Customs has refunded $122 billion in tariffs, and firms keep up to 30% of it.

ISSUE 13 · 8 MIN

Pax AI, a licensed customs brokerage in San Francisco run by Penny Chen, audits an importer's tariff entries and files the refund claim that U.S. Customs now accepts as a CSV of up to 9,999 entry numbers. The Supreme Court struck down the IEEPA tariffs on February 20, 2026, and by September 2026, U.S. Customs had certified about $122 billion of the $166 billion collected for repayment. The terrain was open because the refund was a paper job priced by the entry by brokers and by the percentage by refund firms.

Until April, an importer paid duty on every shipment through a customs broker, and when the duty was wrong, a clerk at the broker pulled that shipment's entry summary, found the wrong line, and filed a correction or a protest for that one entry. A tariff refund was paperwork done one entry at a time, and the per-entry fee was accepted because there was no other way to get the money back.

The Supreme Court held on February 20, 2026 that IEEPA does not authorize the President to impose tariffs, and the Court of International Trade ordered Customs on March 4 to reliquidate every affected entry, for every importer, without the IEEPA duty. Customs built a portal called CAPE, opened it on April 20, and made the claim a spreadsheet: a CSV of up to 9,999 entry numbers, uploaded by the importer of record or its broker.

Pax AI is the agent that does the rest. Its IEEPA Refund Assist reads the importer's entries, checks each for a wrong tariff code, duty rate, or country of origin, and files the CAPE declaration and a protective protest before the window closes. It is a US-licensed, ABI-certified brokerage, so it holds its own filer code, and Penny Chen, an MIT PhD who came from Amazon, runs it from 51 Federal Street in San Francisco. Pax does not publish prices. Its pricing page is a form that promises a personalized recovery estimate.

Two parties collect on a tariff refund today. The first is the customs broker, which charges per entry. UPS raised its post entry services fee by $10 per entry on September 1, 2026, and post entry services cover corrections and protests. FedEx charges the greater of $15 or 2% of the duty whenever it advances the duty on the importer's behalf, and customs brokerage and other services were 39% of Expeditors' revenue in 2025. The second is the refund firm. Tariff Refund Solutions publishes a schedule of 8% to 15% for administrative refunds and 15% to 25% for refunds won in court, and halves the fee when CAPE processes it. IEEPA Tariff Recovery says the specialist partners it refers to typically charge 15% to 30% of what comes back.

The toll existed for a technical reason. A broker is licensed under 19 CFR Part 111 and holds an ACE filer code, which one broker directory calls "the legal fingerprint of the licensed entity responsible for your entry filing", tied to the broker's bond. The entry data lived in the broker's system, and every correction carried the broker's code. In the fiscal year before CAPE, Customs handled 338,000 tariff refund entries. In CAPE's first six weeks, it processed nearly 8.5 million.

What changed is the claim format. CAPE takes a CSV of up to 9,999 entry numbers, filed by the importer of record or an authorized broker. Customs takes about 10 days to accept a declaration and pays interest under 19 U.S.C. 1505(c) from the date the duty was paid, at 6% for a corporation and 7% for anyone else. By September 11, about $134.7 billion had been accepted and about $122 billion certified and sent to the Treasury, with about $1.3 billion held for missing bank details. The government appealed the refund order on June 3, and the brokers' trade group ran three Customs webinars in May teaching members to file it themselves. Zollback (a tiered contingency on drawback claims) and Tipalti (refund eligibility checks inside its payables product) are on the same terrain and get a line, not a card.

The price advantage is the gap between the broker's fee per entry and the refund firm's percentage of the check, because the work in between is an eligibility check and a CSV, and anyone who can price that as a flat fee per entry is under both.

A mention here is listed, never sold.

