Partial assignment lets you sell some of your IEEPA entries while filing the rest through government channels. The question is how to split them optimally.
Not every importer needs a full exit. The Supreme Court’s 6-3 ruling in Learning Resources v. Trump (February 2026) declared IEEPA tariffs unconstitutional and created a $166 billion refund pool. CBP must refund duties collected under HTS headings 9903.01 and 9903.02 between February 2025 and February 2026. For many importers, the right answer is a hybrid approach that converts a portion of the claim to immediate capital while preserving upside on the remainder. The strategies below represent the most common frameworks we see in practice.
Strategy 1: Sell by Entry Age
Older entries — those approaching their 180-day protest deadline under 19 USC 1514 — carry more processing risk. They are candidates for immediate sale. Newer, unliquidated entries have more time and may benefit from post-summary corrections through CAPE under 19 USC 1520(d).
Selling the high-risk entries and retaining the low-risk ones may maximize total expected recovery across both channels. The time value analysis becomes especially relevant here: older entries have accrued more statutory interest under 19 USC 1505(c), which increases their face value but also concentrates deadline risk. Converting those entries to capital eliminates that risk while capturing much of the accrued value.
Liquidated entries that are approaching the protest window require particular attention. If the 180-day deadline passes without action, the opportunity to recover those duties may close permanently. For importers managing hundreds of entries across multiple brokers, tracking these deadlines is a meaningful administrative burden. Selling the time-sensitive entries eliminates both the deadline risk and the tracking overhead.
Strategy 2: Sell to Fund Operations
Calculate your near-term capital needs. Sell enough entries to cover that amount. Retain the rest for full face value recovery through government channels. This approach uses claim structuring as a liquidity tool rather than a full exit.
For importers still actively importing under current tariff rates, this strategy can be particularly effective. The capital from a partial sale may offset ongoing duty payments or fund inventory purchases — keeping the business liquid while the remaining claims work through government processing. There are specific scenarios where selling outright is the clear winner, and operational cash flow pressure is near the top of that list.
The ACE system allows entry-level data export, which means each entry can be independently valued and assigned. CBP processes entries individually, not as portfolios, so splitting a claim into sold and retained portions creates no administrative complication. Your customs broker exports the ES-003 report, we validate each entry against IEEPA-affected HTS codes, and you decide which entries to monetize based on your capital requirements.
Strategy 3: Sell Complex, File Simple
Entries with mixed HTS classifications, multiple tariff programs, or contested liquidation status are harder to process through CAPE. They take longer, require more administrative attention, and carry higher uncertainty. Selling those while self-filing straightforward single-program entries reduces your administrative burden.
This strategy works well for importers with large, heterogeneous portfolios — those with hundreds or thousands of entries spanning multiple product categories across EO 14257 (reciprocal tariffs), EO 14195 (China), EO 14193 (Canada), and EO 14194 (Mexico). The complex entries may involve classification disputes, broker errors, or overlapping tariff programs that create processing ambiguity. Transferring that complexity to a buyer who has dedicated resources to resolve it can be more efficient than managing it internally.
For importers with entries under multiple executive orders, the valuation may vary significantly by program. Entries with clear, single-program HTS classifications are straightforward for self-filing. Entries where duty amounts overlap with Section 301 tariffs or involve contested classifications benefit from specialized analysis — which is precisely what the valuation process provides at the entry level.
How the Split Works Mechanically
Each entry is a discrete unit. Assignment agreements can specify exactly which entries are included by Entry Summary Number, date, and HTS code. There is no requirement to sell the entire portfolio as a single block. The valuation we provide covers your full portfolio with entry-level detail — you see what each entry may be worth and can allocate intelligently between sale and self-filing.
The closing documents for a partial assignment are identical in structure to a full sale. The only difference is the entry schedule attached to the agreement. Retained entries remain fully under the importer’s control for direct government recovery through CAPE.
How to Decide
The optimal split depends on your capital position, risk tolerance, and administrative capacity. Our valuation covers your full portfolio with entry-level detail. You see exactly what each entry may be worth and can allocate intelligently. Customs brokers and trade attorneys who advise importers on these decisions can coordinate through the partner network at tariffpartners.com.
For a complete assessment of all four recovery paths, tariffresolution.com provides comprehensive guidance. Not sure whether your entries qualify? The free screening tool at tariffrefundchecker.com can help determine eligibility in minutes.
Ready to see your entry-level valuation? Request a confidential Impact Assessment to get started — there is no cost and no obligation to proceed with any transaction.