Managed Recovery for
IEEPA Tariffs

The 2025 IEEPA Tariff Regime

In 2025, the Executive Branch relied on IEEPA to impose a new set of additional import duties—both targeted measures and broader baseline (“reciprocal”) duties across multiple trading partners.

These duties have increased landed costs for many U.S. importers and have triggered major litigation over the government’s authority to impose tariffs of this scope under IEEPA. Because customs procedures are deadline-driven, importers should evaluate affected entries and preservation steps early while the litigation proceeds.

Stenson Tamaddon’s Managed Recovery program is built to help importers prepare now and move quickly if the Supreme Court’s decision in the Costco case creates a viable refund pathway. We work with your team and your customs brokers to identify affected entries, organize the underlying documentation, and build a deadline-aware recovery plan aligned with CBP procedures (including liquidation timelines and rights-preservation steps).

Why Act Now?

Because duties are assessed and refunds are governed by strict customs procedures—specifically liquidation timelines—businesses must evaluate refund-preservation steps early, even while appellate review continues.

• Step 1: Identify affected entries (using ACE/ABI data)
• Step 2: Build liquidation calendar & preserve rights (protective protests)
• Step 3: Litigation coordination & refund execution

To start, we typically need a broker export (ACE), a list of brokers, and a date range—often available in a day.