IEEPA Refund Complexity Barometer

Complexity Barometer

Phase 1 is as simple as it gets.

Answer a few questions to gauge how complex your situation is and how strategic your approach should be.

The government's Phase 1 refund program excludes a significant portion of entries based on liquidation status, classification complexity, and filing history. This tool gauges how complex your import profile is and how much strategic thought you should apply before pursuing your refund.

Subsequent phases of the refund program have not yet been announced. While that remains uncertain, working with TTM means you won't be left waiting to find out what applies to you. Our background in VAT refund recovery across multiple jurisdictions means we've seen how these programs unfold — and we use that experience to anticipate what's coming, interpret new guidance as it's issued, and keep you informed so you don't have to monitor CBP's updates.

This is a quick estimation tool based on general indicators. Results should be treated as a starting point for discussion, not a definitive assessment. All inputs are private and used only to generate your estimate.

Liquidation Status
1. What percentage of your entries have been finally liquidated by CBP?
What is final liquidation, and why does it matter?

CBP "finally liquidates" an entry when it officially closes the books on the duty amount owed — typically within 12 months of the entry date. Entries that were finally liquidated more than 80 days before the CAPE filing deadline are excluded from Phase 1 automatic processing. These entries are likely to fall under subsequent refund phases, which are expected to require greater processing and supporting documentation. If you're not sure of your liquidation status, the month picker below estimates it based on when you imported — since most entries liquidate on a predictable timeline, this is a reliable proxy.

Select the months you imported IEEPA-affected goods. We'll estimate your liquidation exposure from there.

Higher exclusion risk Moderate risk Lower risk Lowest risk
used as liquidation estimate
Broker Activity
2. How many customs brokers handled your shipments?
Why does the number of brokers matter?

Each broker maintains separate entry records that must be gathered and reconciled before any refund can be filed. The more brokers involved, the greater the chance that entries get overlooked, duplicated, or become difficult to attribute — all of which increase your complexity score.

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brokers
self-filed entries
Countries of Origin
3. Where were your goods manufactured or sourced?
How does country of origin affect my claim?

Country of origin determines how complex your HTS classification is likely to be. Goods from China were subject to stacked Section 301 duties on top of IEEPA, which introduces an additional layer of classification work and increases the chance that entries are excluded or require additional documentation.

Additional Complexity Factors
4. Do any of these sound familiar? (check all that apply — or use the last option if you're not sure)
Why do these factors affect my estimate?

Each of these situations either automatically excludes entries from Phase 1 or significantly increases the documentation burden for any refund claim. You don't need to know the technical term — if the plain description matches something in your import history, it's worth flagging.

Duty amounts were corrected after the fact
Your broker went back and revised the duty amount on one or more entries after they were originally filed — for example, because the final value or classification changed. These "reconciliation" entries are excluded from Phase 1 automatic processing.
You've previously received refunds by re-exporting or destroying goods
Known as duty drawback, this is where you claimed a refund because imported goods were later exported again or destroyed. Entries connected to drawback claims are handled separately and can complicate IEEPA recovery.
Some goods already carried unusually high additional tariffs
Certain products — often from China — face extra duties imposed because of trade disputes or government subsidies in the country of origin (anti-dumping or countervailing duties). When stacked on top of IEEPA, these complicate the classification and recovery process.
A foreign company was listed as the importer on any shipment
If a non-U.S. entity was named as the official importer of record on any of your entries — even for a single shipment — those entries face one of the more significant Phase 1 exclusions.
Any shipments were cleared with paper forms rather than electronically
If any entries from this period weren't processed through CBP's electronic filing system, they require manual retrieval and are significantly harder to include in a refund claim at scale.
Goods were stored in a warehouse or free trade zone before duties were paid
If you used a bonded warehouse, foreign trade zone, or similar arrangement to delay paying duties until goods were released, additional steps are needed to confirm when and whether IEEPA duties were actually paid — and in what amount.
Your broker has formally disputed a customs charge on any shipment
Sometimes brokers file a formal objection (called a protest) as a precaution — it doesn't necessarily mean there's a problem. But any open, unresolved disputes on an entry may need to be coordinated around before a refund claim can proceed on that entry.
We bore the tariff cost but weren't the official importer of record
If your supplier, freight forwarder, or a third party was listed as the importer of record on your shipments, the legal right to claim a refund sits with them — not you. Recovering what you're owed depends on working through or alongside the IOR, which adds a layer of negotiation to the process.
I'm not sure — some of these may apply but I'd need to check
If any of the above sound possibly familiar but you'd need to confirm with your broker, select this. It adds a moderate complexity weighting to reflect that unknown factors are common — and often more present than importers initially expect.
Duty Amount (optional)
5. Approximately how much did you pay in IEEPA tariffs?
Why add a dollar amount?

Adding a dollar figure converts the complexity estimate into a concrete recovery gap — so you can see the actual dollar amount at risk, not just a percentage.

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