CBP ACE Portal Registration: How U.S. Importers Apply, Set Up Sub-Accounts, and Unlock Tariff Refunds
By Jeb Singer, Managing Partner, Singer Law Group, and Co-Founder of Singer Tariff Recovery
For U.S. importers exploring potential tariff recovery opportunities, customs records come first.
Which entity imported the goods?
Which Importer of Record number appears on the entries?
What duties were paid?
Which entries are potentially affected?
What is the current status of those entries?
And can the people responsible for the recovery project actually access the information they need?
That is where the CBP ACE Portal becomes important.
The Automated Commercial Environment, commonly called ACE, is central to the way U.S. customs transactions are recorded and managed. For an importer pursuing a potential tariff recovery, ACE access can provide key visibility into the entry information needed to identify, organize, and track the recovery population.
But opening an account is only part of the job.
The account needs to reflect the company’s actual importing structure.
If a company has multiple Importer of Record numbers, related entities, historical broker relationships, or changes in corporate structure, those details matter when the business
begins matching historical customs entries to a potential recovery.
The same is true of user access.
The person responsible for the recovery project should not discover during an urgent filing or records review that the necessary account permissions, sub-accounts, or customs information are unavailable.
Jeb Singer is the Managing Partner of Singer Law Group and co-founder of Singer Tariff Recovery. Through Singer Tariff Recovery, Jeb works with U.S. importers seeking to understand and organize potential tariff recovery opportunities.
That work starts with the underlying customs records: identifying affected entries, reviewing Importer of Record information, organizing entry status, and developing a clear administrative recovery plan.
ACE access can be an important part of that process because it helps importers understand what their customs records actually show.
This guide explains how ACE Portal registration works, what importers should have ready before starting, how Top Accounts and sub-accounts fit together, and what account and data issues to identify before they interfere with a tariff recovery project.
What Is the CBP ACE Secure Data Portal — and Why Does It Matter?
The CBP ACE Secure Data Portal is the account-based interface businesses use to access and manage information associated with their customs activity within the Automated
Commercial Environment.
For an importer, ACE Portal access offers more than an online customs account.
It can provide visibility into information that becomes important when the company is trying to answer basic questions about its importing history.
For example:
Which entries were filed?
Which Importer of Record number was used?
When were the entries made?
What duties were reported?
What is the status of the entries?
Which business entity is connected to the records?
Are the company’s internal records consistent with the customs data?
Which entries require additional review?
Those questions matter for ordinary customs compliance.
They become especially important when a company is reviewing potential tariff recovery opportunities.
A refund analysis should not begin with an estimate taken from a general ledger or a total tariff expense.
It should begin with the entries.
ACE as the U.S. Single Window for All Import and Export Processing
The Automated Commercial Environment is the central electronic environment used for U.S. customs and trade processing.
For importers, that means the customs activity associated with the company’s entries exists within a larger electronic record.
The ACE Secure Data Portal provides an account-based way to access and work with information connected to those transactions.
That distinction matters when a company has historically relied almost entirely on its customs broker.
A broker may file entries on behalf of an importer.
That does not necessarily mean the importer has organized its own customs records internally or has direct visibility into everything needed for a recovery review.
When tariff recovery becomes a priority, management may suddenly need information covering years of importing activity.
That can include:
Entry numbers
Entry dates
Importer of Record information
Duty information
Liquidation information
Entry status
Historical broker information
Related importing entities
If the company cannot readily connect those records, the first stage of the recovery project can become a data-reconciliation exercise.
That is why ACE should not be viewed only as a customs filing system.
For an importer evaluating a recovery opportunity, it can also be an important source of information for understanding the company’s entry history.
Who Must Register: Importers, Brokers, Exporters, and Freight Forwarders
Different members of the trade community may use ACE for different purposes.
That can include importers, customs brokers, exporters, freight forwarders, and other parties involved in U.S. trade activity.
For tariff recovery purposes, this article focuses primarily on importers.
The practical question for an importer is not simply:
“Do we have an ACE account?”
A better set of questions is:
Who controls the account?
Which company entities are represented?
Which Importer of Record numbers are connected to those entities?
Who has access?
Can the team obtain the reports and entry information it needs?
Do legacy accounts or identifiers need reconciliation?
This becomes particularly important for companies that have:
Changed customs brokers
Acquired another importing company
Been acquired or reorganized
Used multiple EINs
Used multiple IOR numbers
Imported through several subsidiaries
Changed personnel responsible for customs compliance
Allowed ACE access to remain primarily with one employee or department
Consider a corporate group with three operating companies.
Entity A may have imported under one IOR.
Entity B may have used another.
Entity C may have acquired a business with its own historical import activity.
If management looks at the consolidated company’s tariff expense, it may not be obvious which entity appears on each customs entry.
For recovery purposes, that distinction can matter.
The customs records should be organized at the entry and Importer of Record level before management treats a company-wide estimate as a supportable recovery population.
Why ACE Portal Access Is Especially Urgent for Importers in 2026
For importers reviewing potential IEEPA tariff recovery opportunities, waiting to organize customs access until a deadline or filing issue appears can create unnecessary problems.
The company may know it paid substantial tariffs.
That does not mean it already has the information needed to act.
Before relying on a projected recovery, the importer should be able to identify:
The affected entries
Importer of Record for each entry
Duties paid
Tariff authority under review
Entry status
Liquidation information
Supporting customs records
Any administrative action already taken
Any entries requiring additional review
ACE data can help build that picture.
But account access alone does not establish refund eligibility.
An entry appearing in ACE does not automatically mean the associated duty is recoverable.
You still need to review the records.
Different duties may appear across the same importing population, and you should not
automatically group them.
That is why the process should move in order:
First, establish access.
Then, identify the entries.
Then, reconcile the Importer of Record information.
Then, separate the duties under review.
Then, organize entry status.
Then, determine the appropriate action for each group of entries.
Singer Tariff Recovery’s approach begins with that underlying data.
For importers trying to understand how customs records should be reviewed before a recovery project moves forward, ACE data and customs entry review provide a deeper look at how entry information can be organized, checked, and reconciled.
