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IEEPA Duties

The Three Phases of an IEEPA Refund Claim

Tarisol · August 12, 2026

An IEEPA refund claim is not a single event. It moves through three distinct phases, and knowing them helps you understand what the specialists do and where you fit in. The short version: most of the work is theirs, not yours.

Phase 1: Identify

The first phase is identification. Specialists pull your entry history from ACE and determine which entries carry IEEPA-eligible duties. This is where experience matters, because the recoverable portion has to be separated from duty that is not refundable. You provide access to your data. They do the analysis.

Phase 2: File

The second phase is filing. Using the identified entries, specialists prepare and submit the declaration to CBP. Getting the classification and documentation right at this stage is what determines how much comes back, which is why this is not a do-it-yourself form.

Phase 3: Recover

The third phase is recovery. CBP processes the claim, and approved refunds are returned to you. Timing varies with volume and complexity, but this is where the money moves back to your business.

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What you actually have to do

Your part is small: confirm you were the importer of record, get ACE-ready if you are not already, and give the specialists access to your data. Everything technical is handled for you, on a success-based basis. Begin with a free eligibility check to see whether your entries qualify for the process.