Multi-Entry Refund Strategy: How to Recover Duties Across Hundreds of Shipments

Most conversations about IEEPA tariff refunds focus on whether you qualify. But for importers who have been shipping goods regularly from China, Mexico, Canada, or other affected countries, the more pressing question is not eligibility. It is scale. When you have shipped dozens, hundreds, or even thousands of entries over the covered period, organizing a refund claim is its own operational challenge. This guide walks you through a practical strategy for recovering duties across high-volume import activity before the filing deadlines close.

Why Volume Creates Both Opportunity and Complexity

The U.S. Supreme Court ruled IEEPA tariffs unconstitutional in February 2026. That ruling opened the door for importers to recover duties paid under those tariff orders, with refunds processed through CBP's CAPE portal and paid via ACH within roughly 60 to 90 days including statutory interest.

For a company that imported 10 times over the covered period, the claim process is relatively straightforward. For a company that imported 500 times, the process involves aggregating hundreds of entry summaries, verifying classification codes across all of them, confirming country of origin documentation for each shipment, and ensuring that the correct duty amounts are captured in every line. That is not a paperwork inconvenience. It is a substantive compliance task.

The good news is that high-volume importers tend to have the highest total refund exposure. The structure of the IEEPA tariff rates, which stacked on top of base rates and sometimes on top of existing Section 301 duties, means that each individual entry carried meaningful duty liability. Multiply that across hundreds of shipments, and the aggregate recovery potential is significant.

Step One: Pull Your Full Entry History from ACE

Your starting point is the Automated Commercial Environment portal, known as ACE. If you have an ACE account established and linked to your Importer of Record number, you can run reports that show every entry summary filed under your account within a specified date range.

For IEEPA refund purposes, the relevant date ranges depend on which tariff category applies to your goods. Fentanyl-related tariffs on China, Mexico, and Canada have a refund filing deadline of February 4, 2027. Reciprocal tariffs on other countries carry a deadline of April 5, 2027. Pull your entry data with enough lead time before those deadlines to complete the review and filing process without rushing.

Once you have your entry list, export it to a spreadsheet. At minimum, you want to capture the entry number, entry date, port of entry, country of origin, HTS classification codes used, total duties paid, and the specific IEEPA tariff chapter or order that was assessed. That last column is what connects each entry to a refund-eligible tariff.

Step Two: Segment Your Entries by Tariff Category

Not every entry in your history will be refund-eligible. IEEPA tariff refunds apply to specific duty orders tied to specific countries and product categories. Some of your shipments may have originated from countries not covered by the ruling. Others may have been assessed under Section 301, antidumping duties, or other tariff mechanisms that are subject to separate rules and processes.

Segmenting your entries into clear categories serves two purposes. First, it prevents you from spending time preparing claims on non-refundable entries. Second, it helps you prioritize by deadline. If you have entries in both the February 2027 and April 2027 windows, you need to work the earlier deadline first.

For each eligible segment, confirm that the HTS codes used on the original entry summaries were accurate. Misclassification is one of the most common reasons a refund claim is delayed or disputed. If you have reason to believe a classification was incorrect, that needs to be addressed before the claim is filed, potentially through a post-summary correction.

Step Three: Gather Supporting Documentation at Scale

A high-volume claim requires the same types of documentation as a single-entry claim. The difference is that you need to have it organized and retrievable across every entry in your claim set. The core documents are entry summaries, commercial invoices, packing lists, bills of lading, and country of origin certificates or declarations.

Country of origin documentation deserves particular attention. CBP requires that refund claims be supported by evidence that the goods actually originated in the tariff-covered country. For importers sourcing from multiple countries or from suppliers who manufacture across multiple locations, origin documentation can be inconsistent or incomplete in the historical record. Gaps in this documentation create gaps in the refund claim.

Build a document checklist for each entry or entry group and work through it systematically. If you used a customs broker for original filings, your broker's records are a valuable source for any documents you cannot locate internally.

Step Four: Calculate Your Recovery Estimate by Entry Group

Before you file, it is worth understanding what each segment of your claim is likely to recover. This is not just about knowing your total refund exposure. It is about allocating your time and resources appropriately across the claim preparation effort.

For each entry group, add up the IEEPA duties paid. Then factor in statutory interest, which accrues from the date of original payment. The interest component is often overlooked but adds meaningful value to claims that cover duties paid in 2018, 2019, or 2020. Claims covering duties paid further back carry more interest simply because more time has passed.

A recovery estimate also helps you make decisions about prioritization. If one segment of your claim covers a small number of high-value entries and another covers a large number of low-value entries, the documentation burden of the second group may warrant a different approach than the first.

Step Five: File Through the CAPE Portal or Work With a Specialist

CBP's CAPE portal is the official filing channel for IEEPA tariff refund claims. For importers with a handful of entries, direct filing through the portal is manageable. For importers with hundreds of entries, the volume of individual submissions creates substantial administrative burden.

This is one reason many high-volume importers work with a licensed tariff refund specialist rather than attempting to file independently. A specialist with experience processing large claim sets can aggregate entries efficiently, apply consistent documentation standards across the claim, and catch classification or origin issues before they create problems at CBP. The Tariff Refund Agency, which Tarisol partners with, operates on a success-based fee model, meaning there is no upfront cost to the importer. Fees are paid only from recovered amounts.

For importers who are uncertain whether the effort of a large-scale claim is worth pursuing, the answer almost always depends on one number: the total IEEPA duties paid across the covered period. CBP has processed approximately $121.75 billion in claims so far, but roughly 93.5% of eligible importers have not yet filed. The unclaimed portion represents a significant and time-limited recovery opportunity.

Do Not Let Complexity Become the Reason You Miss the Deadline

High-volume importers sometimes delay filing because the scope of the work feels large. That is understandable. But the filing deadlines are fixed, and once they pass, the refund opportunity for entries in those windows is permanently closed. The complexity of a multi-entry claim is a reason to start earlier, not a reason to defer.

If you have been importing regularly from any of the IEEPA-covered countries and have not yet reviewed your refund exposure, the time to act is now. The more entries you have in scope, the more time the preparation process requires, and the deadlines in early 2027 are closer than they appear.

Check Your Eligibility With Tarisol

Tarisol connects U.S. importers with the Tariff Refund Agency, a licensed specialist that files IEEPA tariff refund claims through CBP's CAPE portal. There is no upfront cost. Fees are success-based, paid only from amounts recovered. If you have multiple entries that may qualify, a review of your ACE data can quickly identify your recovery potential.

Reach out to Tarisol today to check your eligibility and get a clear picture of what your import duty refund opportunity looks like across your full shipment history.