Last reviewed: October 5, 2026. Reading time: about 10 minutes.
Of everyone positioned to help importers recover IEEPA duties, customs brokers hold a structural advantage no one else has: for entries they originally filed, they are one of only two parties, alongside the importer of record itself, who can legally submit a CAPE Declaration. That is not a small detail. It means a proactive broker can turn a client’s confusion about this process into a concrete, billable, trust-building service that a generic refund-recovery company cannot replicate on those specific entries.
This guide is written for brokers deciding how to approach this, practically, with their own client book, not as a sales pitch for any one method.
The short version: brokers can proactively identify which clients have IEEPA-eligible entries, screen for CAPE's exclusions before filing, submit declarations on clients’ behalf where they hold the original filing, flag finally liquidated entries for legal referral, and position all of it as a value-add rather than a sales pitch. Clients remember who told them about money they did not know to ask for.
Transparency note: this guide is educational. At the end, we link to a referral partner and may earn a commission if a client applies through that link. Read our affiliate disclosure and disclaimer.
In this guide
- Why this matters for your client relationships
- Action 1: Identify eligible clients first
- Action 2: Screen before you file, not after
- Action 3: File where you are the broker of record
- Action 4: Flag complex entries for legal referral
- Action 5: Position it as added value, not upselling
- A client outreach template
- Frequently asked questions
Why this matters for your client relationships
CBP has reported roughly $166 billion in IEEPA duties collected across an estimated 330,000 importers. A meaningful share of your own client book likely falls into that pool, whether or not any individual client has thought to ask about it. Being the one who raises it first, accurately and without overpromising, is a differentiator most competitors are not actively using.
It also reinforces the core of the broker relationship: you are the party who understands their entries, their history, and the technical filing requirements better than any outside service could, on day one. For the background your clients likely have not fully absorbed yet, our pillar guide is a good one to point them to directly.
Action 1: Identify eligible clients first
Pull a portfolio-wide view before reaching out to anyone
Before any client outreach, run your own entry data to identify which clients carry IEEPA Chapter 99 duty lines, roughly what period those duties fall in, and roughly which CAPE category each batch is likely to fall into: unliquidated, within the 80-day window, or finally liquidated. This turns a generic “you may be owed money” message into a specific, credible one.
Action 2: Screen before you file, not after
Apply the exclusion checklist to every batch before submitting
CBP has been explicit about the most common file-level and entry-level rejection reasons: filer mismatches, incorrect entry numbers, formatting that does not match the CAPE template, and entries tied to drawback, USMCA duty deferral, antidumping or countervailing duty cases, surety-paid duties, or warehouse types 21 and 22. Running this screen before you file, not discovering it after a rejection, protects both your time and your client’s confidence in the process. Our mistakes guide and eligibility checklist walk through this in client-friendly language you can also share directly.
Action 3: File where you are the broker of record
Remember the legal constraint runs both ways
You can only submit a CAPE Declaration for entries you, or your firm, originally filed. If a client has entries filed by a different broker historically, you cannot file on those specific entries even with the client’s full authorization, they would need to go back to the original filer or their own ACE access. Being upfront about this distinction, covered in detail in our importer of record guide, builds more trust than letting a client assume you can handle everything.
Action 4: Flag complex entries for legal referral
Know when to hand off, not solve, a case
Finally liquidated entries, those past both the 80-day CAPE window and the 180-day protest window, require a court-ordered reliquidation to recover, as covered in our Phase 3 guide. This is litigation, not a filing task, and it sits outside what a broker does. Flagging these clients early and pointing them toward trade counsel is more valuable to them than letting a non-recoverable entry sit unaddressed.
Action 5: Position it as added value, not upselling
Frame this as service, with clear terms upfront
If you charge for this work, say so plainly and early, rather than letting a client discover a fee after the fact. If you are coordinating with a third-party recovery service for clients whose situations fall outside what you handle directly, be transparent about that referral relationship too. Clients forgive a clearly stated fee far more easily than a surprise one, and this entire category of service depends on trust that is easy to lose and hard to rebuild.
A client outreach template
A specific, low-pressure first message tends to perform better than a broad announcement. Here is a starting point you can adapt:
A template to adapt for client outreach
Subject: A quick note about your IEEPA tariff duties
Hi [Client Name], following the Supreme Court ruling on IEEPA tariffs earlier this year, CBP has been processing refunds for duties paid under that program. Based on a review of your entries, you may have [X] entries that could qualify. I wanted to flag this directly rather than wait for you to come across it elsewhere. I am happy to walk through what I am seeing and what the process would involve on our end. Let me know if you would like to set up a short call.
Frequently asked questions
No. You can only file for entries that you, or your firm, originally filed. For entries filed by a different broker, the client would need to work with that original filer or use their own ACE Portal access.
Standard CAPE Phase 1 cannot accept these. As of October 2026, CBP's Phase 3 process covers a narrow subset, plaintiffs in pending Court of International Trade cases with a specific court reliquidation order. Most clients in this position need a trade attorney, not a broker filing.
That is a business decision specific to your firm, but whatever you decide, state it clearly and early. Surprise fees are the fastest way to damage the trust this kind of proactive outreach is meant to build.
Pull entry summaries for the relevant period and look for the IEEPA Chapter 99 duty line specifically, not total duties paid, which may include unrelated tariffs.
Filing a batch without first screening for CAPE's exclusion categories, which leads to avoidable rejections and client frustration. A pre-filing checklist pass is worth the extra time.
Yes, and being transparent about that referral relationship, including whether you receive any compensation for it, is part of maintaining client trust.
Have a client who needs a broader review?
For clients whose entries fall outside what you handle directly, or who want an independent eligibility check alongside your own work, Tariff Refund Agency offers a free eligibility check that takes about five minutes, with no commitment.
Start a Free Eligibility Check
Affiliate disclosure: if a client applies through this button, we may earn a commission from Tariff Refund Agency. Refund eligibility, amounts and timing depend on individual circumstances and are never guaranteed. Read our affiliate disclosure and disclaimer.
Sources and further reading
- Tariff Refunds Finder: IEEPA Tariff Refund: Are You Owed Money by CBP?
- Tariff Refunds Finder: Tariff Refund Eligibility Checklist for US Importers (2026)
- Tariff Refunds Finder: 5 Costly Mistakes That Can Delay Your CAPE Refund Claim
- Tariff Refunds Finder: Importer of Record Explained, Who Can File a Tariff Refund?
- Tariff Refunds Finder: IEEPA Phase 3 Refunds, What Later-Stage Claimants Must Know
- CBP: IEEPA Duty Refunds (official page)
Educational only. Tariff Refunds Finder is not CBP, U.S. Customs or a government agency, and this guide is not legal, tax or financial advice. Brokers should confirm current filing requirements through CBP and their own compliance counsel.
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