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Duty recovery audit · Free

Find the duty you overpaid on your imports

We re-rate every line of your ACE entries for the last 5 years with the Allied CHB HTS Engine, our classification and duty software. You get a line-by-line report of overpaid duty, with the recovery route and the deadline for each line.

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Allied CHB HTS Engine

What does the audit check?

The engine rebuilds the full duty on every entry line, with the rules in force on the date of entry. Then it compares the result with what you paid. Our customs brokers review each difference.

  • Classification

    Each 10-digit HTS number against the goods and CBP rulings. A number with a higher duty than the correct one is an overpayment. A number with a lower duty is a risk, and we tell you.

  • Chapter 99 provisions

    The engine rebuilds the duty on each line with the Chapter 99 lists in force on the date of entry. It flags provisions that do not apply, and duties that the rules say must not stack.

  • Section 232 metals

    For Section 232 metals, heading 9903.82.02 (+50%) covers only chapters 72, 73, 74 and 76. Listed derivatives in other chapters take 9903.82.09 (+25%). Metal under 15% of the weight takes 9903.82.03 (no metals duty).

  • Auto parts and offset licenses

    Parts on the Section 232 auto parts list, parts that you certify for U.S. production or repair, and offset licenses from the Department of Commerce. CBP lets a PSC credit Section 232 duty already paid against a license.

  • Section 301

    Section 301 duties on goods of China. Since July 24, 2026, also the Section 301 duties of 10 to 12.5 percent on goods of sixty listed economies, with their exemptions.

  • AD/CVD flags

    Lines that may fall under an antidumping or countervailing duty order. We flag them for review. An unpaid AD/CVD deposit is a debt to CBP, not a refund, so it is better to know early.

  • IEEPA refunds through CAPE

    The IEEPA duties on your entries and the CAPE status of each entry. CBP refunds IEEPA duties with interest through CAPE declarations in the ACE Portal.

  • MPF

    The merchandise processing fee on each formal entry, against the minimum and the maximum in 19 CFR 24.23. Also goods that the same section exempts from MPF.

  • Duplicate payments and lost refunds

    Bills or entries paid twice, and refunds that CBP issued but could not pay because the ACH refund details were missing. ACE report REV-613 lists these refunds.

Why ACE does not catch these errors

ACE accepts a valid Chapter 99 number even when a lower-duty number applies. CBP does not tell you that you overpaid. You must claim the refund yourself, before a fixed deadline.

Case study · Section 232 metals

What did the audit find for a steel auto parts importer?

A completed engagement. The client's name is not shown. The line figures are from one representative container of its goods.

The situation

  • A U.S. importer of steel and stainless auto parts from India: exhaust hangers, pipe sections, machined housings and engine covers.
  • About 100 ocean containers a month. Another customs broker files every entry.
  • The broker put one Section 232 metals heading, 9903.82.02 (+50%), on every line of every entry. Duty ran at 52.5 to 58.5 percent of the entered value.
  • The importer thought that the cost came from tariff policy. It sent us its entry data for a second opinion.

One line from a container

Exhaust brackets, HTS 8708.99.8180, goods of India

As filed: 9903.82.02
52.5%
2.5% base duty + 50%
Correct: 9903.82.09
27.5%
2.5% base duty + 25%

On an $8,000 line, the duty as filed was $4,200. The correct duty was $2,200. That is $2,000 saved on one line.

Heading 9903.82.02 covers articles in chapters 72, 73, 74 and 76. HTS 8708.99.81 is on the list of derivative steel articles for heading 9903.82.09 (U.S. note 16(c)(vii), CSMS #68855869).

Saved on one container
$7,475
One representative container of the importer's goods.
Saved each month
$747,500
At about 100 containers a month.
Saved each year
About $8.97 million
At the current volume.

What the engine found

  • Wrong heading on chapter 84 and 87 articles

    9903.82.02 covers only articles in chapters 72, 73, 74 and 76 (U.S. note 16(c)(i) to (v)). The auto parts are derivative articles in other chapters. Their heading is 9903.82.09 (+25%).

  • The 15 percent weight rule was not claimed

    A plastic part with steel at 9 percent of its weight takes 9903.82.03: no metals duty. It then pays the Section 301 duty on goods of India (+10%).

  • An article that is not on the metals list

    The cylinder head covers are not on the Section 232 metals list. They pay only the base duty and the Section 301 duty on goods of India.