The goal is not simply to have an ACE login.
The goal is to know what the company’s customs records show and to have the information organized well enough to make informed decisions about the recovery process.
For an importer with years of historical entries, several IORs, multiple brokers, or changing corporate entities, that work is better done before an urgent deadline appears.
Access is the starting point. Clean, organized entry data is what makes that access useful.
What You Need Before You Apply for an ACE Portal Account
Before starting an ACE Portal account application, organize the company’s information.
Do not treat registration as a task that belongs only to IT or the employee who happens to manage customs paperwork.
For an importer, the account may eventually need to support access to years of customs activity involving different entries, Importer of Record numbers, brokers, and business entities.
Start by identifying:
Legal company name
EIN
Importer of Record number or numbers
Current customs broker or brokers
Historical customs brokers, if relevant
Existing ACE access
Existing Top Account information
Trade Account Owner
Employees or advisors who need access
Related importing entities
Legacy accounts or identifiers that may still exist
If the company has gone through a merger, acquisition, restructuring, name change, or broker transition, investigate that history before assuming the current corporate information tells the whole story.
For a potential tariff recovery, the goal is ultimately to connect the company to the underlying customs entries.
That makes accurate identifiers important from the beginning.
Required Corporate Identifiers by Trade Role
The identifier needed for an ACE account or sub-account, depends on the company’s trade role.
The source article organizes the basic requirements this way:
Trade Role | Required Identifier |
Importer | Importer of Record (IOR) Number |
Organizational Broker | Filer Code |
Exporter | Self-provisioned after Top Account approval |
Protest Filer | Self-provisioned after Top Account approval |
For most readers of this guide, the key identifier is the Importer of Record number.
That is because the IOR is tied to the customs entries the company is trying to identify and organize.
Before moving forward, confirm which IOR number or numbers the business has actually used.
Do not assume there is only one.
A corporate group may have several importing entities.
An acquired business may have historical entries under another IOR.
A company may also find that older records don't line up neatly with the corporate structure management uses today.
Build an identifier list before beginning a larger recovery review.
For example:
Entity | EIN | IOR Number | Current/Historical | Broker | ACE Access Confirmed |
Entity A | ___ | ___ | Current | ___ | Yes/No |
Entity B | ___ | ___ | Current | ___ | Yes/No |
Entity C | ___ | ___ | Historical | ___ | Yes/No |
This simple exercise can identify problems early.
Importer of Record Number vs. EIN: Which Do You Need?
An EIN and an Importer of Record number serve different purposes.
Don't treat them as interchangeable just because they may be connected to the same company.
The EIN identifies the business for federal tax purposes.
The Importer of Record information connects the importing entity to its customs activity.
For tariff recovery work, the IOR becomes particularly important because the recovery analysis must tie back to the entries.
Suppose management believes the company paid $4 million in tariffs during the period under review.
That number alone does not answer:
Which entity imported the goods?
Which IOR appears on the entries?
Which entries make up the $4 million?
What duties were actually paid?
Which of those duties belong in the recovery population?
What is the current status of those entries?
You can't answer those questions from the EIN alone.
They require the customs records.
If several IOR numbers appear across the company’s historical entries, organize them separately before combining anything into a company-wide recovery estimate.
The same applies when a parent company and subsidiaries operate under different identifiers.
The corporate structure management uses for accounting purposes may not match how historical customs entries were filed.
That difference should be identified early.
Government Users: The Separate PGA Account Application Process
Government personnel use a different ACE access process from the trade-community registration discussed in this guide.
This article is focused on private-sector importers and the account structure they may need when reviewing customs entries and potential tariff recovery opportunities.
If you are applying on behalf of a government agency, use the process for government or Partner Government Agency access rather than the importer workflow described below.
Step-by-Step: How to Register for a CBP ACE Portal Account (2026 Process)
The source article reflects the electronic ACE Portal application process in use in 2026.
For an importer, the registration process should be approached with two goals:
Establish the appropriate account access.
and
Make sure the account structure reflects the company’s actual importing activity.
The second goal is easy to overlook.
A successful login does not necessarily mean the company has resolved every IOR, sub-account, user-access, or historical-entry issue that may matter later.
Step 1 — Confirm Eligibility and Gather Required Identifiers
Before starting the application, identify the trade role and gather the corresponding company information.
For an importer, have the company’s relevant EIN and Importer of Record information available.
If the business has more than one importing entity, do not choose an identifier simply because it is the one management recognizes most easily.
Confirm which entities and IOR numbers actually appear in the customs history.
Also determine whether an ACE account already exists.
This is especially important when:
The company changed customs brokers.
Customs responsibilities moved between employees.
The business acquired another importer.
Several subsidiaries import merchandise.
The company recently reorganized.
Personnel who handled historical importing activity have left.
Management is uncertain who currently controls ACE access.
Creating a new account without understanding an existing structure can create more work later.
Step 2 — Access the Electronic ACE Portal Application at aceaccountreview.cbp.gov
The source article identifies the electronic application location used for the 2026 ACE Portal process.
When completing the application, use the company’s legal information and verified trade identifiers.
Do not guess at an IOR number or use an identifier simply because it appears in an old spreadsheet.
Confirm it against the company’s customs records.
Keep a record of what was submitted, including:
Legal entity name
EIN
IOR information
Trade role
Contact information
Account owner information
Date submitted
Any supporting information provided
That record becomes useful if the company later needs to determine why an account, sub-account, or identifier does not match historical customs activity.
Step 3 — Submit Your Top Account Application
The Top Account is the company-level account at the center of the ACE Portal structure.
When submitting the application, identify the individual who will serve as the Trade Account Owner, or TAO.
This choice deserves attention.
The TAO should be someone who:
Understands the company’s customs responsibilities
Has appropriate authority
Can manage access when needed
Will remain available during important filing or review periods
Knows who else should have access
Can coordinate with management, customs personnel, brokers, and advisors
Do not make the TAO designation an afterthought.
A technically correct account can still become difficult to use if only one person understands it and that person is unavailable when the business needs records.
