The Role of the Importer of Record Number in IEEPA Tariff Refund Claims

When the U.S. Supreme Court ruled IEEPA tariffs unconstitutional in February 2026, it opened a narrow but significant window for U.S. importers to recover duties paid on billions of dollars worth of goods. Refund deadlines are firm: February 4, 2027 for fentanyl-related tariffs applied to China, Mexico, and Canada, and April 5, 2027 for reciprocal tariffs applied to other countries. With CBP having processed roughly $121.75 billion in claims so far, the opportunity is real. Yet about 93.5 percent of eligible importers have still not filed.

One of the most overlooked barriers to filing is confusion about the importer of record number. Many companies assume that because they paid for the goods, they are automatically entitled to a refund. The process does not work that way. CBP ties every entry to a specific importer of record number, and only the party associated with that number on the original entry can claim the refund.

What Is an Importer of Record Number?

CBP assigns each importer a unique importer of record number, sometimes called an IOR number. This number is derived from either the company's IRS Employer Identification Number or, for individuals, a Social Security Number. Foreign entities that import into the United States but lack a domestic tax ID are assigned a CBP-assigned number.

Every formal entry filed with CBP through the ACE portal is associated with one IOR number. That number appears on the entry summary, commonly referred to as CBP Form 7501. When CBP processes a refund claim through the CAPE portal, it cross-references the IOR number on the original entry against the entity filing the claim. If those numbers do not match, the claim will not be approved.

Why Mismatches Are More Common Than Importers Expect

IOR number mismatches happen for several common reasons. Business restructurings, mergers, entity conversions, and name changes can all result in a situation where the company currently operating is not the same legal entity that was listed as the importer of record on entries filed years ago. Similarly, if a parent company and a subsidiary both import, their entries may be filed under different IOR numbers even when the goods ultimately land in the same warehouse.

Some importers also discover that their customs broker filed entries under the broker's own bond and a slightly different identifier. Understanding exactly whose number appears on each entry is a critical first step before attempting to file any IEEPA tariff refund claim.

How to Locate Your IOR Number in ACE

The ACE portal maintained by CBP is the authoritative source for your import history. Once you log in, you can pull entry summary data filtered by date range, HTS code, and port of entry. Each record in that data set will display the importer of record number that was used when the entry was filed. This is the number you need to reconcile against your current entity information before filing through the CAPE portal.

If your company has gone through a name change, look carefully at whether CBP's records reflect the pre-change name or the post-change name. In many cases, CBP Form 5106, which is used to establish or update importer identity with CBP, must be updated before a refund claim can proceed cleanly.

The Relationship Between the IOR Number and Entry Summaries

Each entry summary documents the duties paid on a specific shipment. It captures the HTS classification, the tariff rate applied, the value of the merchandise, and the calculated duty amount. For IEEPA tariff refund purposes, the entry summary is the foundational document proving that the duties were paid in the first place.

When your IOR number is consistent across your entry summaries, aggregating your refund claim across hundreds or even thousands of shipments becomes a structured data exercise. When the numbers are inconsistent, each discrepancy must be investigated individually. This is one reason why importers who operated under multiple entities during the relevant tariff period often face a more complex claim process.

IOR Numbers, Customs Bonds, and Who Legally Paid the Duty

Customs duties are secured by a customs bond, either a single-transaction bond or a continuous bond. The party obligated under that bond is generally the importer of record. If your company was the importer of record and the bond was in your name, the legal obligation to pay the duties rested with you. That means the right to recover those duties as a refund also rests with you, not with the seller overseas, not with the freight forwarder, and not with the end customer who ultimately purchased the goods.

This is a point that creates real confusion in supply chains where the foreign supplier nominally handles customs clearance or where the domestic buyer reimburses the broker directly. The question CBP asks is simple: whose IOR number is on the entry? The answer determines who files the claim.

Section 301 vs. IEEPA: Does the IOR Number Rule Apply to Both?

Yes. Whether you are pursuing a refund on IEEPA tariffs through the CAPE portal or reviewing older Section 301 exclusion-based refunds, the importer of record identity requirement is consistent. CBP's systems are built around the IOR number as the primary key that ties entry data to a legal entity. Any import duty refund recovery process, regardless of the underlying tariff authority, requires the filing party to demonstrate that it was the importer of record on the relevant entries.

This is worth noting for companies that have both Section 301 overpayments and IEEPA tariff overpayments in their history. Running a clean IOR audit once allows you to prepare for both potential recovery streams simultaneously.

Practical Steps Before You File

• Log into the ACE portal and pull your entry summary data for all entries filed during the relevant IEEPA tariff period.
• Confirm that the IOR number on each entry matches your current legal entity's EIN or CBP-assigned number.
• Review CBP Form 5106 to ensure your importer identity record is current and reflects any business name changes or restructurings.
• Identify any entries filed under a subsidiary, predecessor entity, or related company and determine whether those entities can still file claims independently.
• Ensure your ACH enrollment with CBP is active and tied to the correct bank account so that approved refunds can be deposited electronically without delay.

Statutory Interest Makes Filing Sooner More Valuable

Approved IEEPA tariff refund claims are paid with statutory interest. The interest accrues from the date the duties were originally paid, which means earlier entries carry more accumulated interest than later ones. Resolving IOR number discrepancies quickly and filing as soon as your documentation is clean will maximize the total amount recovered. Waiting until the weeks before the February or April 2027 deadline compresses the time available to correct any data issues CBP may identify after your initial submission.

How Tarisol Can Help You Move Forward

Tarisol connects U.S. importers with the Tariff Refund Agency, a licensed specialist that files IEEPA tariff refund claims through CBP's CAPE portal on a success-based fee structure with no upfront cost. The first step is confirming that your IOR number, entry history, and entity documentation align correctly before a single claim is submitted. That groundwork is exactly where most importers need support, and it is where the process begins.

If you are not certain which entries were filed under your IOR number, whether your current entity matches CBP's records, or how much you may be eligible to recover, check your eligibility with Tarisol today. The refund window is open, the deadlines are fixed, and the cost of waiting is measured in dollars that could otherwise be returned to your business.