What Does a Duty Recovery Audit Actually Check in Your Customs Data?

After the Supreme Court struck down the IEEPA tariffs in February 2026, roughly $166 billion became refundable across an estimated 330,000 US importers. Most of that money is still sitting unclaimed, not because importers don't want it back, but because nobody on their team has time to go line by line through a year of ACE ITRAC data looking for it.

A duty recovery audit is the answer to "where do I even start." Here's what it actually checks, and why the answer is rarely just one thing.

IEEPA refund lines

The most direct win is also the easiest to miss manually: any entry that paid IEEPA tariffs now ruled unlawful is a refund candidate. The complication is that IEEPA duties were often blended into a broader duty line alongside Section 301 or Section 232 charges on the same entry, so a human reviewer skimming a summary report can miss which portion is actually refundable. An audit works from the tariff-line detail, not the entry total, so it separates what's refundable from what isn't rather than flagging (or missing) the whole entry.

Missed FTA preferences

Free trade agreement preference is opt-in at entry time. CBP doesn't apply it automatically, and it doesn't get retroactively corrected unless someone files for it. Entries that qualified for USMCA, KORUS, or another applicable FTA but were filed at the standard rate anyway are a second, separate category of recoverable duty, distinct from IEEPA. On a 46-line test fixture run against a sample importer book, this category alone accounted for roughly 14% of the total recovery found.

Classification errors

HS classification drives the duty rate directly, so a wrong classification either overpays or creates future liability. A recovery audit checks classification consistency against the product description and prior rulings, flagging entries where the classification looks inconsistent with how similar goods were classified elsewhere in the same import history, a pattern that's very hard to spot without comparing entries side by side.

Valuation issues

Related-party transactions, assists, and post-importation price adjustments all affect declared value, and errors here run in both directions: some inflate duty owed, some risk understatement exposure. An audit checks whether the declared value basis matches what the underlying commercial terms actually support.

Forward exposure, not just refunds

The same line-level view that finds past overpayments also flags current Section 232 and Section 301 exposure on future shipments, so the audit isn't only a one-time refund exercise. It's a baseline for whether the next shipment of the same product is going to cost what the import plan assumed.

Why this needs to run against the full ITRAC export, not a summary

Every category above depends on tariff-line and entry-level detail that doesn't survive being rolled up into a monthly or annual summary report. A recovery audit that only looked at total duty paid per entry would catch, at best, the most obvious IEEPA lines, and miss the FTA, classification, and valuation findings entirely, which is usually where a meaningful share of the total recovery actually is.

Trying it on your own data

The fastest way to see what's actually recoverable in your book is to run it, not estimate it. Recover (tradePhlo Intelligence's self-serve duty recovery audit) takes your ACE ITRAC export and returns filing-ready CAPE, PSC, and CF-19 packets for whatever it finds. There's no CBP submission on our end; that stays with your existing broker relationship: customs-compliance.ai/recover.

Frequently Asked Questions

How much of my duty history could actually be refundable?

It depends entirely on your import mix and how much of it was IEEPA-tariffed, and the CAPE Phase 1 refund window applies to specific liquidation periods, so the answer changes with time. The only reliable way to know is to run the actual ITRAC data rather than estimate from memory.

Is a duty recovery audit the same as a customs broker's job?

No. A broker files entries and handles CBP submission going forward; a recovery audit is a backward-looking review of duty already paid (plus a forward check on current classification/valuation exposure) that produces the paperwork a broker or importer then files. The audit doesn't replace the broker relationship, it feeds it.

Do I need to switch customs brokers to run this?

No. The audit runs on an export of your own ACE ITRAC data and returns findings and filing-ready packets. Your existing broker still handles the actual CBP submission.

What if the audit finds nothing?

A clean result is still useful: it confirms classification and valuation are holding up under review, which is worth knowing even without a refund attached.