How to read your ACE ITRAC report for IEEPA refund eligibility

Why ACE ITRAC is the source of truth

Three different views of your import activity sit in three different systems, and they do not agree.

• Your accounts-payable duty ledger. Built from broker invoices. Accurate as a record of what you paid the broker, but the broker's invoice often bundles MPF, HMF, and bond charges into a single "duty & fees" line. AP cannot reliably separate IEEPA from §301 from §232 from MFN.
• Your broker's entry-summary file. Built from the ABI submission their software generated. Accurate at filing time, but does not reflect post-entry corrections, liquidation status changes, or duty re-computations CBP made during liquidation review.
• The ACE ITRAC export. CBP's authoritative record of every entry filed under your IOR number. Reflects the current state in CBP's books, including any post-entry corrections, re-liquidations, and CBP-side adjustments. Penny-precise on duty by component.

For refund work, only the third is acceptable. CBP's CAPE validator reconciles every claim line against ITRAC; if your claim is built off broker-invoice data and disagrees with ITRAC by even a few cents, the validator rejects with "Unable to calculate duty." Build the refund off ITRAC from the start and you avoid the loop.

Pulling the right ITRAC report

ITRAC is generated on demand from the ACE Secure Portal at ace.cbp.dhs.gov. Navigate to Reports → Trade → ITRAC Reports → Importer Trade Activity and fill in the request form.

Recommended settings for IEEPA refund work

• Date range: February 1, 2025 through February 20, 2026 (the IEEPA window). Many practitioners pull the last 18 months as a default to capture stragglers and pre-IEEPA baseline entries.
• IOR number: your CBP-assigned importer number (typically your IRS/EIN with a 2-digit suffix). If you operate multiple IORs, pull each separately and reconcile by IOR before merging.
• Output format: CSV. Avoid PDF — you cannot programmatically reconcile a PDF row-by-row, and ITRAC PDFs for large importers run thousands of pages.
• Column set: request the full column set, not the abbreviated default. The default omits liquidation-status fields you will need.
• Aggregation level: line-level detail, not entry-level summary. IEEPA duty appears on Chapter 99 secondary lines that vanish in entry-level roll-ups.

Reports typically arrive in your ACE inbox within 24-48 hours of request. Very large importers (10,000+ entries in the period) may receive a multi-file split — preserve filename ordering and concatenate by Entry Summary Number when building your reconciliation file.

The seven critical columns explained

ITRAC ships with 40+ columns depending on report version. For IEEPA refund eligibility, these seven do all the work.

1. Entry Summary Number

The 14-character CBP entry identifier in the format FFF-NNNNNNN-C — three-character filer code, seven-digit sequence, one-digit check digit. This is the unique key for every refund claim line. CAPE CSVs key on it; CBP Form 19 protests cite it; CIT complaints attach it as a schedule.

One entry summary can contain anywhere from 1 to 999 lines. Each line is a different HTS / country / value combination, but they all share the same Entry Summary Number. Refund work happens at the line level — never at the entry level.

2. Liquidation Date and Liquidation Status

These two fields together determine which refund pathway applies — see our step-by-step IEEPA refund claim guide for the full decision tree.

• Liquidation Status: typically one of UNL (unliquidated), LIQ (final liquidation), RLQ (re-liquidation), SUS (suspended), or EXT (extended). Only UNL and recently-LIQ entries qualify for CAPE Phase 1.
• Liquidation Date: the date CBP finalised duty determination. Triggers the 180-day protest clock under 19 USC § 1514. For Phase 1 eligibility, the date must be within 80 days before April 20, 2026 (i.e. roughly January 30, 2026 onwards).

If Liquidation Status is UNL, Liquidation Date is blank — the entry is still open. CBP has up to 314 days from entry to liquidate (with extensions to 4 years available); practical statutory liquidation happens around day 314 by default for unflagged entries.

3. HTS Number (primary)

The 10-digit Harmonized Tariff Schedule classification on the entry-summary line. This is the Chapter 1-97 commodity code. It does not by itself indicate IEEPA — it tells you what the product is. The IEEPA flag lives on the secondary Chapter 99 HTS column (see column 6 below).

