The Manufacturer's Guide to Checking Your Tariff Bill

Why your 2025-26 tariff bill is worth rechecking

Four dated events rewrote the duty math inside twelve months, as of June 11, 2026:

• February 20, 2026. The Supreme Court ruled 6-3 that IEEPA does not authorize the President to impose tariffs, striking down the reciprocal and trafficking tariffs. Roughly 330,000 importers had paid an estimated $166 billion under those programs across more than 53 million entries, per figures CBP filed in court.
• February 24, 2026.The Section 122 surcharge took effect at 10 percent on most imports. It expires July 24, 2026 under the statute's 150-day cap, and a federal trade court ruled the invocation unlawful on May 7, 2026; the ruling is on appeal and the surcharge is still being collected.
• April 6, 2026. Section 232 derivative duties moved from metal-content value to the full entered customs value of covered steel, aluminum, and copper articles.
• June 8, 2026. Section 232 changed again: new rate tiers of 50, 25, 15, and 10 percent, a changed American-metal content threshold, and hundreds of products moved in or out of coverage. New Section 301 actions covering roughly 60 trading partners were proposed in early June and are expected to land around the July 24 transition.

Every one of those changes was applied entry by entry, by brokers filing at speed against rules that kept moving. NAM's Q1 2026 Outlook Survey found 70.6 percent of manufacturers naming trade uncertainty a top challenge, the fifth consecutive quarter it has led the list. The uncertainty is real, but the bill itself is checkable: every dollar you paid sits on a numbered line of a form you already own.

First, check what you already paid

Most guidance for manufacturers skips straight to strategies for the next sourcing cycle. The audit-first step comes before any of that: rebuild what you already paid against the rules that were in force on each entry date, and recover the difference where one exists. It is the only mitigation lever with a deadline attached, and the only one that pays out in cash rather than in avoided future cost.

This is arithmetic, not judgment. A duty line is a rate applied to a value under a program in force on a date. All four of those inputs are knowable after the fact. In a recent run, Kynthar's duty engine priced $2.32 million of duty across 532 entry lines and reconciled the total to the dollar. The same math runs on any entry file. If you want the fast path, the tariff check runs it on upload; the rest of this guide shows you the work so you can run any part of it yourself.

The documents that hold the answer

Your entry summaries (CBP Form 7501)

The 7501 is the entry summary your customs broker files with CBP for every import: the lines, values, tariff codes, and duties for that entry. It is the single most important document in a recheck, because it shows exactly what was charged and under which programs. Your broker can send you copies, or you can pull your entries from your ACE account.

Your ACE data export

ACE is CBP's own portal, and any importer of record can open an account. An ACE export gives you your entry data as structured rows, which makes a line-by-line recheck dramatically faster than working from PDFs, and it reflects the entry record as CBP currently holds it, including corrections filed after the original entry.

Supplier invoices

The invoices behind your entries carry what the entry summary cannot: the product descriptions, material details, and values the duty math depends on. Exclusion checks and value-basis checks both live or die on invoice text, which is why a recheck that reads only the 7501 misses two of the largest error classes.

Broker billing statements

Your broker's statements show the duties, fees, and brokerage charges as they were billed to you. They are the reconciliation layer: when a billed total disagrees with the duty the entry record supports, one of the two is wrong, and the difference is worth chasing.

POs and contracts

Purchase orders and supplier contracts matter for one specific check: when a supplier adds a tariff surcharge line to an invoice, the PO and contract are what you compare it against, alongside the duty actually owed on the goods. Surcharge drift is a buyer-side leak that no entry document will ever show you.

How one entry line gets priced: the duty stack

Each line on a 7501 can carry several duties at once, stacked. Understanding the stack is what turns a wall of codes into a checkable bill. As of June 11, 2026, the layers are these; rates change on a known calendar, so verify current rates with your broker before acting on any single number.

The MFN base rate

Every HTS code carries a base duty rate, often low single digits, sometimes zero. This is the floor of the stack and the one layer that rarely moves.

Section 301

The China tariffs remain in force: Lists 1 through 3 at 25 percent, List 4A at 7.5 percent, and strategic goods at rates from 25 to 100 percent, as of June 2026. They appear on the 7501 as Chapter 99 codes in the 9903.88 range. The money question on every 301 line is whether an active exclusion covered it; 178 exclusions run through November 10, 2026.

Section 232

Steel, aluminum, and copper articles and their derivatives carry Section 232 duties, and the rules were rewritten on April 6 and again on June 8, 2026: full entered customs value replaced metal-content value, and the rate tiers moved to 50, 25, 15, and 10 percent. Every derivative line entered this year needs re-math against the version in force on its entry date. The full treatment is in the Section 232 recheck guide.

Section 122

The 10 percent global surcharge took effect February 24, 2026 and hard-expires July 24, 2026 under the 150-day statutory cap; only Congress can extend it. A federal trade court ruled the invocation unlawful on May 7, 2026, the ruling is stayed on appeal, and the surcharge is still being collected as of June 11, 2026. Confirm its current status with your broker before filing anything that depends on it.

