Audit every US entry against the tariff schedules that changed in 2025
Three parallel audits on every ACE entry: the original declaration against commercial documents, the recovery and correction routes, and the tariff overlay reconciliation. IEEPA baseline, IEEPA country-specific, Section 301, Section 232 and the base HTS rate. One data set. One reconciled view.
This document defines the scope of an IEEPA tariff compliance engagement. It explains what we audit, how we audit it, what data we ingest and what we deliver. It does not constitute legal advice.
US importers now face four concurrent tariff regimes on the same entry
Since February 2025, IEEPA tariff orders have layered on top of existing Section 301 and Section 232 duties. A single ACE entry line can carry the base HTS rate, IEEPA baseline, IEEPA country-specific surcharge, Section 301 list rate and Section 232 rate simultaneously. Most importers have not yet mapped where stacking is incorrect or where rates have been misapplied.
One workflow. Three audits. Every entry.
The three audits run in parallel against the same ACE data set. A finding in one layer almost always surfaces a recovery or exposure in another. The original declaration audit feeds the tariff overlay. The tariff overlay identifies the correction route.
We reconcile every field on the ACE Entry Summary (CBP Form 7501) against the commercial invoice, bill of lading, certificate of origin and packing list. Where an HTS classification, entered value, country of origin or duty rate does not match the source document, we raise a finding.
This is not a sample audit. Every entry line in the engagement period passes through the same reconciliation. Findings are categorised as overpayment, underpayment, classification risk or data discrepancy. The Importer of Record number is the unifying key. We audit every entry filed under your IOR, across every broker.
For every entry line flagged or cleared in Layer 1, we reconcile the applied tariff rates against the rate schedules in force on the date of entry. The IEEPA rate engine tracks every Executive Order amendment and applies the correct baseline and country-specific rate.
IEEPA stacking: the audit verifies that the correct IEEPA rate was applied based on the country of origin and the Executive Order in force on the entry date. Where Section 301 or Section 232 also applies, we verify that the stacking is correct and that no duplicate or excluded rate has been applied.
Section 301 list assignment: each entry line is checked against the four Section 301 lists and their exclusion schedules. Goods assigned to the wrong list, or goods where an exclusion has been reinstated but the rate not corrected, generate findings.
Every finding from Layers 1 and 2 is mapped to the applicable CBP correction mechanism. The remaining time window for each route is calculated per entry. Entries closest to deadline closure are prioritised in the output.
Post-Summary Correction (PSC): the primary recovery route for unliquidated entries. 314-day window from entry summary acceptance. Filed by a licensed customs broker.
Protest: for liquidated entries where the 180-day window from date of liquidation remains open. Filed by a licensed customs broker under 19 USC §1514.
Drawback: for goods subsequently exported or destroyed. 5-year window under 19 USC §1313. IEEPA-specific guidance tracked per Executive Order.
Prior Disclosure: for underpayment findings where voluntary disclosure to CBP under 19 USC §1592 reduces penalty exposure. Filed by a customs attorney.
Document-first. Entry-level. Every line.
We do not start from the tariff schedule. We start from the shipping documents: the commercial invoice, the bill of lading, the certificate of origin, the packing list and the ACE entry summary filed by the broker.
FastNet™, our document-extraction engine, ingests and normalises these documents into a structured data set. Every field on the entry summary is then reconciled against the source documents. Where a field does not match, a finding is raised.
This approach is deliberately conservative. We do not reclassify. We do not revalue. We reconcile what was declared against what the documents say and what the tariff schedules require. The result is a set of findings that are defensible because they are grounded in the importer's own paperwork and CBP’s own rate schedules.
Once the declaration reconciliation is complete, the tariff overlay and recovery route layers run against the same data set. The IEEPA rate engine applies the correct Executive Order rate to each entry based on its date. The output is a single dashboard with three views: original declaration findings, tariff overlay exposure and recovery route mapping.