Watch for misclassification while you are here. If the HTS code on a refundable IEEPA line is also wrong, you can stack a misclassification refund on top of the IEEPA refund — both via PSC if unliquidated, or both via CF-19 protest if liquidated. We routinely surface 15-30% additional recovery from misclassification flagged during IEEPA scans.

4. Country of Origin

Reported as an alpha-2 ISO code in newer ITRAC formats and alpha-3 in older formats — see the quirks section below. For IEEPA: only goods of Canadian, Mexican, or Chinese origin were caught by the fentanyl tariffs (9903.01.xx). Reciprocal tariffs (9903.02.xx) applied across all origins.

Country of origin matters for refund decisions in three ways: (1) it determines which IEEPA EO applied; (2) it interacts with EO 14289 stacking math (Canada/Mexico steel and aluminium were stack-capped against §232); (3) it sets up your forward-planning analysis for §301 and §232 origin-engineering opportunities (covered in our refundability matrix article).

5. Entered Value

The dutiable value of the line, in U.S. dollars, on which duty was assessed. For most CIF-quoted goods imported into the U.S. this approximates CIF; the U.S. is technically a FOB-valuation country, but transaction value (the negotiated price) governs and usually includes freight to U.S. port for FOB-Incoterm shipments, so the practical effect is similar.

Entered Value is the denominator for every effective-duty-rate calculation. If your CAPE CSV claim amount is $X and your Entered Value is $Y, the validator computes X/Y and cross-checks against the IEEPA rate that should have been collected on that 9903 code on that date. Mismatches reject.

6. Chapter 99 HTS (the IEEPA flag)

This is the most important column for refund work and the one most easily missed. Chapter 99 codes are secondary HTSUS classifications — they sit on a separate line from the Chapter 1-97 commodity code, but are linked to it. ITRAC reports them either as a column on the same row as the primary HTS, or as separate rows immediately after the primary line (depending on report version).

For IEEPA, the refundable Chapter 99 ranges are 9903.01.xx (fentanyl: Canada, Mexico, China) and 9903.02.xx (reciprocal: all countries). For non-refundable Trump-era tariffs, the codes sit elsewhere — 9903.80.xx, 9903.85.xx, 9903.88.xx, 9903.91.xx, 9903.94.xx. Our IEEPA vs Section 301 vs Section 232 article contains the full code map.

7. IEEPA Duty Paid (the dollar amount)

The dollar amount actually collected on the IEEPA Chapter 99 line, after all stacking and effective-rate adjustments. Crucially, this is not simply Entered Value × headline IEEPA rate — EO 14289 stacking caps may have reduced the effective collected amount to zero on Canada/Mexico steel and auto entries.

ITRAC reports duty by component when full column set is requested. Look for column names along the lines of EstDuty_99, EstDuty_Sec99, or Duty_Component_IEEPA. If your ITRAC version shows only a roll-up duty figure, request a re-run with line-level detail — you cannot reconcile a CAPE claim against a roll-up.

Reading Chapter 99 indicators — refundable signals

Once you have the Chapter 99 column visible, the eligibility check is mechanical. Sort or filter:

• Refundable — Chapter 99 code in 9903.01.10 through 9903.01.34 (IEEPA fentanyl) or 9903.02.01 through 9903.02.99 (IEEPA reciprocal).
• Not refundable — Chapter 99 code in 9903.80.xx (steel §232), 9903.85.xx (aluminium §232), 9903.88.xx (China §301 lists 1-4), 9903.91.xx (newer §301), 9903.94.xx (auto §232).
• Other — every other 9903 code is some other special-programme modifier (FTA preference, GSP, Chapter 98, TPL quota). Not in scope for IEEPA refund work.

Total the IEEPA Duty Paid column for the refundable subset — that is your gross potential refund pool. Mid-market importers typically see this number land between $80k and $4M; large industrial importers $10M+.

