Client Profile

Built for consignees that bore the tariff burden but do not control the customs entry.

The IEEPA Managed Recovery Program is designed for downstream businesses that funded or absorbed the economic cost of challenged tariffs. We help solve the practical problem of turning that economic burden into a documented, supportable recovery path.

Consignees often face a simple commercial problem with a complicated administrative solution.

They may have paid the tariff burden in substance, while the customs entry, broker file, and refund pathway sit elsewhere.

We help consignees work with Importers of Record and customs brokers, identify affected duties and amounts, track liquidation timing, assemble a supportable record, and position themselves to recover principal and applicable interest.

The Operational Reality

A recovery problem is usually a record-and-control problem.

For many consignees, the central difficulty is not whether tariff cost was borne. It is proving it, tracing it, and getting paid. The consignee may have absorbed the burden through landed-cost pricing, reimbursements, or post-entry adjustments, even though the Importer of Record made the customs entry.

That leaves the consignee in a commercially difficult position. The money may be tied to customs records it does not control, and the recovery process may be run by another party.

The consignee’s practical challenge is assembling the record, tracing the duties, calculating the amounts, and ensuring recovery is pursued and distributed in a way that reflects the actual burden borne.

Platform Capabilities

How we organize the recovery path

From economic burden to documented recovery

For consignees, the central task is translating economic reality into a supportable recovery record. A consignee cannot effectively pursue recovery without knowing what amount is actually at issue.

That requires connecting customs data to invoices, payment records, landed-cost calculations, or other commercial documentation showing that the consignee funded the tariff burden. It also requires isolating the challenged duties from standard charges.

We help make that translation. We assemble the record, calculate the relevant amounts, and turn a commercially understood burden into a disciplined recovery file.

Working with Importers and Brokers

Recovery often depends on effective coordination with the parties that control the customs-facing record. That may include the Importer of Record who sits at the center of the refund process, and the customs brokers that hold the historical entry data.

In many cases, the consignee’s ability to recover depends on obtaining the right information from those parties and presenting it as a coherent demand.

We help coordinate with upstream parties to gather relevant data, identify affected entries, and position the consignee’s claim in a way that is more likely to be documented, understood, and acted upon.

Risk Profiles

The problems consignees are usually trying to solve

Consignees typically engage the program because they need an organized way to move from economic exposure to recoverable dollars. They are often facing one or more of the following problems:

they believe they absorbed the tariff burden, but do not control the customs entry;
the relevant customs records are held by the Importer of Record or one or more brokers;
they do not know which entries were affected or the exact duties at issue;
they need help identifying tariff amounts and connecting them to specific transactions;
they need to track liquidation dates and related timing considerations;
they want to understand whether interest may be recoverable;
they need a structured way to present a documented claim or allocation position;
they want visibility into whether recovery is being pursued; or
they need a supportable file in case the matter later becomes disputed.

Payment visibility and downstream recovery

Even where the consignee has a strong claim, a separate problem remains: visibility into how and when payment will actually be made.

In some cases, recovery may move through the Importer of Record or another upstream party before any downstream disbursement occurs. Consignees need confidence that the recovery process is moving, that relevant amounts are being monitored, and that their position is documented.

The Managed Recovery Program provides that structure, helping consignees track the recovery path and understand where the matter stands at each stage.

Supportable administration and audit-ready records

A consignee’s recovery should not depend on informal spreadsheets, scattered emails, or loosely assembled assumptions. It should be grounded in a supportable record.

We emphasize disciplined documentation and audit-ready administration. We maintain organized support for the claimed tariff burden, the entry-level analysis, and the relevant timing record.

That can matter not only for the recovery itself, but also for later disputes, internal accounting questions, or any subsequent review of the basis for payment.

Take Action

If you bore the tariff burden, you should not be left without a path to recovery.

If your business acted as consignee or otherwise absorbed the cost of challenged IEEPA tariffs, let our platform help you assemble the record, coordinate with upstream parties, and track the path to payment.

Request a Consignee Assessment Speak with Our Team