Fees: MPF and HMF

The merchandise processing fee and, on ocean shipments, the harbor maintenance fee ride on most entries. They are small per line and rarely wrong, but they belong in any reconciliation of billed totals against the entry record.

The stacking rules

The layers interact, and one interaction saves money: goods already subject to Section 232 do not pay the Section 122 surcharge. Lines where the surcharge was stacked on 232-covered goods anyway are among the cleanest recoveries in the whole recheck, because the error is visible on the face of the entry.

The seven places money leaks

1. Missed Section 301 exclusions

Exclusions are written as prose product descriptions, not codes, so a code lookup can only say maybe. Lines where the invoice description matches exclusion language that was never claimed at entry are refundable after the fact. Full guide: did your broker claim your Section 301 exclusions?

2. The surcharge stacked on 232 goods

The Section 122 surcharge does not apply to goods already covered by Section 232, and it gets added anyway because the non-stacking rule is obscure and nothing in the filing flow stops it. Ten percent of the entered value, line after line.

3. Section 232 valuation-basis and tier errors

Two restructurings in nine weeks left filings keyed to the wrong basis, the wrong tier, or to coverage a product had already left. Full guide: how to recheck every Section 232 line.

4. HTS misclassification

Recovery firms cite misclassification as the most common overpayment source they find, and the mechanism is mundane: a code chosen years ago under one duty regime quietly became expensive under another. When a line's duty rate disagrees with how comparable goods enter, the difference in dollars is a review candidate for your broker.

5. Country-of-origin errors

Origin determines which programs apply at all. A vendor that moved production, a transshipment leg, or a default origin copied from an old setup can each put a line under the wrong program. Origin errors cut both ways, which is exactly why they belong in the recheck.

6. Missed USMCA qualification

USMCA-qualifying goods are exempt from the Section 122 surcharge, so qualification now moves real money on Canada and Mexico lines. Goods that qualified but entered without the claim paid a surcharge they did not owe.

7. Drawback never claimed on exports

If you export, duties paid on Section 301 goods can be recovered up to five years back. Most mid-market manufacturers have never filed a drawback claim. The routing logic is in the refund pathways guide.

The tariff check runs all seven classes against every line on upload.

The deadlines that decide what you can still recover

Recovery windows are set by statute, and entries liquidate continuously, so the set of entries you can still correct shrinks every week. Liquidation dates vary entry by entry; verify every window below against your own entries with your broker before relying on it.

Post Summary Correction: 300 days from entry

A PSC can fix an entry up to 300 days after the entry date, and no later than 15 days before scheduled liquidation. It is the cheapest, fastest pathway while it is open.

Protest: 180 days from liquidation, absolute

Once an entry liquidates, a protest on CBP Form 19 is the remaining administrative route. The 180-day clock runs from the liquidation date and does not extend.

Drawback: 5 years from import

Drawback on exported goods reaches back five years. Section 301 and Section 122 duties are drawback-eligible; Section 232 duties are not.

CAPE and the IEEPA residue

Refunds of the struck-down IEEPA tariffs run through CBP's CAPE system, live since April 20, 2026. Phase 1 covers unliquidated entries and recently liquidated ones, only the importer of record or the original filing broker can file, and CAPE cannot rule on classification, valuation, or origin. Rejections are common and the rules are unforgiving; the full walkthrough is in the CAPE rejection guide.

Which refund pathway fits which entry

The condensed decision tree: if the entry has not liquidated and is inside 300 days, a PSC fixes nearly everything. If it has liquidated within the last 180 days, protest. If the duty is an IEEPA line, CAPE handles the IEEPA math, and only that. If the goods were exported, drawback reaches back five years on eligible duties. One shipment can hold lines in three different pathways with three different deadlines, which is why the routing is per line, never per entry. The full version, with a worked entry, is in PSC, protest, CAPE, or drawback. Confirm each line's pathway and dates with your broker before filing.

A worked audit: one entry, line by line

Take one entry filed March 12, 2026, three lines, and rebuild each line under the rules in force that day:

Three lines, two findings, one clean line, and a different deadline on each finding. That is what a real audit looks like at full scale: not a verdict about your broker, just line-level arithmetic with a date attached. Every number in a real report clicks through to the exact line on your own document, so you can check any finding yourself. This is the part of the recheck that the checker runs in one pass across every entry you upload.

The do-it-yourself checklist

A controller can run this in an afternoon for a sample of entries:

1. Request 12 months of entry summaries (CBP Form 7501) from your broker, or pull them from your ACE account.
2. Pull the matching supplier invoices for the same period.
3. Pick the ten highest-duty entries to start; the leaks concentrate where the duty does.
4. For each line, note the HTS code, the Chapter 99 codes, the entered value, the origin, and the entry date.
5. Write down which programs were charged on each line: the 9903.88 range is Section 301, the 9903.01 range is IEEPA, and the 232 and 122 programs carry their own ranges.
6. Check every 232-covered line for a stacked Section 122 surcharge. Stacked means money back.
7. Check every 301 line's invoice description against the exclusion list in force on its entry date.
8. Re-math every 232 derivative line against the rules in force on its entry date: value basis, tier, coverage.
9. Flag Canada and Mexico lines that paid the surcharge, and ask whether the goods qualified for USMCA.
10. For each finding, get the liquidation date from your broker and compute which window it is inside: PSC, 300 days from entry; protest, 180 days from liquidation. Verify both dates with your broker.
11. Hand the findings, with the line references, to your broker or counsel to file.
12. Diarize the rest of the entries. The set that is still correctable shrinks every week.