Six documents. The same for every IEEPA audit.
This is the complete list of documents we ingest for an IEEPA tariff compliance audit. We do not request ERP data, accounting records or internal pricing files.
| Document | Source | Key Fields Extracted | Used In |
|---|---|---|---|
| ACE Entry Summary (7501) | Customs broker / ACE portal | Entry number, HTS code (10-digit), country of origin, entered value, duty rate, duty paid, liquidation status | All three layers |
| Commercial Invoice | Seller / exporter | Unit price, total value, product description, Incoterms, currency | Layer 1 (value reconciliation) |
| Bill of Lading | Carrier / freight forwarder | Shipper, consignee, port of lading, port of discharge, weight, container number | Layer 1 (origin & routing verification) |
| Certificate of Origin | Exporter / chamber of commerce | Country of origin, manufacturer, preferential treatment indicator | Layers 1 & 2 (origin verification, IEEPA rate assignment) |
| Broker Entry Worksheet | Customs broker | Classification rationale, rate computation, special programme indicators | Layers 1 & 2 (rate verification, 301 list assignment) |
| Exclusion Documentation | Importer / trade attorney | Exclusion request number, granted/denied status, product scope, effective dates | Layer 2 (exclusion window tracking) |
Four paths from finding to recovery
MCI identifies the finding and quantifies the amount. The recovery action is filed by your licensed customs broker or trade attorney.
| Route | Legal Basis | When Used | Deadline | Filed By |
|---|---|---|---|---|
| Post-Summary Correction | 19 CFR 191 | Unliquidated entries where duty was overpaid or classification was incorrect. | 314 days from entry summary | Licensed customs broker |
| Protest | 19 USC §1514 | Liquidated entries where CBP assessment was incorrect. | 180 days from liquidation | Licensed customs broker |
| Prior Disclosure | 19 USC §1592 | Underpayment findings requiring voluntary disclosure before CBP investigation. | Before CBP investigation | Customs attorney |
| Drawback | 19 USC §1313 | Goods subsequently exported or destroyed. Duty refund on IEEPA, 301 and 232. | 5 years from importation | Licensed broker / drawback specialist |
Critical timing. The PSC window is the primary recovery route for IEEPA overpayments on unliquidated entries. Once the 314-day window closes, recovery depends on whether the entry has liquidated and the 180-day protest window remains open. The MCI audit calculates the remaining window for every entry in scope, prioritising those closest to deadline closure.
How the IEEPA tariff regime evolved — and why the date of entry matters
The IEEPA tariff regime is not a single policy but a sequence of Executive Orders, each amending rates, scope and country-specific surcharges. The rate in force on the date of your entry determines the duty owed. Applying the wrong rate in either direction creates exposure.
February 2025: EO 14257
Baseline IEEPA tariff of 10% on imports from all origins. Established the framework for country-specific surcharges. First Executive Order to use IEEPA authority for broad-based tariff imposition.
March–April 2025: Rate Escalation
Country-specific rates adjusted through successive amendments. China rate escalated to 145%. Reciprocal tariff schedules published for 57 trading partners with rates varying by country.
August 2025: EO 14324
De minimis threshold ($800) abolished effective 29 August 2025. Every parcel now subject to IEEPA duty regardless of value. Entry Summary (CBP Form 7501) required for all shipments. Formal entry obligation replaces Type 86.
April 2026: Section 232 Expansion
Copper added to Section 232. Six-tier rate structure replaces flat 25%. IEEPA and Section 232 duties stack on affected entry lines. Subheading 9903.82.01 at 0% for entries with no aluminium, steel or copper.
What the rate engine checks for each entry line
- Executive Order in force on the date of entry
- Country of origin and applicable country-specific IEEPA rate
- Section 301 list assignment and exclusion status
- Section 232 applicability (steel, aluminium, copper)
- Stacking correctness: are all applicable rates applied, and only those?