Document internally:
Who is the TAO?
Who is the backup contact?
Who has user access?
Which sub-accounts exist?
Which IORs are connected to the account structure?
Who is responsible for maintaining the information?
That gives the company an internal ownership structure for its customs access.
Step 4 — Await CBP Approval and Account Creation
After the application is submitted, the account goes through the applicable review and creation process.
Do not build a tariff recovery strategy around an assumed approval date.
Processing time can vary.
If the company knows it may need ACE access for a customs review, entry analysis, or recovery project, begin the account process before the information becomes urgent.
While the application is pending, use the time to organize the records the recovery team will need.
That may include:
Entry summaries
Broker reports
Customs invoices
Duty-payment records
IOR information
Historical broker files
Internal tariff reports
Entry-status information already available.
Corporate entity records
ACE access is valuable.
It shouldn't be the first time the company starts thinking about its customs data.
Step 5 — Add Sub-Accounts After Your Top Account Is Established
Once the Top Account is established, determine which sub-accounts the company actually needs.
Do not add account types without understanding their purpose.
For an importer pursuing a tariff recovery review, the importer-related account structure is especially important because it must connect back to the company’s customs activity.
Before adding an importer sub-account, confirm:
Correct legal entity
Correct IOR number
Whether the identifier is already associated with another account
Whether the company has historical identifiers
Whether related entities need separate treatment
Who needs access to the sub-account
This is where prior corporate changes matter.
Suppose Company A acquired Company B.
Company B historically imported merchandise under its own IOR.
Management now operates everything under Company A.
That does not necessarily make Company B’s historical customs records disappear or automatically move them into Company A’s current account structure.
You still need to identify and reconcile the historical entries.
For a tariff recovery project, preserve those distinctions until the records establish how the entries should be organized.
Step 6 — Configure User Access and ACH Refund Capabilities
Once you establish the account and appropriate sub-accounts, review the account configuration.
Do not stop at:
“The account works.”
Confirm that the people responsible for the customs and recovery project can access what they need.
Review:
User profiles
Permissions
Report access
Relevant sub-accounts
Importer identifiers
Administrative access
Backup access
Payment or refund information applicable to the company’s account
Internal responsibility for maintaining the account
If the company expects to receive a tariff refund, verify the applicable payment information and refund configuration rather than assuming account creation completed every necessary step.
This is also a good time to establish an internal ACE responsibility checklist.
Responsibility | Primary Owner | Backup | Confirmed |
Top Account administration | ___ | ___ | Yes/No |
Importer sub-account | ___ | ___ | Yes/No |
IOR verification | ___ | ___ | Yes/No |
ACE Reports access | ___ | ___ | Yes/No |
Entry review | ___ | ___ | Yes/No |
Refund/payment information | ___ | ___ | Yes/No |
Deadline tracking | ___ | ___ | Yes/No |
The objective is not simply to complete registration.
It is to create an account structure the company can actually use.
For an importer reviewing a potential tariff recovery, that means being able to move from:
Company
to
Importer of Record
to
Customs entry
to
Duty paid
to
Entry status
to
Recovery action.
When those pieces connect, ACE becomes more than an account.
It becomes part of an organized customs-record system that management can use to understand and pursue the company’s potential recovery opportunities.
ACE Portal Top Accounts vs. Sub-Accounts: Understanding the Structure
An ACE Portal account is not simply one login attached to one company.
The account has a structure.
At the company level is the Top Account. Beneath it are sub-accounts tied to specific trade functions and identifiers. User permissions determine who can access and manage different parts of that structure.
For an importer reviewing a potential tariff recovery, understanding that hierarchy matters because the account structure needs to connect back to the company’s actual customs
history.
The basic relationship looks like this:
Company
↓
Top Account
↓
Importer or other applicable sub-account
↓
Importer of Record information
↓
Customs entries
↓
Users and permissions
The details become especially important when the business has changed over time.
A company may have:
Multiple importing entities
More than one IOR number
Historical IOR numbers
Several customs brokers
Acquired subsidiaries
Legacy ACE access
Employees who previously managed customs activity
Different entities responsible for different entry populations
If those relationships are not understood, management may believe it has complete ACE access while important historical customs activity remains disconnected from the account or recovery review.
What Is a Top Account?
The Top Account is the primary company-level account in the ACE Portal structure.
It sits above the company’s applicable trade sub-accounts and user access.
For management, the important point is that the Top Account should be treated as part of the company’s customs infrastructure.
Know who controls it.
Know which entities and trade functions it connects to.
Know which users have access.
Know what happens if the person responsible for the account leaves the company.
An importer should be able to answer:
What is our Top Account?
Which corporate entity is associated with it?
Who is the Trade Account Owner?
Who else has administrative access?
Which sub-accounts are connected to it?
Which IOR numbers are represented?
Do those IOR numbers match our historical customs records?
That last question becomes particularly important for tariff recovery.
A current corporate structure may not tell the complete story of how merchandise was historically imported.
Suppose a company acquired another importer three years ago.
The acquired company may have filed entries under its own IOR before the acquisition.
The parent may now operate under a different structure.
Those historical entries still need to be identified according to what the customs records actually show.
Do not assume that today’s corporate organization automatically reorganized yesterday’s customs entries.
What Is a Sub-Account — and What Identifier Does Each Type Require?
Sub-accounts sit beneath the Top Account and correspond to specific trade functions.
Depending on the company’s activities, those may include importer, broker, exporter, protest-filer, or other applicable functions.
For an importer reviewing tariff recovery opportunities, the importer sub-account is particularly important because the underlying customs activity must connect to the correct Importer of Record information.
Each identifier should be treated carefully.
Before attempting to add or reorganize a sub-account, determine:
Which legal entity is involved
Which trade function applies
Which identifier belongs to that function
Whether the identifier is already connected to an existing account
Whether the company has historical identifiers
Whether an acquired or related entity previously used the identifier
Who currently controls the applicable account
Whether the historical entries match the expected IOR
Do not create an account map based only on what the company uses today.
