CUSTOMS COMPLIANCE | 2026-10-04

Find Every IEEPA Entry You Can Still Refund: The ES-003 and ES-022 ACE Reports

You cannot claim a refund on entries you cannot see. Two ACE reports — ES-003 and ES-022 — list your entries, their liquidation dates, and the IEEPA duties paid, so you know exactly where you stand.

Every IEEPA refund claim starts with the same question: which entries are at issue, and what is their status? The answer lives in your own CBP data. Two reports from the Automated Commercial Environment (ACE) — the ES-003 (liquidation) report and th

No importer can claim a refund on an entry it cannot account for, and the deadlines that govern those refunds run from a date buried in CBP's own records. Two ACE reports surface exactly that data — every entry, every liquidation date, every dollar of IEEPA duty — turning a vague sense of "we paid a lot of tariffs" into a precise, actionable list. For a California importer with hundreds or thousands of entries moving through Los Angeles, Long Beach, and Oakland, that list is the difference between a complete recovery and money left behind because a deadline quietly passed. This guide explains what the reports show, the law that makes liquidation dates decisive, the step-by-step procedure for turning the data into claims, and the mistakes that cause importers to lose refunds they were entitled to.

Why You Need the Data First

An IEEPA refund is entry-specific. For each entry, the available path — CBP's administrative refund processing, a protest under 19 U.S.C. § 1514, or a Court of International Trade complaint under 28 U.S.C. § 1581 — depends on whether and when the entry liquidated, because the controlling deadlines run from the date of liquidation. Liquidation is CBP's final computation and assessment of the duties owed on an entry under 19 U.S.C. § 1500, and the timing rules for it appear in 19 U.S.C. § 1504. Before any claim can be made, you need an accurate inventory of your entries, their liquidation dates, and the IEEPA duties paid on each. That inventory comes from ACE.

What ACE Is

The Automated Commercial Environment (ACE) is CBP's electronic system of record for imports — the platform through which entry summaries are filed, duties are paid, and liquidations are posted. Importers and their customs brokers with ACE access can run standardized reports that pull their own entry and liquidation data directly from CBP's records. Because the data comes straight from the agency's system, it is the authoritative source for what was entered, what was paid, and when each entry finalized. Two reports are central to an IEEPA refund analysis: the ES-003 and the ES-022.

The ES-003 — Liquidation Report

The ES-003 is a liquidation report. It lists entries and their liquidation status and dates — the single most important fact for an IEEPA refund, because every refund deadline runs from the date of liquidation. From the ES-003 you can see:

which entries have liquidated and on what exact date;
which remain unliquidated and are still open;
whether any liquidation was extended or suspended under 19 U.S.C. § 1504; and
how each entry maps to a refund path based on its liquidation date.

Because the path and the deadline both turn on the liquidation date, the ES-003 is where the refund analysis begins. An entry that liquidated last month and one that liquidated a year ago call for entirely different actions, and the ES-003 is what tells them apart.

The ES-022 — Entry Summary Report

The ES-022 is an entry summary report. It provides the detail of each entry, including the duties, taxes, and fees paid, the tariff classifications (the Harmonized Tariff Schedule numbers), the entered value, and the entry-level data needed to quantify the IEEPA duties at issue. Where the ES-003 tells you when an entry liquidated — and thus the path and deadline — the ES-022 tells you how much IEEPA duty was paid, and thus the size of the refund at stake. Reading the ES-022 lets you separate the IEEPA component from ordinary duties, antidumping or countervailing duties, and other charges, so the refund figure is accurate. Together, the two reports give a complete picture of both the timing and the money.

Step-by-Step: Turning the Reports Into Claims

Once the reports are in hand, the analysis follows a repeatable sequence:

Pull both reports covering the full period in which IEEPA tariffs were paid.
Match entries across the two reports by entry number, so each liquidation date (ES-003) is paired with its IEEPA duty amount (ES-022).
Isolate the IEEPA duty on each entry, separating it from other duties and fees.
Sort by liquidation status and date into the path categories below.
Calendar every deadline — the 180-day protest window from each liquidation date, and any CIT filing deadline.
File the appropriate claim for each category before its window closes.