- De minimis status: was the entry correctly treated post-29 August 2025?
What MCI does. What MCI never does.
MyCustomsInfo® operates as an independent compliance auditor under §1641 restrictions. We audit the data. Your licensed customs broker or trade attorney handles every corrective filing.
What MCI Does
- ✓ Ingest and structure ACE entry summaries and shipping documents
- ✓ Reconcile every declaration field against source documents
- ✓ Apply the correct IEEPA, Section 301 and Section 232 rates per entry date
- ✓ Identify overpayments, underpayments and rate misapplication
- ✓ Map each finding to PSC, Protest, Drawback or Prior Disclosure
- ✓ Calculate the remaining recovery window for every entry in scope
- ✓ Deliver findings in a structured dashboard and PDF report
What MCI Never Does
- ✗ File, prepare or submit any document to CBP
- ✗ File a Post-Summary Correction or Protest on your behalf
- ✗ Determine or confirm an HTS classification
- ✗ File exclusion requests or drawback claims
- ✗ Act as a customs broker, trade attorney or legal adviser
- ✗ Guarantee any classification, valuation or outcome
- ✗ Provide legal advice
Every corrective action sits with your broker or attorney. MCI identifies the finding. Your licensed customs broker determines the appropriate corrective action and files the relevant document with CBP. We identify. Your broker acts.
What you receive at the end of each audit cycle
Reconciliation Dashboard
Live, filterable view of every entry, every finding and every discrepancy. Drill from summary to entry line. IEEPA, 301 and 232 exposure in one view.
PDF Audit Report
Formal findings report suitable for board presentation, external audit and broker instruction. Per-tariff-regime breakdown.
Recovery Schedule
Entry-by-entry quantification of overpayments with the applicable recovery route (PSC, Protest, Drawback) and remaining window.
Exposure Register
Entry-by-entry list of underpayments and rate misapplications requiring corrective action or Prior Disclosure.
Broker Data Pack
Structured data extract formatted for your customs broker to file PSCs or Protests without re-keying. ACE-compatible format.
Rate Audit Trail
Per-entry record of which Executive Order, Section 301 list and Section 232 rate was applied and whether it was correct.
IEEPA tariff compliance engagements typically range from $8,000 to $50,000 per audit cycle for the three-layer scope, depending on entry volume, number of tariff regimes in scope and the complexity of your country-of-origin profile. Full pricing on the US Pricing page.
As an indicative benchmark, importers with $5M to $25M annual duty paid across IEEPA-affected origins have historically surfaced 2–5% in audit findings, of which 40–70% is recoverable through PSC and Protest routes within the applicable windows.
See how the three layers work. Then book a review.
Three dashboard views. Each corresponds to one audit layer. The same reconciliation engine, the same data set, three different compliance dimensions.
20-Minute IEEPA Exposure Assessment
Walk through the three-layer methodology with a senior compliance analyst. We will show you the dashboard on a demonstration dataset, discuss your entry volume and tariff exposure, and scope a tailored engagement.
- 20 minutes, no preparation required
- Demonstration dataset, not your data
- Tailored scope and pricing within 48 hours
Sample Audit on Your Own Entries
We run the full three-layer audit on a sample of your recent ACE entries and return the dashboard, the findings and the recovery schedule within five business days. Available under a signed short-form NDA and Data Processing Agreement.
- NDA and DPA before any data inflow
- Isolated sample audit tenant, AWS KMS encrypted
- Thirty-day retention, then verified destruction
IEEPA tariff compliance questions
New Recovery Opportunity
Subheading 9903.82.01 at 0% for entries with no aluminium, steel or copper
Retroactive to 6 April 2026. PSC window open for affected entries. If your entries were assessed at the flat 25% Section 232 rate but contain no steel, aluminium or copper, you may qualify for recovery under the new 0% subheading.
Learn more about 9903.82.01 →