Create it from the customs history.
A useful internal worksheet might look like this:
Entity | IOR | Top Account | Importer Sub-Account | Historical Entries | Access Confirmed |
Entity A | ___ | ___ | ___ | Yes/No | Yes/No |
Entity B | ___ | ___ | ___ | Yes/No | Yes/No |
Entity C | ___ | ___ | ___ | Yes/No | Yes/No |
If the company has undergone acquisitions, reorganizations, broker changes, or entity consolidations, add those historical relationships to the worksheet.
The objective is to map the business entity to the customs entries.
What Is a Trade Account Owner (TAO) and What Authority Do They Hold?
The Trade Account Owner, or TAO, is the individual responsible for administering the company’s ACE Portal Top Account.
Don't treat that role as an administrative formality.
The TAO can be central to how the company manages users, permissions, and account access.
For a tariff recovery project, that matters because the recovery team may need timely access to entry information and reports.
The TAO should understand:
Who needs ACE access?
What permissions do those users need?
Which sub-accounts are relevant?
Which IORs belong to the company?
Who is responsible for customs reporting?
Who should have backup administrative access?
Which outside professionals need authorized access, if applicable?
The company should also have a continuity plan.
If only one employee knows how the ACE account is structured, that creates unnecessary operational risk.
A customs manager may retire.
A controller may leave.
A broker relationship may change.
A company may reorganize.
A recovery project may begin years after the entries were originally filed.
Management should not have to reconstruct the entire ACE account history under deadline pressure.
Keep an internal account record that identifies:
TAO
Backup contact
Authorized users
Relevant sub-accounts
IOR numbers
Historical importing entities
Customs brokers
Responsibility for ACE Reports
Responsibility for deadline tracking
The ACE account belongs in the company’s compliance and financial recordkeeping structure, not in one employee’s institutional memory.
Common Error: Why Sub-Account Identifiers Cannot Span Multiple Top Accounts
An identifier conflict can occur when a company attempts to associate a sub-account identifier with a Top Account. In contrast, that identifier is already connected elsewhere in the ACE account structure.
For a company with a simple, unchanged corporate history, this may be straightforward to identify.
For a company that has changed brokers, acquired businesses, reorganized entities, or used different importing structures over time, it can be more complicated.
If an identifier conflict appears, don't work around it by creating additional accounts until you understand the history.
Investigate:
Which Top Account currently holds the identifier?
Which legal entity originally used it?
Is the identifier still associated with an active business?
Did an acquisition or reorganization change the company’s structure?
Who controls the existing account?
Which historical entries are connected to that identifier?
The answer may affect more than ACE access.
If the same identifier is connected to the historical entries being reviewed for tariff recovery, the company needs to understand that relationship before building its recovery population.
The goal is not simply to make an error message disappear.
The goal is to make sure the account structure accurately connects the importer to the customs records being reviewed.
The Setup Errors That Kill CAPE Declarations Before They’re Filed
A tariff recovery problem does not always begin with the filing itself.
Sometimes the problem exists before anyone prepares the declaration.
The company’s ACE account may not reflect its historical importing structure.
The wrong IOR may be associated with the records being reviewed.
A key employee may not have the necessary access.
The company's internal analysis may be missing historical entries.
Different entities may have been combined into one spreadsheet without first determining which importer appears on each entry.
Those are the kinds of issues worth finding before the company reaches the filing stage.
For importers preparing for CAPE or another tariff recovery process, Singer Tariff Recovery starts with the records and works forward.
That means reviewing:
ACE access
Importer of Record information
Entry populations
Entity relationships
Entry status
Duty information
Account permissions
Filing authority
Available supporting records
Applicable deadlines
The objective is straightforward:
Find the mismatch before it becomes a filing problem.
Mismatched Importer of Record Information
An IOR mismatch can become a major issue because tariff recovery needs to be tied to the actual customs entries.
Do not begin with:
“Which company do we think paid the tariffs?”
Begin with:
“Which Importer of Record appears on these entries?”
Then work outward.
For every group of entries under review, identify:
Entry | IOR | Entity | Broker | Duty Under Review | Entry Status |
___ | ___ | ___ | ___ | ___ | ___ |
___ | ___ | ___ | ___ | ___ | ___ |
___ | ___ | ___ | ___ | ___ | ___ |
This becomes particularly important when a company has:
Multiple subsidiaries
Historical acquisitions
Corporate reorganizations
Several IOR numbers
Broker changes
Older entries under an entity no longer actively importing.
Do not combine those entries into one recovery number until you have reconciled the IOR and entity relationships.
A company-wide tariff total may help with financial planning.
It is not a substitute for an entry-level recovery analysis.
Incomplete or Incorrect Entry Populations
Another problem is starting with an incomplete list of entries.
A company may pull records from one customs broker and assume that represents its entire importing history.
But what if the company used three brokers during the period under review?
What if an acquired subsidiary used a different broker?
What if management changed ERP systems?
What if the accounting department’s tariff totals do not reconcile with the entry data?
Build the entry population from the customs records and reconcile it against other available business records.
Look for:
Missing time periods
Missing IORs
Duplicate entries
Gaps between brokers
Unexplained changes in duty totals
Entries assigned to the wrong entity
Entries outside the period being reviewed
Duties that should not be grouped into the same recovery analysis
For a deeper discussion of this records-first process, ACE data and customs entry review explains how importers can organize and review their customs information before relying on it for a recovery filing.
User Access and Permission Problems
A company may technically have an ACE account but still be unable to complete the work it needs to do.
The right users need the right access.
Before a recovery project becomes time-sensitive, confirm the people responsible can obtain the information they need.
That may include:
Internal customs personnel
Finance
Controller or CFO
Trade compliance personnel
Legal counsel
Customs broker
Other properly authorized professionals
Don't wait until a filing is being prepared to find out the employee responsible for the project cannot access the necessary reports.
Test the workflow.
Can the responsible team identify the entries?
Can it obtain the relevant data?
Can it determine which IOR is associated with the entries?
Can it organize the entries by status?
Can it preserve the reports used for the analysis?
