ClearDuty AI Phase 1 MVP — what's working today, what isn't, and why. This page is updated as the product evolves.
You can upload ACE entry summary CSVs via drag-and-drop or enter up to 20 entries manually. The parser recognizes standard ACE column names (Entry Number, Entry Date, Import Date, Country of Origin, HTS Code, Duty Paid, etc.) and common variants used by brokers like Flexport, e-Customs, and CustomsCity. If you export directly from the ACE Secure Data Portal, the format is usually compatible.
We first try deterministic column mapping: matching your headers to our known column names (case-insensitive, with minor variations). If fewer than 7 of 10 required columns match, or if the entry number column is missing, or if we parse zero entries from a non-empty file, we fall back to AI-assisted extraction. The AI attempts to infer structure from raw CSV text, which helps with broker exports that use non-standard headers or layouts.
IEEPA tariffs are all in Chapter 99 of the HTS (9903.01.xx and 9903.02.xx). We maintain a versioned registry of these codes with their rates, Executive Order authority, effective date ranges, and country-of-origin applicability. Each line in your entry is checked against this registry: the HTS code must match, the country of origin must be in the code's "applies to" list (or "*" for all countries), and the import date must fall within the code's effective window. Only matching lines are counted as refundable.
For entries that have explicit IEEPA Chapter 99 line items with duty amounts, we sum those amounts as the refundable total. We also estimate interest under 19 U.S.C. § 1505(c), which governs overpayment interest on customs duties. The interest calculation uses the federal overpayment rate and the expected refund timeline (PSC vs. Protest), so your estimate includes both principal and accrued interest.
The tool assigns one pathway per entry. PSC (Post-Summary Correction) applies to unliquidated entries — you can file a PSC in ACE to correct the entry before liquidation. Protest applies to liquidated entries: you have 180 days from the liquidation date to file CBP Form 19; this window is absolute and cannot be extended. CIT (Court of International Trade) is the only option once the protest window has closed. UNCLEAR is used for suspended liquidation or ambiguous cases.
PSC deadline: The earlier of (a) entry date + 300 calendar days, or (b) estimated liquidation date − 15 days. Per 19 C.F.R. § 173.4a, you must file the PSC before liquidation. If your entry is unliquidated and you don't have a liquidation date, we estimate it as import date + 314 days, rounded to the next Friday (CBP standard practice per 19 C.F.R. § 159.11).
Protest deadline: Liquidation date + 180 calendar days. Per 19 U.S.C. § 1514(c)(3), this is absolute — no extensions, no equitable tolling. Missing it bars the protest remedy.
Each deadline gets a color-coded urgency level: Safe (>90 days left), Watch (30–90 days), Urgent (10–30 days), Critical (<10 days — file immediately), and Expired (deadline passed, CIT only). The calendar and entry table use these to help you prioritize which entries to file first.
The dashboard has three tabs: Summary (total refund, pathway breakdown, top entries), By Entry (full sortable/filterable table), and Deadline Calendar (monthly grid with urgency dots). You can export deadlines to .ics (Google Calendar, Apple Calendar, Outlook) with reminder alarms, and export the full computed dataset as CSV.
Some ACE exports or broker reports show only a single total duty amount per entry, without breaking it down by HTS line. In that case, we cannot separate IEEPA duty from MFN (Most Favored Nation) base duty, Section 301, or Section 232. To compute the IEEPA portion accurately, we would need the base Chapter 1–97 HTS code and declared value to recalculate rates — we don't have that logic yet. So if your data is blended, our refund estimate may be lower than what you're actually owed. We surface a disclosure when this applies.
Our registry is built from available sources (Executive Orders, CBP CSMS, trade publications), but the complete list of country-specific IEEPA codes (9903.01.34 through 9903.01.90 and related) may not be fully confirmed with CBP. Edge cases or rarely used codes could be missed. If you have an IEEPA line that we don't identify, it will show $0 refund — verify in ACE or with your broker.
The February 2026 Supreme Court ruling invalidated IEEPA tariffs only. Section 301 (USTR China duties under trade law) and Section 232 (steel, aluminum, auto) are separate authorities and were not affected. We flag entries that contain Section 301 or Section 232 codes in warnings, but we do not calculate refunds for those duties — they are outside this tool's scope.
We accept .csv and .txt only. If your broker exports from Excel, save as CSV first. .xlsx support is deferred to a future release.
Maximum 50MB per file and 5,000 entries per upload. Larger portfolios should be split by date range and processed in batches. The limits exist to prevent browser and server timeouts; we may raise them in a future version.
When deterministic parsing doesn't work, we call an AI model to extract entries from the raw CSV text. If the CSV is highly irregular (e.g., merged cells, multiple tables, non-tabular layout), or if the AI times out or errors, you'll see "Could not automatically parse this CSV format. Please try the manual entry form." We never expose internal AI errors to you — we show a generic message. For small portfolios, the manual form is a reliable fallback.
Phase 1 has no accounts and no database. Your results live only in the browser. They are encoded in the URL when you navigate to the results page, so you can bookmark or share the link, but reloading from a fresh tab (or clearing the URL) loses everything. Export to CSV or iCal if you need to keep the data.
Entries with suspended liquidation (e.g., CF-28/29 exams, ISF bond forfeitures, ADD/CVD orders) don't fit the standard PSC or Protest timeline. We assign pathway "UNCLEAR" and recommend manual verification in ACE. We do not estimate deadlines for these — the liquidation date is unknown until CBP acts.
Federal overpayment interest (19 U.S.C. § 1505(c)) follows the IRS rate, which changes quarterly. We use a hard-coded rate with a disclosure that the estimate is approximate. For precise interest, consult CBP or a customs attorney.
The following are explicitly deferred to later phases. We are not building them in this release:
This tool is for informational purposes only and does not constitute legal advice. Consult a licensed customs broker or trade attorney before filing any CBP Form 19 Protest or Post-Summary Correction.