Bucketing entries by liquidation status: Phase 1 vs Phase 2 vs Protest vs CIT

Once you have your refundable IEEPA pool, sort it by Liquidation Status and Liquidation Date to bucket each line into a refund pathway:

For most importers, 60-65% of the IEEPA pool sits in CAPE Phase 1, 25-30% in Protest, and the remainder in long-tail liquidated-and-stale or stuck-suspended. The full pathway-selection logic and how to build the filing packet are covered in how to claim your IEEPA tariff refund.

Common ACE ITRAC quirks

ITRAC is a 25-year-old report format that has accumulated idiosyncrasies. Six things that catch first-time readers and cause the most reconciliation errors.

Alpha-2 vs alpha-3 country codes

Newer ITRAC versions use ISO 3166-1 alpha-2 codes (CN, MX, CA). Older versions use alpha-3 (CHN, MEX, CAN) — the legacy SCHEDULE C / ISO 3166-1 alpha-3 standard. Some ITRAC exports inconsistently mix them across columns. Build your country filter to handle both, or normalise to alpha-2 before filtering.

Parentheses-as-negative duty values

ACE inherits an accounting convention where negative dollar values appear as parentheses rather than a minus sign — e.g. ($1,234.56) means -$1,234.56. Negative IEEPA duty appears on re-liquidated entries where CBP has already partially refunded a prior over-collection. If your CSV parser treats parens as text, you will silently exclude these from your total.

Multi-line entries

An entry summary can have 1-999 lines. Each line is a separate HTS / country / value, but Entry Summary Number, Entry Date, and Liquidation Date are shared. When you group by Entry Summary Number to compute totals, do not deduplicate — every line is a separate refund decision. Conversely, when you reconcile against your AP system (which usually has one row per entry), you need to roll up ITRAC lines first.

Penny-precision vs dollar-rounded duty

ACE's underlying database stores duty to penny precision. ITRAC's default presentation rounds to whole dollars on roll-up rows but preserves penny precision on line-level detail rows. CAPE CSV claims must use the penny-precise figures or the validator rejects with "Unable to calculate duty." Always pull line-level detail, never an entry-level roll-up, for refund work.

Re-liquidated entries (RLQ status)

An RLQ entry has been liquidated, then re-opened by CBP and re-liquidated. The Liquidation Date in ITRAC is typically the most recent re-liquidation date, not the original. The 180-day protest clock runs from that most-recent date, which is friendlier to the importer than people usually realise — RLQ entries that look "old" by entry date may still be inside the protest window.

Suspended entries

SUS-status entries are typically suspended pending an AD/CVD scope ruling, a §232 exclusion review, or an outstanding CF-28. They cannot be liquidated until the suspension lifts. For IEEPA purposes, they behave like UNL entries — once the suspension lifts, they become Phase 1 eligible if liquidation occurs within 80 days of the program window.

Putting it together: a worked example

Here is a synthetic but realistic 4-row excerpt from an ITRAC export, showing the seven critical columns. Imagine an importer of mixed industrial goods sourcing from Canada and China.

Reading line by line:

• Row 1: Chinese-origin machinery, IEEPA reciprocal 10% paid ($24,850), liquidated February 15, 2026 (within 80 days of April 20). Pathway: CAPE Phase 1. Refund: $24,850 + interest.
• Row 2 + 3: Same entry, two lines. Canadian-origin steel — IEEPA fentanyl declared (9903.01.10) but $0 collected because EO 14289 stacked it under §232 steel (9903.80.01) at $153,000. Pathway: nothing for IEEPA (no IEEPA dollars to claim). The §232 steel is not refundable. Skip both lines on the CAPE CSV.
• Row 4: Chinese-origin plastic, IEEPA reciprocal 10% paid ($8,720), liquidated September 12, 2025 — more than 180 days ago. Pathway: protest window closed. Only CIT remains, and at $8,720 it is not worth pursuing.

Total claimable from this 4-row excerpt: $24,850. Apply the same logic at scale across 5,000-50,000 rows and you have your portfolio refund position.

Frequently asked questions