If not, solve the access problem before relying on ACE for a time-sensitive recovery project.
Legacy Account and Corporate-Structure Problems
Corporate changes can create some of the most difficult customs-record problems.
Consider:
Acquisitions
The acquired company may have historical entries under an IOR that does not match the parent’s current importing structure.
Mergers
Two businesses may now operate as one organization while their historical customs records remain associated with separate entities.
Name changes
Management may recognize the new company name while older entries reflect the former entity.
Broker transitions
Historical entry records may be spread across several broker systems.
Personnel changes
The employee who managed ACE access may no longer work for the company.
These are not reasons to abandon a recovery review.
They are reasons to map the history before filing.
Create a simple timeline:
Period | Legal Entity | IOR | Customs Broker | ACE Account/Access |
Year 1 | ___ | ___ | ___ | ___ |
Year 2 | ___ | ___ | ___ | ___ |
Year 3 | ___ | ___ | ___ | ___ |
That timeline can explain why today’s ACE account doesn't immediately line up with yesterday’s entries.
Treating Account Setup as the Entire Recovery Process
One of the most serious mistakes an importer can make is assuming that a properly configured ACE account means the tariff recovery work is finished.
It does not.
ACE access gives the company a way to work with its customs information.
The company still needs to analyze the information.
The importer needs to determine:
Which entries are potentially affected?
Which IOR appears on those entries?
What duties were paid?
What is the status of each entry?
Which recovery process may apply?
What deadlines need to be tracked?
What supporting records should be preserved?
That is the difference between account setup and recovery planning.
A login does not establish eligibility.
A report does not automatically establish the amount recoverable.
And a company-wide tariff number does not replace an entry-level analysis.
Customs records must support the recovery strategy.
That is why Singer Tariff Recovery begins with the underlying entries.
The account structure matters because it gives the recovery team access to the records.
The records matter because they tell the team what actually happened.
And only after those records are organized can the importer begin building a clear administrative recovery plan.
Get the account structure right. Then make sure the customs data behind it is right, too.
ACE Portal Registration and IEEPA Tariff Refunds: The Critical Connection
For an importer reviewing potential IEEPA tariff refunds, ACE access becomes valuable when it helps answer a more important question:
What do the customs records actually show?
A company may know from its financial statements that tariff costs increased.
It may have estimates from its customs broker.
It may have spreadsheets showing millions of dollars in duties paid.
Those records can be useful.
But a tariff recovery analysis needs to get more specific.
The importer needs to connect the potential recovery to the underlying customs entries.
That means identifying:
Entry number
Entry date
Importer of Record
Importing entity
Customs broker
Relevant duty information
Entry status
Liquidation information
Administrative action already taken
Supporting records
Deadlines that may affect the entry
Next step for the recovery review
ACE data can help organize that information.
But ACE does not make the recovery decision for the importer.
A customs entry appearing in ACE does not automatically mean every duty associated with that entry is recoverable.
You need to review, organize, and separate the records by the duties and recovery issues involved.
That connection between ACE and tariff recovery is critical.
ACE provides access to the records. The records provide the foundation for the recovery analysis.
How ACE Data Supports CAPE Filing
When an importer is preparing for a CAPE-related recovery process, the starting point should be a reliable entry population.
Don't start with a company-wide estimate and work backward.
Begin with the entries and work forward.
For each potentially affected entry, identify:
Entry | IOR | Duty Under Review | Entry Status | Liquidation Status | Recovery Status |
___ | ___ | ___ | ___ | ___ | ___ |
___ | ___ | ___ | ___ | ___ | ___ |
___ | ___ | ___ | ___ | ___ | ___ |
This creates a working recovery inventory.
From there, the importer can begin separating entries into groups.
For example:
Entries requiring additional data review
These may have incomplete records, unclear IOR information, or discrepancies between broker data and the company’s internal records.
Entries requiring status review
These may need additional attention to determine where they are in the customs process.
Entries ready for the next administrative step
These have the necessary records organized and can move forward based on the applicable recovery process.
Entries requiring legal review
Some entries may raise questions about deadlines, liquidation, protests, ownership, or other issues that qualified customs counsel should evaluate.
The point is to avoid treating thousands of entries as though they are all in the same position.
They may not be.
A company with 10,000 potentially affected entries could have several different entry populations requiring different next steps.
The recovery plan should reflect those differences.
For importers working through this process, STR’s claim your IEEPA refund through the CAPE process resource provides additional information about organizing and preparing a CAPE-related recovery.
ACE Reports: The Foundation of Your Refund Claim
ACE Reports can help an importer move from a general tariff estimate to a more detailed customs-record analysis.
That distinction matters.
Consider the difference between these two statements:
“Our company paid approximately $6 million in tariffs.”
and
“We identified the entries, IORs, duty information, and entry status associated with the tariff amounts under review.”
The second statement is much more useful for recovery planning.
A good entry-level dataset should allow the importer to answer:
Which entries are potentially affected?
Which entity appears as the Importer of Record?
Which duties are under review?
How much was paid?
What is the status of the entry?
Has the entry been liquidated?
Is additional documentation needed?
Has any administrative recovery action already been taken?
What is the next action?
Who is responsible for that action?
The company should also preserve the reports and source records used to create the recovery analysis.
Do not rely on a spreadsheet without knowing where the numbers came from.
If a recovery schedule says an entry is associated with a particular IOR or duty amount, the team should be able to trace that information back to the underlying records.
This becomes particularly important when:
Several customs brokers were used.
Multiple IORs are involved.
The company changed ERP systems.
An acquisition occurred
Another department maintained historical records.
Different tariff programs appear across the entry population.
The objective is not simply to collect more data.
It is to create data that can be explained and supported.
Why ACH Refund Setup Must Happen Before You File
Don't treat refund and payment information as an afterthought.
If an importer is pursuing a potential tariff recovery, the company should understand how its applicable payment and refund information is configured before expecting funds to be processed.
