Recover Duties Imposed Under
the 2025 IEEPA Orders

How AssetBull Helps You Recover IEEPA Duties

AssetBull’s Managed Recovery program is built to help importers prepare now and move quickly once a viable refund pathway is established. We work with your team and customs brokers to identify affected entries, organize the underlying documentation, and build a deadline-aware recovery plan aligned with CBP procedures — including liquidation timelines and rights-preservation steps.

Our affiliated legal partners prepare and file the necessary CBP protest forms and manage each matter through resolution — coordinating with brokers, tracking status, responding to CBP requests, and driving recovery to completion — so your organization converts uncertainty into an organized, auditable tariff refund process.

Scope of Services

• Entity & Standing Verification — Identification of importing entities and validation of legal standing to protest duties before filing.
• Forensic Record Assembly — Systematic aggregation of CBP entry data, commercial invoices, packing lists, and proof of payment.
• Merits & Eligibility Screening — Rigorous evaluation of entry data to determine protestability against statutory deadlines.
• Recovery Quantification — Precise calculation of recoverable duties, fees, and interest suitable for financial forecasting.
• Protest Preparation — Drafting of CBP Form 19 protests, Requests for Further Review, and supporting legal memoranda.
• Submission Management — Secure filing via ACE (e-Protest) with full documentation retention and submission evidence.
• Administrative Defense — End-to-end management of CBP interactions, including RFI responses and procedural advocacy.
• Performance Accountability — Contingency structure aligns our success directly with yours.

The 2025 IEEPA Tariff Regime

In 2025, the Executive Branch invoked the International Emergency Economic Powers Act (IEEPA) to impose significant additional duties on imports. These measures include targeted tariffs on goods from Canada, Mexico, and China linked to border security rationales, as well as broadly applied “reciprocal” baseline duties affecting imports from numerous trading partners.

These measures have materially increased landed costs for U.S. importers and are now the subject of major litigation challenging whether IEEPA authorizes tariffs of this scope. Because duties are governed by strict customs procedures — specifically liquidation timelines — businesses must evaluate refund-preservation steps early, even while appellate review continues.

Who Qualifies for Tariff Recovery?

AssetBull supports a diverse range of market participants affected by 2025 IEEPA duties. Our compliance engine handles the data complexities inherent in each model.

We Help Across the Full Import Ecosystem

• Importers of Record — Comprehensive end-to-end support from eligibility analysis through refund resolution, coordinating directly with your customs broker.
• IORs Acting for Downstream Customers — We prepare Form 19 protests, serve as third-party administrator for refund allocation, and coordinate compliant disbursements to downstream beneficiaries.
• Customs Brokers — Centralized, scalable IEEPA recovery programs for your importer clients. You stay focused on brokerage; we handle legal strategy and filing.
• Importers Unsure of Their Status — We analyze entry documentation, identify the correct protest party, and structure the appropriate recovery pathway.

Rates, Countries & Effective Dates

IEEPA measures were implemented in phases, creating a complex matrix of applicable duties. The table below is illustrative — specific rates and dates should be confirmed against current CBP operational guidance.

Illustrative Affected Goods

• Industrial: Machinery, auto parts, steel and aluminum derivatives
• Consumer: Electronics, apparel, household goods
• Energy: Refined petroleum products, solar components
• Retail / E-Commerce: High-volume “de minimis” shipments subject to aggregation rules

How to File a Tariff Protest & Preserve Rights

Refunds are not automatic. They generally require affirmative steps by the importer to protest duty assessments before liquidation becomes final.

The Liquidation Clock

Liquidation is the final computation of duties. It generally occurs months after entry but can be extended. Once liquidated, an importer generally has 180 days to file a Protest (CBP Form 19). If this window is missed, the duty assessment becomes final and unreviewable.

The Recovery Process

1. Intake & Scoping — Submit your inquiry. We establish scope, entry universe, and initial recovery estimate.
2. Data Assembly — Records aggregated from your brokers into a consolidated exposure schedule.
3. Eligibility Analysis — Protest viability assessed; liquidation calendar built; deadline alerts activated.
4. Protest Preparation — CBP Form 19 drafted with exhibits and supporting legal memoranda.
5. Filing via ACE — E-Protest filed with full documentation retention and submission evidence.
6. Active Defense — CBP RFIs managed; administrative posture maintained through resolution.
7. Refund Execution — Reliquidation coordinated; refunds traced to correct entity; interest calculated.

Protest — Not a Post-Summary Correction — Is the Required Pathway

If IEEPA tariffs are ultimately held invalid, the only proper administrative mechanism to obtain a refund is a formal customs protest (CBP Form 19), not a Post Summary Correction (PSC). This distinction is not semantic — it is dispositive of refund rights.

The Ministerial Argument: Administrative Barriers to Recovery

CBP has signaled that its collection of 2025 IEEPA tariffs constitutes a ministerial act — that it merely implemented executive directives without exercising independent discretion. This carries significant implications for the administrative protest process.

The Jurisdictional Challenge

Based on Federal Circuit precedent, CBP may assert that its implementation of the tariffs is not a “protestable decision,” denying protests on jurisdictional grounds without addressing underlying legality and arguing that constitutional determinations reside exclusively with the judiciary.

The Statutory Framework

Despite administrative positioning, 19 U.S.C. § 1514 and § 1515 remain clear: once a protest is properly filed and allowed, any duties collected in excess of what is required by law must be refunded. The key question is whether CBP will recognize tariff invalidity as an administratively resolvable question.

Multi-Track Recovery Strategy

• Automatic refunds for unliquidated entries upon judicial invalidation.
• Administrative recovery via successfully processed Form 19 protests.
• Judicial mandates for reliquidation where CBP maintains a ministerial defense.

Representation & Filing Authority

A refund strategy often turns on whether a timely CBP protest is filed for the applicable entries. Protests must be handled by a party authorized to represent the importer before CBP — typically a licensed customs broker or attorney.

AssetBull coordinates with staff attorneys and an affiliated law firm to officially represent clients in preparing and submitting CBP protests — ensuring every filing is handled within a formal attorney-client framework.

Judicial Strategy: The Costco Litigation & Beyond

On November 28, 2025, Costco Wholesale Corporation filed suit in the U.S. Court of International Trade (CIT), challenging the legality of the IEEPA tariff orders (Costco Wholesale Corp. v. United States).

Case Theory

Plaintiffs argue that IEEPA grants the President authority to regulate international economic transactions during emergencies but does not authorize sweeping tariff regimes absent clear Congressional delegation — a separation-of-powers argument central to the claim for refunds.

How Litigation Supports Recovery

AssetBull coordinates with specialized customs counsel to manage CIT escalation. In many cases, we can file “protective” complaints stayed pending lead test cases — minimizing active legal costs while preserving your place in line for a refund.

Post-Decision Refund Execution

Winning the legal argument is only the first step. Actual recovery requires a disciplined execution phase, often involving thousands of individual entries.

• Reliquidation — Following a favorable ruling or protest approval, CBP reliquidates entries to refund excess duty.
• Interest Calculation — Under 28 U.S.C. § 2644, interest may be payable on refunded duties. We verify calculations against statutory rates.
• Reconciliation — We trace refunds back to specific entries and payment sources, especially complex for clients using multiple brokers or financing.

Deliverables & Why AssetBull

Estimate Your Tariff Refund

Enter your import profile below for a high-level estimate of potentially recoverable duties. Exact amounts depend on entry data, classification, and liquidation status.