How the Reports Drive the Refund Path

Reading the two reports together lets you sort your entries into the correct paths:

Unliquidated entries — can often be corrected before they finalize, for example through a Post-Summary Correction or CBP's administrative refund processing, before liquidation locks in the duties.
Recently liquidated entries — may be eligible for CBP's administrative refund handling within the agency's short post-liquidation processing window.
Entries within 180 days of liquidation — can be preserved by a timely protest under 19 U.S.C. § 1514, following the procedures at 19 C.F.R. Part 174.
Finally liquidated entries past the protest window — generally require a Court of International Trade complaint, filed under 28 U.S.C. § 1581(a) after a denied protest or, where applicable, invoking residual jurisdiction under 28 U.S.C. § 1581(i).

The ES-003 dates place each entry into the right category, and the ES-022 amounts show what is at stake in each.

Running the Reports and Reading Them Correctly

The ES-003 and ES-022 are standard ACE reports that an importer's customs broker, or the importer's own ACE account, can run quickly. If you do not have direct ACE access, your broker can produce them on request. Reading them correctly is the part that rewards care: confirm the report period covers every entry that bore IEEPA tariffs; verify that each liquidation date is a final liquidation and not a scheduled or suspended one; and reconcile the duty figures so the IEEPA portion is cleanly identified. Errors at this stage — a missed entry, a misread date, an overstated refund — propagate into the claims, so the reports deserve a careful reconciliation rather than a glance.

Deadlines the Reports Help You Meet

The reason the ES-003 date matters so much is that the deadlines it feeds are strict and unforgiving:

Protest: within 180 days of liquidation under 19 U.S.C. § 1514(c)(3).
CIT suit after a denied protest: within 180 days of the denial under 28 U.S.C. § 1581(a).
Pre-liquidation corrections: available only while an entry remains unliquidated.

Because each entry has its own liquidation date, each has its own clock. The reports let you build a deadline calendar instead of discovering, too late, that a window has closed.

Common Mistakes When Working From the Reports

Pulling only one report. The ES-003 without the ES-022 tells you the deadline but not the amount; the ES-022 without the ES-003 tells you the amount but not the deadline. Both are needed.
Using a too-narrow report period. Entries that fall outside the pulled range are invisible and can be lost.
Mistaking a scheduled liquidation for a final one. Extensions and suspensions under 19 U.S.C. § 1504 change the real date.
Counting non-IEEPA duties in the refund. Overstating the claim invites denial; isolate the IEEPA component.
Waiting to run the reports. Every day of delay shortens the protest windows on already-liquidated entries.

The Importers Who Recover the Most See Their Data First

Because IEEPA refund deadlines are strict and run from liquidation, the importers who recover the most are the ones who see their data early. Pulling the ES-003 and ES-022, reconciling them, mapping each entry to its path, and acting before the windows close is what turns a general right to a refund into an actual recovery. The reports are the practical starting point for every claim that follows.

Reading Liquidation Status Correctly

The ES-003 does more than list a single date, and reading it well means understanding what liquidation actually is. Under 19 U.S.C. § 1500, liquidation is CBP's final ascertainment of the duties, taxes, and fees due on an entry. Under 19 U.S.C. § 1504, an entry is generally deemed liquidated within a set period unless CBP extends or suspends liquidation, and an extension can push the real liquidation date well past what an importer might assume from the entry date. The ES-003 reflects these states, and each carries a different consequence for a refund:

Liquidated. The duties are final and the 180-day protest clock under 19 U.S.C. § 1514 is running from the posted date.
Unliquidated. The entry is still open; corrections may be possible before the duties finalize.
Extended or suspended. The liquidation date is not yet what a simple calendar calculation would suggest, which changes when the protest window will open and close.

Misreading any of these states leads to a miscalendared deadline, which is why the ES-003 deserves a line-by-line reading rather than a quick scan of the most recent dates.

Quantifying the Refund From the ES-022

The ES-022 is where the dollar figure takes shape, and quantifying the refund accurately protects the claim from challenge. For each entry, the report shows the duties, taxes, and fees along with the tariff classifications and entered value. The task is to isolate the portion attributable to the IEEPA tariffs from everything else on the entry — ordinary ad valorem duties, the merchandise processing fee, the harbor maintenance fee, and any antidumping or countervailing duties, which are not part of an IEEPA refund. An IEEPA refund claim that sweeps in non-IEEPA charges is both inaccurate and an invitation for CBP to deny or reduce it. Building a clean, entry-by-entry schedule of the IEEPA duty amount — supported by the ES-022 detail — is what lets the claim state a precise figure that can be verified, and it also sets the base on which statutory interest under 19 U.S.C. § 1505 will later be computed.

