The work that determines whether an importer files cleanly when CBP's CAPE module opens is not glamorous. It is reconciling ACE entry data so that IEEPA duties are cleanly separated from Section 232 and Section 301 duties on every affected entry.
Most importers that paid significant tariffs during the February 2025 to February 2026 window had multiple duty types stacked on the same entries. The Learning Resources v. Trump ruling made IEEPA refundable. It did not change anything about Section 232 or Section 301. The refund filing has to thread that distinction precisely, or CBP will reject the claim and the filing window will close before the importer can correct it.
The trade compliance work to get this right is straightforward. It is also time-bounded.
What the stacking actually looked like
A representative entry from mid-2025 might have included three duty layers on a single shipment.
The base duty rate. The MFN (most favored nation) rate or the preferential rate under a trade agreement like USMCA or KORUS. This rate has nothing to do with IEEPA or the section tariffs and is not refundable under Learning Resources.
The Section 301 layer. The 7.5 to 25 percent additional tariff on goods from China that has been in place since 2018. Section 301 is not affected by Learning Resources. It remains in force.
The IEEPA layer. The additional tariff imposed under the International Emergency Economic Powers Act during the February 2025 to February 2026 window. This is the refundable portion. Rates varied by country of origin and product category, generally in the 10 to 25 percent range.
In some cases there was also a Section 232 component (the steel, aluminum, and certain auto parts duty regime). Section 232 is similarly unaffected by Learning Resources and not refundable.
A single entry could include the base rate plus 301 plus IEEPA, or the base rate plus 232 plus IEEPA, or in some unusual cases all four. The importer of record paid the total at clearance. The refund filing has to identify the IEEPA-attributable portion specifically.
How ACE stores this
ACE, the Automated Commercial Environment, is CBP's electronic system for entry filing and duty reporting. The data needed for the refund filing is in ACE, but it requires a specific pull to get it out in usable form.
The relevant data elements on each entry summary:
Entry number and entry date. The unique identifiers.
Importer of record number. The IRS or CBP-assigned number for the legal party that paid the duty.
HTS code (Harmonized Tariff Schedule). The 10-digit product classification that determines which duty regimes apply.
Country of origin and country of export. The origin determines IEEPA applicability for entries from countries that were subject to the emergency proclamation.
Declared value. The basis for the duty calculation.
Duty type codes. ACE uses specific codes for each duty regime. The IEEPA-related codes are distinct from the Section 232 codes (typically prefixed with 9903.81) and the Section 301 codes (typically 9903.88 series). The codes are what cleanly separates the refundable from the non-refundable.
Duty amount paid per type. The dollar figure CBP collected, broken out by code.
Liquidation date and status. Whether the entry has liquidated, and if so, when, which determines the procedural path for the refund.
The customs broker that filed the original entries has access to all of this. In most cases the broker has the data more cleanly organized than the importer's own records do. The first call in the entry-data work is to the broker.
What "clean separation" requires
Three steps produce a clean refund-ready dataset.
Pull the full ACE history for the affected window. February 1, 2025 through February 19, 2026 is the relevant range. Some importers will want to pull through the end of February for completeness, but the cutoff date for IEEPA applicability is the day of the Learning Resources ruling.
Filter to entries where IEEPA duty codes are present. The codes are specific. An entry without an IEEPA code in the duty breakdown is not eligible for refund regardless of when it was filed. Some entries will have IEEPA codes that produced zero duty (because of exemption claims at filing), and those entries are not part of the refund pool either.
Reconcile the per-code duty amounts against the actual payment records. The entry summary shows what was filed. The payment record shows what was actually remitted to CBP. Discrepancies between the two are not unusual, particularly on consolidated entries or entries with subsequent corrections. The reconciliation has to happen before the filing or the claim will be rejected on data mismatch.
The output of this work is a refund-ready entry list with IEEPA-attributable duty amounts cleanly separated from everything else. That is the dataset that submits to CAPE.
Common reconciliation issues
Three patterns come up most often when trade compliance teams start this work.