Review the information associated with the company’s customs account and confirm that the appropriate internal personnel understands:
Which entity is expected to receive a refund
Which Importer of Record is associated with the underlying entries
What payment information is on file
Whether the information is current
Who is responsible for maintaining it
Whether corporate or banking changes have occurred
Whether additional steps are required before payment
This is particularly important after:
Bank changes
Mergers
Acquisitions
Entity reorganizations
Changes in treasury personnel
Changes in customs responsibility
Do not assume that because an ACE account is active, every piece of payment or refund information associated with the company is current.
Verify it.
The same records-first principle applies here:
Identify the entity.
Confirm the IOR.
Confirm the entries.
Confirm the applicable refund information.
A recovery project should have a clear path from the customs entry to the company expecting the recovery.
The 180-Day Protest Deadline: Why Importers Cannot Afford to Wait
Tariff recovery is not only a data problem.
Timing can matter.
An importer reviewing historical entries needs to understand their status and identify any deadlines that may affect available administrative rights.
That is why the recovery file should include liquidation information from the beginning.
Do not maintain a list that shows only:
Entry number + estimated refund.
Build a schedule that includes:
Entry | IOR | Liquidation Status | Liquidation Date | Duty Under Review | Next Action |
___ | ___ | ___ | ___ | ___ | ___ |
___ | ___ | ___ | ___ | ___ | ___ |
___ | ___ | ___ | ___ | ___ | ___ |
For entries where protest rights may be relevant, identify and track the applicable deadline carefully.
A deadline should not first appear on management’s radar when only a few days remain.
The company should have a process for identifying:
Entries that have not liquidated
Entries that have liquidated
Liquidation dates
Entries requiring legal review
Potential protest issues
Other administrative actions under consideration
Internal responsibility for the next step
For more information, STR’s 180-day customs protest deadline resource explains why liquidation status and protest timing should be part of an importer’s recovery planning.
When an entry raises a legal question about protest rights or filing deadlines, qualified customs counsel should evaluate the specific facts.
The important operational point is simpler:
Know the status before the deadline becomes the problem.
How to Track Your Refund After Filing
The recovery process does not end when a filing is submitted.
Importers need a system to track what happens next.
A company with hundreds or thousands of entries should not rely on email chains or individual employee memory to know where each part of the recovery stands.
Build a recovery tracker.
At a minimum, consider tracking:
Entry number
Importer of Record
Entity
Duty amount under review
Filing or administrative action
Date submitted
Current status
Additional information requested
Response due
Refund status
Payment status
Next action
Responsible person
A simple structure might look like this:
Entry/Group | IOR | Action Taken | Date | Current Status | Next Step | Owner |
___ | ___ | ___ | ___ | ___ | ___ | ___ |
___ | ___ | ___ | ___ | ___ | ___ | ___ |
This is especially important when different groups of entries move through different stages at the same time.
One group may still be under data review.
Another may require additional documentation.
Another may already be part of an administrative recovery process.
Another may require deadline review.
Another may be awaiting a payment-related step.
Management should be able to see those differences without reopening the entire customs file every time it wants an update.
For importers that need a more structured way to follow the process, STR’s Track Your Tariff Refund Status resource explains how to organize recovery information after filing.
ACE Data Is the Beginning of the Recovery Analysis, Not the End
ACE can provide valuable visibility into an importer’s customs history.
But access to the data is only the beginning.
The recovery team still needs to determine:
Which entries belong in the review?
Which IOR appears on each entry?
Which duties are relevant?
What is the status of each entry?
Which deadlines need attention?
Which records support the recovery?
What administrative step may apply?
Which entries require legal review?
That is why Singer Tariff Recovery approaches potential tariff recovery from the underlying customs records forward.
Jeb Singer is the Managing Partner of Singer Law Group and co-founder of Singer Tariff Recovery. Through STR, Jeb works with U.S. importers seeking to understand and organize potential tariff recovery opportunities.
The process begins with the records: identifying affected entries, reviewing Importer of Record information, organizing entry status, and developing a clear administrative recovery plan.
ACE can help provide the information.
The real work is turning that information into an organized entry-level recovery strategy.
Know the entries. Know the IOR. Know the status. Know the next step.
Common Myths About CBP ACE Portal Registration — Debunked
ACE account setup can look straightforward until an importer needs historical entry data, discovers an IOR mismatch, changes customs brokers, or begins organizing a tariff recovery.
That is when assumptions about the account can become expensive distractions.
Here are four common misconceptions importers should address before relying on their ACE setup for a recovery project.
Myth: PDF applications are still accepted after April 1, 2026.
Importers creating or updating an ACE account should confirm the current application process before relying on an old form, saved instructions, or a procedure the company used years ago.
Customs processes change.
Internal instructions become outdated.
Employees leave.
Old bookmarks remain in company files long after procedures change.
The practical rule is simple:
Use the current ACE account process applicable to the action you are trying to complete.
If your company has not reviewed its ACE access recently, do not assume the process used to establish an older account is still the process you should follow today.
This is particularly important when a recovery project is already underway.
Identify account-access problems before the company is working against an entry-specific deadline.
Myth: An ACE Portal account is only needed for filing customs entries.
For an importer, ACE can be much more than an entry-filing system.
ACE access can help the company review the customs information behind its importing history.
That becomes important when management needs to determine:
Which entries were filed
Which IOR appears on those entries
Which entities were importing
What duties were paid
What the current entry status is
Whether entries have liquidated
Which records belong in a potential recovery review
A customs broker may have filed entries for the company for years.
That doesn't necessarily mean the company’s finance, legal, or management teams have direct access to the customs information needed for a recovery analysis.
For tariff recovery, the goal isn't simply to have an ACE account.
The goal is to be able to connect:
Importer to IOR to Entry to Duty to Entry status to Potential recovery action.
That is what makes ACE access useful.
Myth: Any employee can manage sub-accounts and user access.
ACE account administration should have clear internal ownership.
Don't assume anyone with a login can make every necessary account change or manage every permission.
The company should know:
Who serves as the Trade Account Owner?
Who has administrative authority?
Who has backup access?
Which users can access the relevant reports?
Which sub-accounts exist?