One representative container, line by line

Duty on one representative container of the importer's goods, as filed and on the correct headings
Article and HTSValueAs filedDutyCorrectDutySaved
Exhaust hangers and brackets8708.99.8180$8,0009903.82.0252.5%$4,2009903.82.0927.5%$2,200$2,000
Exhaust pipe sections8708.92.7500$6,0009903.82.0252.5%$3,1509903.82.0927.5%$1,650$1,500
Machined housings, cast steel8487.90.0080$3,5009903.82.0253.9%$1,8879903.82.0928.9%$1,012$875
Fuel filler necks, plastic8708.99.8180Steel is 9% of the weight$4,0009903.82.0252.5%$2,1009903.82.03 + 9903.05.4412.5%$500$1,600
Cylinder head covers8409.91.5085Not on the metals list$3,7509903.82.0252.5%$1,9699903.05.4412.5%$469$1,500
Hex bolts, alloy steel7318.15.8069Chapter 73: heading correct$5,0009903.82.0258.5%$2,9259903.82.0258.5%$2,925$0
Total, one container$30,250$16,230$8,755$7,475

Goods of India, ocean, date of entry August 20, 2026. Rates include the base duty. Two lines left Section 232 and paid the Section 301 duty on goods of India (heading 9903.05.44, +10%). MPF and HMF did not change.

The result

The importer now files new entries with the correct headings. We checked the open entries for a post-summary correction or a protest, by date of entry.

Checklist

What do we need from you?

Two things to start: your entry line data and a signed power of attorney.

  • Your entry lines for the last 5 years

    Send the ACE report ES-003 Entry Summary Line Tariff Details for your importer of record number. Or grant Allied Cross Account Access to your importer account in the ACE Portal, and we run the report.

  • A signed power of attorney

    It lets Allied act for you with CBP, for example to file a post-summary correction or a protest. You sign it online in a few minutes.

  • Answers to a short list of questions

    Some rules depend on facts that are not in ACE, for example the metal weight of a part. We ask for proof only for the lines where the fact changes the duty.

  • Nothing else to start

    No invoices or packing lists for the first pass. We ask for documents later, only for the entries that we recommend for recovery.

ACE Portal

How do I get the report out of ACE?

The ACE Portal is CBP's website for importers. An importer account lets you run ACE Reports on your own entries. The report we need is ES-003 Entry Summary Line Tariff Details.

No ACE Portal account yet?

  1. Apply online

    Use CBP's Importer Account Application if you have one importer of record number. Use the ACE Portal Account Application Web Form for several numbers.

  2. Name a Trade Account Owner

    The application names one person as the Trade Account Owner for your company. That person adds users and grants access to other accounts.

  3. Wait 24 hours

    CBP says that a new ACE Portal account must wait 24 hours before it can run ACE Reports.

Run the ES-003 report

  1. Log in

    Log in to the ACE Portal and open ACE Reports.

  2. Choose the report

    Select report ES-003 Entry Summary Line Tariff Details.

  3. Set the filters

    Enter your importer of record number and a date range that covers the last 5 years.

  4. Export

    Run the report and export the result as a spreadsheet file.

  5. Send it

    Grant Allied Cross Account Access in ACE (you can revoke it at any time), or ask us for a secure file request link. Do not send the file by open email.

Or give us Cross Account Access

Your Trade Account Owner can grant Cross Account Access to your importer account to the Trade Account Owner of Allied's ACE Portal account. It starts from the Tools tab on the ACE home page.

You choose which tabs we can see. You can revoke the access at any time. We then run the report ourselves.

Sources: CBP ACE Reports catalog (ES-003), CBP CAPE trade information notice (24-hour wait), and CBP's Cross Account Access guide.

Recovery

How is overpaid duty recovered, and by when?

The route depends on the status of each entry on the day we file. The findings report gives the route and the last day for every line.
Routes to recover overpaid duty, with the deadline and the rule for each
RouteWhen it appliesDeadlineRule
Post-summary correction (PSC)The entry is not liquidated yet.Within 300 days of the date of entry and at least 15 days before the scheduled liquidation, whichever is earlier.19 CFR 101.9(b), CBP PSC test
ProtestThe entry is liquidated.Within 180 days after the date of liquidation.19 U.S.C. 1514, 19 CFR 174.12(e)
CAPE declarationIEEPA duties on the entry.CAPE now takes unliquidated entries and entries liquidated in the last 80 days. CBP adds other entries in later phases.CBP IEEPA Duty Refunds, CSMS #68396594
Prior disclosureThe error went the other way: you paid too little.Before CBP starts a formal investigation of the error.19 U.S.C. 1592(c)(4), 19 CFR 162.74

The clock starts on the date of entry

CBP normally liquidates an entry about 314 days after the date of entry. A protest must follow within 180 days. After that, the entry is final and the overpaid duty stays with CBP.