LISTED · LICENSED BROKERAGE WITH AN AGENT

Pax AI audits IEEPA-affected entries for tariff code, duty rate and country of origin errors, resolves them, and files the CAPE declaration and a protective protest before the deadline; it says analysis packages are ready in days where incumbents take months. It is a US-licensed, ABI-certified customs brokerage with SOC 2 Type II, and it claims an average of 15% more recovered than traditional duty drawback methods. Penny Chen raised a $4.5 million seed in April 2025 led by Initialized Capital, with Flexport angels in the round. The price is not published; the pricing page asks you to request an estimate.

Reach them · @getpaxai · paxai.com

LISTED · FREE CALCULATOR FROM A BROKER

On February 26, 2026, six days after the ruling, Flexport released a set of agents that includes a Tariff Refunds calculator, which takes an upload of ACE entry data and estimates the IEEPA refund, and an Audit Your Customs Broker agent that reads past filings for errors. Both are free, and the help page says Flexport is not acting as your customs broker, attorney or advisor when you use them. Ryan Petersen says the audit agent cut Flexport's own customs filing error rate to 0.2%. The free tool is how Flexport wins the brokerage account.

Reach them · @typesfast · @flexport · tariffs.flexport.com

Take an importer that paid $2,000,000 of IEEPA duty across 500 entries, our assumption rather than a published case. Start with the take rate, the share of the money moving through a service that the service keeps. A refund firm at 15% to 30% keeps $300,000 to $600,000 of that $2,000,000. Tariff Refund Solutions keeps $160,000 to $300,000 on its administrative tier of 8% to 15%, and because it halves the fee when CAPE processes the refund, a CAPE claim there costs $80,000 to $150,000. TariffGuru, run by Omar El Adli in Los Angeles, formats the CAPE CSV for $1 per line with a $1,500 minimum, so the same 500 entries cost $1,500, a take rate of 0.075%.

Now, the cost to serve: what it costs the builder to deliver one job. The claim is a list of entry numbers plus an eligibility check on each, since CAPE rejects anything already under a protest or a drawback claim. The expensive input is a licensed broker's review, because the importer of record or an authorized broker must file the declaration. Call that two hours at $150 an hour, $300 per client, our assumption again. Against a $1,500 flat fee that is a gross margin, revenue minus the direct cost of delivering it, of 80%. Against a 15% contingency the cost to serve is a rounding error.

The third term is working capital, the cash a business needs on hand between paying its bills and getting paid. The $2,000,000 has been at the Treasury since the day it was paid, and Customs pays interest at 6% for a corporation, so a one-year wait, our assumption, adds about $120,000 to the check. A firm that takes a percentage of the whole refund takes a percentage of the interest too. The refund is working capital coming home 60 to 90 days after acceptance, and the builder that brings it home fastest is worth the most to a company with supplier terms due now.

For the build to make money at scale, the flat fee has to be low enough that a broker cannot match it without cutting its own per-entry rate, the broker's review has to be spread across thousands of entries per client, and the agent has to be right about eligibility, because a rejected declaration costs another 10 days of Customs review.

The narrowest wedge is the small importer with a few hundred entries who has never heard of CAPE and whose refund is too small for a contingency firm to chase. The importer of record can pull its own entry data from its ACE portal account and file its own declaration, so the rail is ACE, and the one integration that matters is reading what ACE exports. Pull every entry from February 2025 onward, when the first IEEPA duties appeared, separate the IEEPA line from the Section 232 and Section 301 lines that still apply, drop anything already under a protest or a drawback claim, and produce the CSV. Price it at $2 an entry with a $500 minimum, so 500 entries cost $1,000, an assumption chosen to fall under the broker's per-entry rate and far under the refund firm's percentage. The first customer to call is the importer whose money is stuck. Customs reported about $1.3 billion in refunds held for missing ACH banking information as of September 11, and every one of those companies has a check waiting and nobody telling it how to collect.

RECON · TWO TERRAINS WHERE THE TOLL STILL STANDS

Two jobs where an incumbent still collects and no builder is standing yet, found this week with the sources attached.