Which IORs are connected to the account structure?
Who is responsible for maintaining access when personnel change?
This is an internal-control issue as much as an account issue.
If the entire ACE structure depends on one employee, the company has a vulnerability.
That employee may leave.
They may be unavailable.
The recovery project may begin years after they established the account.
Management should not discover under deadline pressure that no one else knows how the company’s customs access is organized.
Myth: CBP will send paper checks for tariff refunds.
Don’t make assumptions about how a potential tariff refund will be paid.
Before filing or expecting payment, confirm the refund information associated with the importer and the applicable customs account.
Review:
Refund recipient
Importer of Record
Current banking information
Account configuration
Corporate changes
Bank changes
Treasury contacts
Responsibility for monitoring payment
This is particularly important when the business has changed banks, reorganized entities, completed an acquisition, or changed the personnel responsible for customs or treasury functions.
A recovery plan should account for what happens after a refund is approved.
The company should know where the payment is expected to go and who is responsible for confirming receipt.
Frequently Asked Questions
What is the CBP ACE Secure Data Portal and who needs to register?
The ACE Secure Data Portal provides account-based access to information associated with U.S. customs and trade activity.
For importers, it can be particularly useful for reviewing and organizing customs records.
Whether a company needs its own ACE Portal access depends on what it needs to accomplish.
An importer reviewing a potential tariff recovery should determine whether it has the access necessary to identify and organize:
Customs entries
Importer of Record information
Entry dates
Duty information
Entry status
Liquidation information
Relevant reports
Do not assume that because a customs broker filed the company’s entries, management already has the customs visibility needed for a recovery project.
The importer should understand its own records.
How do I apply for a CBP ACE Portal account in 2026?
Start by identifying the company’s trade role and gathering the correct corporate and customs identifiers.
For an importer, that means understanding the relationship between the legal entity, EIN, and Importer of Record information.
Before submitting an application, determine whether an ACE account already exists.
This is particularly important if the company:
Changed customs brokers
Acquired another importer
Reorganized
Has several subsidiaries
Used multiple IOR numbers
Previously assigned customs responsibility to an employee who has left
Then use the current electronic ACE account application process applicable to the company’s request.
Keep a record of what was submitted, including:
Legal entity
Trade role
EIN
IOR
Account owner
Contact information
Submission date
Once the Top Account is established, determine which sub-accounts and user permissions the business needs.
Don't stop just because the company can log in.
Make sure the account structure can support the customs-record work the business expects to perform.
What is the difference between an ACE Portal Top Account and a Sub-Account?
The Top Account sits at the company level.
Sub-accounts sit beneath it and relate to specific trade functions and identifiers.
A simplified structure looks like this:
Company
↓
Top Account
↓
Trade Sub-Account
↓
Applicable Identifier
↓
Customs Activity
For an importer, the key issue is ensuring the account structure connects to the correct Importer of Record information.
This can get complicated when a company has multiple entities or a changing corporate history.
For example, an acquired company may have historical entries under one IOR while the current parent company imports under another.
Those historical distinctions should be preserved until the customs records establish which entries belong to which importer.
The recovery analysis should follow the entries, not simply today’s organizational chart.
Why do U.S. importers need an ACE Portal account to receive IEEPA tariff refunds?
ACE access can be an important part of organizing a potential IEEPA tariff recovery because the importer needs visibility into the customs entries behind the claim.
But having an ACE account does not automatically establish that a refund is available.
The importer still needs to determine:
Whether it is the Importer of Record
Which entries are affected
Which duties were paid
Whether the duties fall within the recovery issue being reviewed
What the status of each entry is
Whether liquidation has occurred
Whether deadlines need to be addressed
What administrative process may apply
That is why eligibility should be evaluated at the entry level.
For importers trying to determine where they stand, STR’s IEEPA tariff refund eligibility resource offers a deeper look at the questions a company should answer before treating its tariff payments as recoverable.
ACE access supports that analysis by helping the company organize the underlying records.
It does not replace the analysis.
How do I set up ACH refund capabilities in my CBP ACE Portal account?
If the company expects a potential customs refund, review the payment and refund information associated with the applicable account before the recovery process reaches the payment stage.
Do not assume the information is current because it was established years ago.
Verify:
Legal entity
Importer of Record
Refund recipient information
Banking information
Account permissions
Internal treasury contact
Person responsible for monitoring payment
Pay particular attention if the company has:
Changed banks
Completed an acquisition
Reorganized entities
Changed treasury personnel
Changed customs personnel
Updated its importing structure
The person responsible for the ACE account should coordinate with the company’s finance or treasury team so customs and banking records don't operate in separate silos.
If you're unsure what information is required for a particular refund process, confirm the applicable requirements before filing.
What happens if I try to use the same sub-account identifier in two different ACE Portal Top Accounts?
An identifier conflict can prevent the company from organizing the account structure as intended.
If that happens, do not immediately create another account or try to work around the problem.
First, determine why the identifier is already associated with another account.
Ask:
Which Top Account currently holds the identifier?
Which legal entity originally used it?
Is that entity still active?
Was there a merger or acquisition?
Did the company change customs brokers?
Is there a legacy account?
Who controls the existing account?
Which historical entries are connected to that IOR?
For a tariff recovery project, the last question matters most.
An identifier conflict may reveal a larger records issue.
The company may discover that the historical entries it wants to review belong to an importing entity or account structure management wasn't considering.
Resolve the history first.
Then determine the appropriate account solution.
The goal should not be to eliminate an ACE error message.
The goal is to ensure the account structure matches the customs history the company relies on for its recovery analysis.
Get Your ACE Account Right Before You File Anything
An ACE Portal account should not be something an importer thinks about only when a filing deadline is approaching.
If your company is reviewing a potential tariff recovery, organize the account and underlying customs records early.
Start by confirming:
Who controls the Top Account?
Who serves as the Trade Account Owner?
Which users have access?
Which importer sub-accounts exist?
Which Importer of Record numbers are associated with the company?
Do historical IORs need to be reviewed?
Do acquired or related entities have separate customs histories?
