How Tariffi works with your broker.

Think of Tariffi like a duty-drawback specialist — focused on historical refund recovery, never daily freight clearance — but for IEEPA CAPE refunds under the Supreme Court ruling and CBP’s CAPE rulemaking, not 19 USC § 1313 drawback.

We handle:

• Importer onboarding (corporate-email verification), PII encryption, 7-year retention per 19 CFR Part 163.
• ACE ES-003 CSV ingestion (the universal CBP-sanctioned ingestion format — no PDFs, no broker-specific formats).
• HTS validation at the 6-digit HS heading/subheading level (consistent with CBP Ruling HQ H350722, which caps AI classification at 6 digits and reserves the 10-digit statistical-suffix call for the licensed broker).
• Unit Entered Value computation via USITC HTS REST + Census Bureau International Trade API (Sprint L7).
• CAPE declaration formatting, 9,999-entry chunking, broker-review artifact generation, audit-log trail.

• We do not hold a CBP broker license. Unlike Comstock & Holt or Charter Brokerage (who file drawback under their own licenses), every CAPE filing Tariffi touches is transmitted by your firm’s filer code. This division — platform prepares data, licensed broker stays Filer of Record — is the exact arrangement CBP blessed in Ruling HQ H326926 (December 2023).
• We do not touch ABI. No automated CBP transmission. You log into your own ACE portal and upload the CSV — Tariffi never pushes anything to CBP.
• We do not make 10-digit HTSUS determinations. Per CBP Ruling HQ H350722, final statistical-suffix calls are the licensed broker’s responsibility; our platform refuses to render guidance past 6 digits.
• We do not solicit your importer clients for daily entry work. Every broker partnership is governed by a non-solicit covering referred importers. If a referred importer wants to consolidate daily brokerage with us, we decline and refer them back to you.
• We do not file drawback claims. 19 USC § 1313 drawback is a different statutory regime Tariffi is purpose-built for IEEPA refunds only.
• We do not represent importers before CBP. All importer representation is the licensed broker partner’s role under 19 CFR Part 111.

Two distinct commercial relationships run in parallel under 19 CFR § 111.36(c):

1. Importer ↔ Tariffi: tiered contingency on the recovered refund (10% / 15% / 25% by liquidation status) per 16 CFR § 310.3(a)(1). Disclosed before signing. Zero advance fees per 16 CFR § 310.4(a)(2).
2. Importer ↔ broker partner: flat per-filing data-service fee under 19 CFR § 111.36(c), owed by the importer to the broker. Never a percentage of the refund. Never a referral bounty. Never a revenue share on customs-business income.

As a promotional platform benefit, Tariffi is authorized by the importer to remit the broker’s fee on the importer’s behalf — so the importer writes a single payment to Tariffi, but the legal fee obligation flows directly importer-to-broker (19 CFR § 111.36(c)). This also keeps us inside 19 CFR § 111.36(b), which prohibits broker fees from “inuring to the benefit of” unlicensed parties through indirect percentage-share arrangements. Your fee stream is independent of every importer’s refund size.

Exact figures (per-filing fee, optional advance-referral flat fee) are set in the signed partnership agreement with a mutual non-disclosure.

Every broker partnership agreement includes a non-solicit clause covering importer clients you refer to Tariffi. For the duration of the agreement and 12 months after, Tariffi will not:

• Offer daily customs entry services, freight forwarding, or drawback filings to your referred importers.
• Accept an inbound request from a referred importer to consolidate their daily brokerage with Tariffi — we decline and refer them back to you.
• Share any referred importer’s client data with other broker partners (tenant isolation is enforced at the database layer with role-scoped access).

The clause is mutual, plain-English, and designed to clear a broker compliance officer’s desk without revision. We expect every partnership to begin there.