Consolidated entries with mixed origins. A single entry may have included goods from multiple countries, only some of which were subject to IEEPA. The line-level detail in ACE allows separation, but the entry-level summary may have aggregated the duty figures in a way that obscures the per-line IEEPA exposure. The fix is to pull line-level data, not just entry-level data.
Corrected entries (PSC, post-summary corrections). Some entries from early 2025 were corrected after initial filing, sometimes multiple times. The IEEPA-attributable duty on the original entry may not match the IEEPA-attributable duty on the corrected entry. The final corrected version is what controls for refund purposes, but reconstructing which version was final requires pulling the full correction history.
Drawback claims that have already touched the IEEPA duties. Some importers have already filed duty drawback claims on the same entries, claiming back a portion of the duty for goods that were re-exported or used in manufacture-for-export. The drawback rules interact with the IEEPA refund rules in ways that require coordination, and the answer is not always intuitive. This is one of the cases where the customs broker and (often) outside counsel need to be in the loop.
The work to surface these issues is the same work that produces the refund-ready dataset. The reconciliation is not separable from the filing prep.
Who should be doing this work and when
The work is the trade compliance team's lane, supported by the customs broker that filed the original entries.
The trade compliance team owns the relationship with the broker, has access to ACE through the broker's filing privileges, and is the function inside the company that understands the duty stacking on the entries.
The customs broker has the line-level entry data, the correction history, and the duty-code breakdown in a form that is faster to extract than reconstructing it from the importer's own records.
The CFO or VP Finance, depending on company structure, is the party that needs to be informed of the refund position once the dataset is clean. Refund recovery is a balance-sheet matter as much as a trade compliance matter, and the financial structure of how the refund gets recovered (in-house wait on CBP versus structured advance through a capital partner) is a finance decision.
The work should start now, not when CAPE opens. The 45-to-60 day filing window once CAPE goes live is not enough time to assemble the data and file. It is enough time to file data that is already assembled. Companies that wait until the window opens will spend the window assembling.
What CBP looks for on a clean filing
CBP's review of refund filings will focus on three things, in this order.
The IEEPA attribution. CBP needs to see that the duties being claimed for refund were actually IEEPA duties, separated from any other tariff regime on the same entry. Mixed-code entries without clean separation get flagged for additional documentation.
The importer of record verification. The legal party that paid the duty has to match the party filing the refund. This is straightforward in most cases but gets complicated when there have been corporate transactions (acquisitions, sales, dissolutions) since the original entries.
The liquidation status. Entries that have liquidated past the 180-day protest window follow a separate procedural path. Filings that try to use the standard refund process on out-of-window liquidated entries will be rejected and routed to the protest process.
Filings that satisfy all three on the first pass go through CBP's processing pipeline directly. Filings that miss one of the three get sent back for documentation, which costs time the importer does not have during the filing window.
What "prep for early filing" looks like in practice
The pattern at well-prepared importers in the affected industries looks like this:
By June 2026: customs broker pulls full ACE history for the affected window, organized by entry, with line-level duty code breakdown.
By July 2026: trade compliance team reconciles entry summaries against payment records, identifies discrepancies, and resolves them with the broker.
By August 2026: clean refund-ready dataset is finalized, with IEEPA-attributable duties separated cleanly. Filing template is prepared and reviewed.
When CAPE opens (date pending, expected mid-to-late 2026): the filing submits in the first week of the window, not the last.
This timing leaves room for whatever surprises emerge in the reconciliation work without compressing the filing window itself.
The honest framing
Stone Path facilitates the introduction to a vetted capital partner for importers evaluating the structured File and Fund path. The trade compliance and entry-data work outlined above is the importer's own work, supported by the customs broker. The capital partner handles the refund filing itself for importers who choose the structured path and provides upfront liquidity against the expected refund.
The work to get the entry data clean is the same regardless of which path the importer chooses. In-house, broker-led, or structured through a capital partner, the importer that arrives at CAPE with clean data files cleanly. The importer that arrives without clean data scrambles.
Walk through what an entry-data assessment looks like for your imports and we will scope the prep timeline against your specific entry volume and broker setup.