Can the right team members access the reports they need?
Is refund and payment information current?
Are entry status and liquidation information being tracked?
Whether deadlines have been identified?
Then move beyond the account itself.
The real tariff recovery analysis happens at the entry level.
For each potentially affected entry, the importer should be able to identify:
Who was the Importer of Record?
What merchandise was entered?
What duties were paid?
Which tariff authority is under review?
What is the current status of the entry?
Has the entry been liquidated?
Is a deadline approaching?
What supporting records are available?
What recovery action, if any, may be appropriate?
That is the difference between having customs data and having a recovery plan.
Do Not Build a Refund Estimate Before You Build the Entry Population
A large tariff number can get management’s attention.
But an accounting estimate is not the same thing as an entry-level recovery analysis.
If the company believes it paid $5 million, $10 million, or $20 million in tariffs during the period under review, the next question should not be:
“When do we get the money back?”
The next questions should be:
Which entries make up that number?
Which IORs appear on those entries?
Which duties are actually part of the issue being reviewed?
What is the status of each entry?
What administrative path may apply?
That work can change the recovery estimate.
Some entries may require additional records.
Some may involve different duties.
Some may be associated with another importing entity.
Some may be in a different procedural position.
Some may require deadline analysis.
That is why STR does not recommend treating a company-wide tariff total as automatically recoverable.
Customs records must support the number.
For importers that want a broader explanation of the recovery process, STR’s IEEPA duty refunds resource explains how importers can begin evaluating potential recovery opportunities.
Build a Recovery File That Management Can Actually Use
A well-organized tariff recovery project should not depend on one employee’s spreadsheet or one customs broker’s records.
Create a central recovery file.
At a minimum, consider tracking:
Field | Information to Track |
Entry Number | CBP entry identifier |
Importer of Record | IOR associated with the entry |
Legal Entity | Company connected to the IOR |
Entry Date | Date of entry |
Customs Broker | Broker associated with the entry |
Duty Under Review | Tariff amount or category being analyzed |
Entry Status | Current administrative status |
Liquidation Status | Liquidated/Unliquidated |
Liquidation Date | If applicable |
Recovery Action | Action taken or under consideration |
Filing Date | If applicable |
Current Status | Where the entry stands |
Next Deadline | Date requiring attention |
Next Action | Required follow-up |
Responsible Person | Internal or external owner |
This gives management a clearer picture of the recovery.
It also makes it easier to identify gaps.
For example:
Entries without an identified IOR
need records review.
Entries without a known liquidation status
need status review.
Entries approaching a potential deadline
need immediate attention.
Entries with inconsistent duty information
need reconciliation.
Entries tied to an acquired or historical entity
may need additional corporate and customs records.
Entries already included in a recovery process
and need tracking.
That is far more useful than one spreadsheet column labeled “estimated refund.”
Your Customs Broker Is Important, but the Importer Should Understand Its Own Records
Customs brokers can be an important part of an importer’s customs process.
But management should still understand the company’s own importing history.
A recovery project may cover years of entries.
During that period, the company may have:
Changed brokers
Used several brokers at once
Acquired another importer
Reorganized subsidiaries
Changed IORs
Changed accounting systems
Changed customs personnel
Changed banks
Moved customs responsibility between departments
No single broker may have the entire history.
That is another reason ACE access and internal customs-record organization matter.
The importer should be able to bring the different pieces together.
The goal is not to replace the broker.
The goal is to ensure the company understands the entries behind its potential recovery.
Know the Status Before You Decide the Strategy
Not every entry should automatically receive the same treatment.
Once you organize the entry population, separate it by status.
For example:
Group 1: Entries still requiring data reconciliation
Resolve missing IOR, duty, broker, or entity information.
Group 2: Entries requiring status or liquidation review
Determine where those entries stand before deciding what administrative step may be available.
Group 3: Entries approaching a potential deadline
Prioritize those entries and obtain legal review where necessary.
Group 4: Entries ready for an administrative recovery step
Confirm that the supporting records and filing information are organized.
Group 5: Entries already submitted for recovery
Track status, requests for additional information, and payment-related developments.
This gives the company an actual workflow.
Instead of asking:
“What is happening with our tariff refund?”
management can ask:
“How many entries are in each recovery stage, what is the value associated with those entries, and what needs to happen next?”
That is a much more useful way to manage a significant recovery project.
Singer Tariff Recovery Starts With the Records
Jeb Singer is the Managing Partner of Singer Law Group and co-founder of Singer Tariff Recovery.
Through STR, Jeb works with U.S. importers seeking to understand and organize potential tariff recovery opportunities.
That process begins with the underlying customs records.
The team identifies affected entries, reviews Importer of Record information, organizes entry status, and develops a clear administrative recovery plan based on the records.
That approach matters especially with ACE.
An ACE account is a tool.
It can provide access to information.
But the account itself does not tell an importer which entries belong in a recovery, whether the IOR information is correct, which deadlines require attention, or what administrative strategy may be appropriate.
Those answers come from reviewing and organizing the records.
Conclusion
For U.S. importers evaluating potential tariff refunds, getting ACE access organized is an important first step.
It is not the finish line.
A useful recovery process connects the entire chain:
ACE access → Importer of Record → Customs entries → Duties paid → Entry status → Deadlines → Recovery strategy
If one piece is missing, find it before the company relies on a refund estimate or moves forward with a filing.
Know which entities imported the goods.
Know which IORs appear on the entries.
Know which duties are under review.
Know whether the entries have liquidated.
Know which deadlines may matter.
And know what the records support before deciding what to do next.
That is how a tariff estimate becomes an organized recovery plan.
If your company paid IEEPA tariffs and you are trying to determine which entries may be affected, where those entries stand, and what steps may be available, Singer Tariff
Recovery can help organize the customs records and build a clearer path forward.
Schedule a call with Singer Tariff Recovery to begin reviewing your company’s entries, Importer of Record information, entry status, and potential tariff recovery opportunities.
Start with the entries. Get the records organized. Then build the recovery strategy around what the customs data actually shows.
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