Recovery Execution

Tariff Identification

The identification of IEEPA tariffs is a forensic exercise. It requires an exact review of customs-entry data, Chapter 99 reporting, applicable country measures, product-specific modifications, and the interaction between IEEPA duties and other tariff regimes.

For importers, consignees, customs brokers, and manufacturers, the first practical recovery issue is fundamental: which IEEPA tariffs were actually paid, on which entries, in what amounts, and during what periods?

That inquiry requires absolute precision. The relevant tariffs were imposed through multiple executive actions, at different times, and at different rates depending on country, timing, and product scope. Those duties were frequently reported alongside ordinary customs duties and other Chapter 99 measures on the exact same entry lines.

As a result, tariff identification dictates a structured reconstruction of the customs record rather than a simple review of a single duty rate.

Statutory Framework

What IEEPA tariffs are

IEEPA tariffs were additional duties imposed pursuant to executive actions invoking the International Emergency Economic Powers Act. Those measures included several principal categories.

China

Additional 10% tariff beginning February 1, 2025
Increased to 20% beginning March 3, 2025
Reciprocal-China tariffs later increased to 125% and then 145% during April 2025
Reciprocal-China component reduced to 10% on May 12, 2025
Separate China tariff later reduced from 20% to 10% on November 4, 2025

Global / Most Countries

General 10% reciprocal tariff beginning April 2, 2025
Higher country-specific reciprocal rates imposed simultaneously on numerous countries
Higher country-specific rates paused for most countries on April 9, 2025; general 10% rate remained
Country-specific reciprocal rates reinstated July 31, 2025 (minimum 10% rate)

Targeted Jurisdictions

Brazil: Additional 40% tariff beginning July 30, 2025
Canada: Additional 25% tariff beginning July 31, 2025
India: Additional 25% tariff beginning August 6, 2025 (tied to Russian oil)

Product-Specific Modifications

Semiconductor-related exceptions identified in April 2025
Certain agricultural products later addressed through scope modification

Note: The materials reviewed do not include a complete country-by-country reciprocal-rate annex. This page serves as a practical overview of the principal categories and identification issues, rather than an exhaustive global schedule.

Data Architecture

How IEEPA tariffs appear in the customs record

Line-Level Reporting

IEEPA tariffs are identified strictly through the customs-entry record, including Entry Summary data reflected in Form 7501, ACE exports, and broker-generated reporting.

Duties are reported at the Entry Summary line level. Each line reflects merchandise from a particular country, together with the entered value, the ordinary HTSUS classification, and any applicable additional tariff provisions. Importers also report Chapter 99 provisions for additional duties, including IEEPA measures, Section 232 duties, Section 301 duties, Section 201 duties, exclusions, and AD/CVD-related obligations.

Tariff identification begins with a rigorous review of:

ACE data exports
Entry Summary / Form 7501 data
Customs broker reports and spreadsheets
Line-level CBP data
Liquidation and reliquidation history
Deposit and payment records

Stacking and Non-Stacking Considerations

A central issue in tariff identification is determining the extent to which IEEPA duties were stacked with other applicable duties.

IEEPA duties were frequently imposed in addition to the ordinary duty rate and in addition to other Chapter 99 measures already applicable to the same merchandise. A single entry line inherently reflects:

Ordinary Chapter 1–97 duty;
IEEPA duty;
Section 232, Section 301, or Section 201 duty; and
AD/CVD-related obligations, where applicable.

Non-stacking issues arise where product exceptions, country-specific modifications, or subsequent executive actions altered which duties applied during a given period. The identical product category reflects different effective IEEPA treatment depending on:

Country of origin;
Date of entry;
Product scope;
Whether a country-specific reciprocal rate was paused, reduced, reinstated, or replaced; and
Whether another trade measure already applied to the merchandise.

China-related entries illustrate this complexity entirely. At various points during 2025, Chinese merchandise implicated both a separate China-related IEEPA tariff and a reciprocal-China tariff, while product-specific exceptions altered the effective rate.

Calculated Discrepancies

Where IEEPA tariffs deviate

IEEPA tariffs deviate materially depending on exact statutory factors.

Country of Origin

Country-specific measures trigger materially different tariff treatment. China, Brazil, Canada, and India command rates substantially different from the general 10% baseline.

Date of Entry

Applicable tariff treatment pivots exactly on when the entry was made. Various IEEPA measures were imposed, increased, paused, reduced, reinstated, or modified precisely by date.

Product Scope

Specific products were excepted or treated differently. Semiconductor exceptions and agricultural modifications dictate whether IEEPA duties applied to the entry.

Tariff Interactions

IEEPA duties appear alongside Section 232, 301, 201, or AD/CVD obligations. Mapping that interaction is mandatory to determine the refundable amount.

Execution Model

How we identify IEEPA tariffs

The IEEPA Managed Recovery Program executes tariff identification through a structured, forensic customs-data review.

That process begins with the complete reconciliation of the available customs record. We review line-level data to identify relevant Chapter 99 reporting, test country-of-origin and timing assumptions, and reconstruct the duty profile across the exact entry population. That work dictates:

Step 01

Mapping relevant time periods by country and executive action

Step 02

Identifying entry lines that include relevant Chapter 99 treatment

Step 03

Distinguishing IEEPA duties from other additional duties

Step 04

Evaluating whether product-specific exceptions or scope changes apply

Step 05

Identifying entries reported ambiguously or inconsistently

Step 06

Tracking liquidation dates and refund posture

Step 07

Organizing the file for ACE-based refund declarations and validation

The Forensic Hurdle

Why tariff identification is a forensic problem

The customs record is not cleanly organized to permit immediate identification of the IEEPA component.

Importers do not always separate duties with precision. Isolating the IEEPA component mandates line-level analysis, manual calculations, and reconstruction of the duty picture. A single importer has a large population of affected entries, each containing numerous lines and overlapping duty treatments. A business knows it paid IEEPA tariffs, but lacks a reliable answer to critical questions:

which entries exactly qualify;
what exact IEEPA amount was paid;
whether interest is involved;
whether liquidation or reliquidation timing legally affects the recovery path; and
whether the full recovery opportunity has been captured.

Why this work matters

A recovery opportunity is materially diminished if tariff identification is incomplete or inaccurate.

If affected entries are not fully captured, if the wrong Chapter 99 treatment is assumed, if product exceptions are overlooked, or if IEEPA duties are not properly distinguished, the result is a reduced refund, a delayed refund, or an avoidable legal dispute regarding the amount recoverable.

Clients engage this platform not to confirm tariffs were paid, but to execute the difficult work of identifying, validating, and documenting the recoverable IEEPA component to support the refund process definitively.

Take Action

If your business paid IEEPA tariffs, the first step is determining precisely what was paid and where it appears.

The IEEPA Managed Recovery Program is designed to help importers, consignees, customs brokers, manufacturers, and distributors identify affected entries, isolate IEEPA duties, evaluate timing and scope issues, and prepare a supportable refund-ready file.

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