The order of the filings matters

After a CAPE declaration is filed for an entry, ACE rejects a post-summary correction on that entry (error 864, CSMS #68397097). CBP does not accept a post-summary correction as an IEEPA refund request. We file any correction first, then the CAPE declaration.

Costs

What does the audit cost?

Nothing. The audit and the findings report are free.

If the report shows duty that you can recover, we quote the recovery work for your entries. The quote depends on the number of entries and the routes. You decide after you see the findings. If you do not go ahead, you owe nothing.

You can keep your current customs broker. CBP lets a filer submit a post-summary correction on an entry that another filer submitted, when the same importer of record authorizes it.

Process

How does the audit work?

Six steps from your request to corrected entries. You do three of them.
  1. You

    Request the audit

    Use the request box on this page. Tell us the importer name, the type of importer of record number, your ports and your goods.

  2. You

    Sign the power of attorney and share the data

    Sign the power of attorney online. Send the ES-003 report, or grant Cross Account Access in the ACE Portal.

  3. Allied

    We re-rate every line

    The Allied CHB HTS Engine rebuilds the duty on each line with the rules in force on its date of entry. Our customs brokers check the classification behind each variance.

  4. Allied

    You get the findings report

    For each line: the overpaid duty, the legal basis, the recovery route and the deadline. A separate list shows the facts that we need you to prove.

  5. You

    You decide

    We quote the recovery work. If you accept, we file the PSCs, protests and CAPE declarations in the correct order and answer CBP.

  6. Allied

    Correct the next entries

    We give you the corrected headings for new entries. We file them for you, or you give the list to your current broker.

Questions

Duty recovery audit: common questions

Is the audit free?

Yes. The audit and the findings report are free. We quote any recovery filing after the audit, and you decide then. If you do not go ahead, you owe nothing.

Do I have to change customs brokers?

No. CBP lets a filer submit a post-summary correction on an entry that another filer submitted, when the same importer of record authorizes it. Your broker can keep filing your new entries.

Why do you ask for 5 years of entries?

Five years is the recordkeeping period in 19 CFR 163.4. The refund routes reach only the recent entries. The older lines show if an error repeats, and if you paid too little on some entries.

What if the audit shows that I paid too little?

We tell you the entries and the amount. A prior disclosure made before CBP starts a formal investigation limits the penalty under 19 U.S.C. 1592(c)(4). You decide if you file one.

What is the Allied CHB HTS Engine?

It is our classification and duty software. It holds the HTS and the Chapter 99 lists with their start and end dates. For each entry line, it rebuilds the duty in force on the date of entry. Our customs brokers confirm the classification behind each finding.

Can I use the HTS Engine myself?

Not yet. We plan a public HTS lookup on the engine. For now, we run it for you as part of the audit.

Can you recover IEEPA duties too?

Yes, through CAPE declarations in the ACE Portal. CBP pays these refunds with interest to the ACH refund account in your ACE Portal account. Our IEEPA refund page explains the steps.

Why does the order of the filings matter?

After a CAPE declaration is filed for an entry, ACE rejects a post-summary correction on that entry (error 864). CBP also does not accept a post-summary correction as an IEEPA refund request. So we file any correction first, then the CAPE declaration.

Does the audit cover goods other than steel?

Yes. The engine checks every line, for all goods and all countries of origin. Section 232 metals lines need a close check in 2026, because the metals headings changed on April 6 and again on June 8, 2026.

How much time do I have?

It depends on each entry. A post-summary correction must be filed within 300 days of the date of entry. A protest must be filed within 180 days after liquidation. Each week, some entries pass their last day, so send the data soon.

How do you protect my data?

You send the report through a secure file request link from us, or you grant Cross Account Access in ACE, which you can revoke at any time. We sign your non-disclosure agreement first if you ask.

Start

How do I request the audit?

Send the request below. We reply with the next steps. Do not send your importer of record number in the request.

Request: Free duty recovery audit

Free. Recovery work is quoted after the audit.

Do not send an EIN, a Social Security number or a password in this form. We ask for them securely later.

Or call (908) 291-8001 or email info@alliedchb.com.

Find out what you overpaid

Send us your ES-003 report or ACE access and a signed power of attorney. The audit is free.

Call (908) 291-8001 or email info@alliedchb.com

Request the free auditSign the power of attorney

Last reviewed September 26, 2026. This page explains customs rules in general terms. It is not legal advice. Duty rates and CBP procedures change often, and we confirm the figures for your shipment in writing before you commit.

Sources