Be honest about where the manual method runs out: 178 exclusions written as prose descriptions, rates that are effective-dated per line, and thousands of lines per quarter. The checklist proves the method on a sample. It does not scale to the whole bill.

Or upload it: what the checker reads and what the report shows

The Kynthar tariff check reads your entry summaries and supplier invoices, prices every line against the duty rules in force on its entry date, and runs all seven error classes. The free first look shows the lines read, the finding count by error class, and your single largest finding in full, with its source line and its recovery deadline. The full report prices every finding in dollars, tags each with its pathway and deadline, and exports in a format your broker or counsel can file from. Recovery always files through your broker, your counsel, or CBP directly; the report is the evidence, not the filing.

Cutting the bill going forward

Once the recheck has recovered what it can, five levers reduce the next twelve months' bill. Each deserves honest framing, because each costs something.

Tariff engineering

Changing what the product is at the border, in material mix, configuration, or state of assembly, can move it to a cheaper line legitimately. It pays when the duty delta is large and the product change is commercially neutral. It costs engineering time and a defensible position your broker signs off on, and it is worthless if the savings evaporate at the next rate change.

The first sale rule

In multi-tier supply chains, duty can sometimes be owed on the price of the first sale in the chain rather than the last, which lowers the dutiable value. The math only works when a genuine earlier sale exists and the documentation proves it, and the documentation burden is real and ongoing. Ask your broker whether your supply chain qualifies before building anything on it.

Origin planning

Re-sourcing to change origin changes which programs apply at all. It is the heaviest lever, it takes quarters, and enforcement attention on origin is tightening, so the planning has to be substantive, not paper.

Drawback, if you export

Exporters can recover eligible duties going back five years, and keep recovering on an ongoing basis. The recordkeeping is the cost. The routing rules are in the refund pathways guide.

Supplier surcharge checks

When a supplier adds a tariff surcharge to an invoice, check it against the duty actually owed on those goods as of the ship date. Surcharges drift PO by PO, and the only way to know whether a surcharge line is the same size as the tariff behind it is to compute the tariff behind it.

What changes next, and when

July 24, 2026: Section 122 expires

The surcharge hard-expires under its 150-day statutory cap, and the replacement Section 301 actions proposed for roughly 60 trading partners are expected around the same date. The week of July 24, most importers' rates change again, and no broker will have re-priced history. Inventory your Section 122 exposure line by line before then, and confirm the transition timing with your broker as it approaches.

November 10, 2026: the 301 exclusions expire

The 178 exclusions and the trade arrangement that extended them run out on November 10, 2026, and claim windows on missed exclusions close entry by entry before that, one liquidation at a time; verify where your own entries stand with your broker. The recheck happens now, not in October. Full guide: did your broker claim your exclusions?

CAPE Phase 2 and the refund appeals

The IEEPA refund machinery is mid-rollout, and the question of refunds on finally-liquidated entries sits with the Federal Circuit as of June 11, 2026. Both will move; what to do while they do is covered in the CAPE guide.

Monitoring: re-pricing on every change

Monitoring prices each new entry as it arrives, re-prices your history every time the rules change, and warns you before a recovery window closes. The rules have changed four times in twelve months; a one-time recheck catches the past, and monitoring catches the next rewrite the day it lands.

Questions manufacturers ask

How far back can I recover overpaid duties?

Three windows matter. A Post Summary Correction reaches back 300 days from the entry date, and no later than 15 days before scheduled liquidation. A protest reaches back 180 days from the liquidation date, with no extensions. Drawback on exported goods reaches back five years. Liquidation dates vary entry by entry, so verify the windows on your own entries with your broker.

Who files the refund claim?

Your customs broker, your trade counsel, or you, directly through CBP's own systems. Kynthar is not a law firm and not a customs broker; the report identifies the overpayment, the pathway, and the deadline, and hands whoever files the line-level evidence to file from.

Do I need my broker's cooperation?

No. Your broker can send you copies of your entry summaries, and you can pull your own entry data from your ACE account regardless. Most brokers welcome the recheck: it hands them line-level evidence instead of a vague suspicion.

What does a check cost?

The first look is free: upload your entries and see the finding count, the error classes, and your largest finding in full. Full report and monitoring terms are listed on the tariff check page.

Is this legal advice?

No. The report identifies potential duty overpayments and the recovery path for each finding. Filing runs through your broker, your counsel, or CBP directly.