checks: legitimate recovery services never charge advance fees (16 CFR § 310.4(a)(2) makes it illegal); CBP never charges you to release a refund; real refunds arrive only by ACH to the importer of record's own verified bank account; attorneys cannot file CAPE Declarations (CBP FAQ) — only the IOR or the licensed broker who filed the entries can; and any broker's license can be verified with CBP.