Building a Deadline Calendar From the Data

Once the two reports are reconciled, the single most valuable work product is a deadline calendar. For every liquidated entry, record the liquidation date from the ES-003 and count forward 180 days to fix the protest deadline under 19 U.S.C. § 1514(c)(3). Group the entries by deadline month so the nearest-expiring windows are visible at a glance. For unliquidated entries, note that the opportunity to correct before finalization exists only while the entry remains open, and track expected liquidation dates so none finalizes unnoticed. For any entry where a protest has already been filed and denied, calendar the 180-day deadline to file suit in the Court of International Trade under 28 U.S.C. § 1581(a). A business with thousands of entries cannot hold these dates in memory; the reports make it possible to manage them as a schedule rather than a scramble.

What the Reports Do Not Tell You

The ES-003 and ES-022 are powerful, but they are inventories, not legal conclusions. They tell you which entries exist, when they liquidated, and how much was paid — they do not tell you which legal theory applies, whether a given charge is truly an IEEPA tariff as opposed to another measure, or how to frame a protest so CBP grants it. The reports are the factual foundation; the refund strategy is built on top of them. Treating the data as the starting point for analysis, rather than the analysis itself, keeps importers from the twin errors of claiming too much (and inviting denial) or claiming too little (and leaving money behind). The reports answer "what and when"; counsel answers "how and whether."

Coordinating With Your Customs Broker

For most California importers, the customs broker is the day-to-day holder of the ACE relationship, and a productive refund effort depends on clear coordination with that broker. The broker can run the ES-003 and ES-022 across the full period in which IEEPA tariffs were paid, export the data in a workable format, and confirm which entries were filed under the importer's identifier. When an importer uses more than one broker, or has changed brokers over the relevant period, the reports must be pulled from each so that no entries are missed — a frequent gap for growing businesses. It is also worth confirming that the report period aligns with the importer's own purchasing and shipping records, so that any entry present in the business's books but absent from the reports is investigated rather than overlooked. The goal is a single, reconciled master list of entries that everyone — importer, broker, and counsel — is working from.

Keeping the Reports as a Living Record

Because liquidation is an ongoing process, the reports are not a one-time snapshot but a record that changes as entries move from open to liquidated. An importer that pulls the reports once and sets them aside may find that entries which were unliquidated at the first pull have since liquidated, starting their 180-day protest clocks without anyone noticing. Refreshing the ES-003 periodically — and comparing it against the prior version to catch newly liquidated entries — keeps the deadline calendar current. For a business with a steady flow of entries, this refresh discipline is what prevents the slow, silent loss of refund rights as windows open and close over time. The reports reward not just an initial look but continued attention until every eligible entry has been carried through to a filed claim.

Frequently Asked Questions

What is the ES-003 report?

An ACE liquidation report that lists your entries and their liquidation status and dates — the key fact for determining the refund path and deadline, because the deadlines run from liquidation under 19 U.S.C. § 1504.

What is the ES-022 report?

An ACE entry summary report showing each entry's duties (including IEEPA tariffs), tariff classifications, and entered value — used to quantify the refund on each entry.

Why do liquidation dates matter so much?

Because the IEEPA refund deadlines — the 180-day protest window under 19 U.S.C. § 1514 and the CIT filing deadline under 28 U.S.C. § 1581 — all run from the date of liquidation.

How do I get the reports?

Through your own ACE account, or through your customs broker, who can run both reports quickly on request.

What do the two reports tell me together?

The ES-003 shows when each entry liquidated (the path and deadline); the ES-022 shows how much IEEPA duty was paid (the refund size). Matched by entry number, they give a complete picture.

What if my entries are not yet liquidated?

Unliquidated entries can often be corrected before they finalize, such as through a Post-Summary Correction or CBP's administrative refund processing, before the duties lock in.

Can I rely on the reports to be complete?

Only if the report period covers every entry that bore IEEPA tariffs. A too-narrow range leaves entries invisible, so confirm the dates and reconcile the figures.

How quickly should I run them?

As soon as possible. The protest windows on already-liquidated entries shrink every day, so early data collection preserves the most options.

Related Customs & Trade Guides

Talk to a Customs Attorney About Your Entries

The ES-003 and ES-022 show exactly which IEEPA entries you can still refund. Trembach Law Firm reviews them and maps each to its path. Call (213) 645-2246.

Contact Trembach Law Firm at (818) 514-7680 for a confidential consultation.

Trembach Law Firm | 27001 Agoura Road, Suite 350, Calabasas, CA 91301