RECON · WORKERS' COMPENSATION PREMIUMS

APEX Services says it has returned $48,000,000 to employers, with single recoveries from about $17,000 to more than $500,000, and NCCI's own guide shows the experience modifier that sets the premium is a formula an agent can recompute, with medical-only claims counted at 30% and a split point near $18,500. The consultants who find the errors work on contingency and none publishes the percentage, while the insurer keeps every overpayment nobody disputes. The incumbent cannot cover this spot because the carrier's own audit is the thing being checked. The build reads the policy, the loss runs, and the mod worksheet, recomputes the mod, and files the correction. Charge a flat $750 per policy year. The first call is an employer whose premium rose after last year's audit.

RECON · TELECOM AND UTILITY BILLS

Auditel reports its clients' telecom spend falls by an average of 36%, Ruby+Solberg puts the recoverable range at 15% to 40% of annual telecom expense, and one expense audit guide says 65% to 75% of enterprise telecom invoices carry at least one billing error. The carrier collects on every line item nobody reads, and the contingency auditors all say they keep a portion of the savings; none prints the number. The carrier will not audit its own invoice against its own contract, so the spot stays open. The build parses the invoice and the contract, diffs them, and drafts the dispute. Charge $0.50 per invoice line, or a 10% share capped at $2,500 a month. The first call is a company with a few hundred lines and no telecom manager.

Steven-Chen2021/ieepa-refund-calculator is a FastAPI app that takes an uploaded CBP Form 7501, reads it with OCR, and splits the duty on each line into its MFN, IEEPA, Section 301, Section 232, merchandise processing, and harbor maintenance parts before estimating the refund. It has 0 stars, 1 fork, no license file, and was last pushed on April 18, 2026. It was built inside a freight forwarder as an internal tool and left public, and the missing license means you read it rather than fork it. It is worth an hour because the business rules file is the exact tariff arithmetic a refund agent needs.

The fraud is the bank account switch. A CAPE refund is paid by the Treasury to the account Customs holds for the importer, and as of September 11 about $1.3 billion in refunds was unpaid because that banking information was missing. A recovery firm emails some of the 330,000 importers who paid, offering to file for free, collects an ACE login or a power of attorney, and points the refund at an account it controls before the declaration is accepted. The importer sees a filed claim and waits 90 days for money that has already landed elsewhere. The one control is that the importer sets the refund account directly with Customs, never the agent, and the agent is never a payee. Any product that asks to receive the refund and forward it on is fraud.

PASS IT ON

Someone in your network runs a company that imports, and the refund firm's pitch is already in their inbox. Put ours next to it.

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Agents that claw back bank fees. Recoup says its app finds hidden bank and card fees and files the refund request in under 30 seconds across 16,000 institutions, free to the user, with an average of $325 recovered per person. Bank of America still lists a $35 overdraft item fee, and the federal cap on it was nullified in May 2025. Who keeps the fee, and who gets the reversal.

SOURCES

Supreme Court opinion · Holland & Knight CIT order · CBP CSMS CAPE bulletin · Holland & Knight CAPE guide · Holland & Knight June update · GHY CAPE refund tracker · Penn Wharton tariff revenue · FreightRight importer count · UPS brokerage rate changes · FedEx 2026 fee changes · Tariff Refund Solutions fees · IEEPA Tariff Recovery guide · Expeditors 2025 10-K · Customs Broker Index filer code · NCBFAA CBP webinars · Flexport launch release · Flexport refund tool help · Flexport refund tool · Pax AI product page · Pax AI seed announcement · Pax AI pricing page · Pax AI home · TariffGuru pricing · Zollback launch post · American Banker Tipalti · GitHub refund calculator · NCCI experience rating guide · APEX premium recovery · Auditel telecom audit · Ruby+Solberg contingent audits · Socium telecom audit guide · Recoup fees back · Bank of America fee schedule · Consumer Finance Monitor CRA