The ACE Data Guide: Pull Your Own Import History and Quantify Your Tariff Exposure

Most importers rely on broker summaries to understand what they paid in duty, but those reports show only part of the picture. The complete record lives in U.S. Customs and Border Protection's Automated Commercial Environment (ACE), where importers can independently verify the HTS classifications, entered values, Chapter 99 overlays, and duty amounts reported under their importer-of-record number. 

As tariff programs continue to change, access to that data has become essential for validating filings, measuring exposure, and identifying potential overpayments or compliance risks. Historical duty totals alone are no longer enough. A duty amount from six months ago can produce the wrong exposure estimate today unless it is re-priced against the current tariff schedule. 

Getting ACE Access

CBP maintains several ACE Portal account types, including Importer, Broker, Carrier, Filer, and Exporter, each scoped to the data relevant to that role. An importer of record applies for an Importer account through CBP's modernized ACE Portal Account Application webform. Account creation ties to CBP Form 5106, the Importer Identity Input Record, and the verification code CBP sends during signup goes to the point-of-contact email on that 5106 record. An outdated broker email on the record is one of the most common causes of onboarding delay, so confirming that contact first saves days.

Inside an account, a Trade Account Owner holds full administrative control and can create sub-users, AP staff, logistics, and compliance, with scoped, role-based permissions. Multiple people can share one company account, and the owner can grant cross-account access to a broker or drawback provider through a Power of Attorney without ever sharing login credentials. Registration and use of the ACE Portal are free.

The stakes of not having an account are concrete. An importer with only a broker relationship sees whatever the broker forwards, typically a 7501 PDF. An importer with its own ACE account sees, independently, the full entry-summary header and line-level detail CBP has on file, including the duty, tax, and fee amounts actually assessed and paid.

Pulling Your History: ACE Reports

ACE Reports are available within the modernized ACE Portal and organized by subject area in CBP's reports catalog. For tariff-exposure analysis, a handful of reports provide most of the data importers need:

• ES-001 Entry Summary Header Details: Header-level information for each entry summary.

• ES-002 Entry Summary Line Details: Commodity-level details for each entry.

• ES-003 Entry Summary Line Tariff Details: Tariff-line data, including Chapter 98 and 99 overlays. This is the primary report for most duty-exposure and broker-audit analyses.

• ES-006 Entry Summary Dimensions by Value: Aggregate entry-value summaries for validating line-level results.

• TR-004 and TR-005 (Section 301) and TR-001 through TR-003 (Section 232): Trade-remedy reports that isolate duties collected under those programs.

• ITRAC Entry Summary reports: Header, line, and tariff-level views showing estimated, ascertained, and paid amounts.

Importers can run ES-001 through ES-003, ES-006, and the TR reports directly through their ACE accounts without relying on a broker.

Running and Exporting a Report

Once the account is active, generating a report takes only a few steps:

1. Sign in to ACE and select the appropriate company account.

2. Open the Entry Summary or Trade Remedy reports folder and choose the required report, such as ES-003.

3. Enter the Trade Account ACE ID and the required search parameters, including the reporting period.

4. Run the report and export it in Excel, CSV, PDF, HTML, or TXT format.

5. Schedule recurring reports if regular monitoring is required.

The Fields That Drive an Exposure Model

The fields that actually build a duty-exposure figure live at the tariff-line level, in ES-003 or its ITRAC equivalent, because a single commodity line can carry multiple stacked HTS numbers. The ones that matter most:

Reading Chapter 99 Overlay Lines

CBP's order-of-reporting guidance specifies the mandatory sequence when a Chapter 98 or 99 HTS applies: Chapter 98 first if applicable, then Chapter 99 numbers for additional duties, with Section 301 reported before Section 232 or 201 overlays and quota numbers last, followed finally by the Chapter 1 through 97 commodity line. Entered value is reported against the Chapter 1 through 97 line, not the overlay, which creates the single most common analysis error: because each overlay ordinal appears as its own row in exported data, summing the value field across all ordinals on a line overstates the entered value several times over. An analyst has to join overlay duty amounts back to the base line's value to compute a correct effective rate.

Turning the Data Into an Exposure Figure

Building a defensible exposure number is a three-stage process.

Stage 1, reconstruct historical duty paid 

Pull ES-003 for the date range, group rows by Entry Summary Number, base HTS number, and country of origin, sum the Line Tariff Duty Amount across all ordinals attached to that base line, and divide by the base line's entered value to derive the effective rate actually paid.

Stage 2, isolate overlay-program costs. 

Rather than parsing Chapter 99 numbers manually, use the purpose-built trade-remedy reports: the TR-004 and TR-005 reports return Section 301 totals and detail, and the TR-001 through TR-003 reports return Section 232 detail. Cross-referencing these against the ES-003 pull validates that overlay duty has been correctly separated from base duty.

Stage 3, reprice under current rates, not historical rates. 

This is the step most analyses get wrong by treating "duty paid" as "duty exposure." The rate an entry cleared under months ago frequently no longer applies:

• IEEPA-based reciprocal, fentanyl-trafficking, and related country-specific tariffs were struck down by the Supreme Court on February 20, 2026, and CBP stopped collecting them effective February 24, 2026. Entries that historically paid these overlays should not have that rate projected forward.

• A global Section 122 surcharge replaced the IEEPA tariffs from February 24, 2026, but is scheduled to expire by operation of law on July 24, 2026, absent congressional extension, with litigation over its legality still on appeal. Any model built now must state explicitly whether it assumes the Section 122 surcharge continues, lapses, or is replaced by a new action.

• Section 301 China tariffs, generally 25 percent with List 4A at 7.5 percent and up to 100 percent on select additions, were unaffected by the IEEPA ruling and remain in force, with exclusions extended through November 10, 2026.

• Section 232 tariffs on steel, aluminum, copper, and autos, plus patented pharmaceuticals under an April 2026 executive order, also remain unaffected and stack with Section 301 in many cases, subject to anti-stacking rules.

A defensible exposure figure therefore pulls the current, dated rate for each active HTS, country, and program combination from primary sources, not from the historical duty-paid column, and applies it to the entered-value base from Stage 1. Scenario modeling, such as resourcing a line from Vietnam instead of China, substitutes the target country's applicable rate against the same value base.

What the Data Usually Reveals

Importers who run this analysis for the first time are frequently surprised by how much is wrong in their own filings. When Gaia analyzed nearly 30,000 entries and almost 270,000 line items across a broad range of industries, origins, and tariff conditions, roughly one third of the entries contained discrepancies. The total value of misalignment, combining recoverable overpayments and underpayment exposure, exceeded $64 million. The pattern that makes this so consequential is that overpayments and underpayments tend to appear together, sometimes within the same importer's data, so a company that goes into ACE looking only for refunds ends up reopening its entire data set, including the underpayments that carry their own liability. Pulling the data is not just a refund exercise; it is the only way for importers and exporters to see both sides of the ledger before CBP does.

Common Mistakes

• Relying only on broker summaries: A 7501 PDF may omit Chapter 99 overlay lines or roll up tariff sequences that ACE returns as separate rows; only a direct pull under your own account guarantees completeness.

• Mismatched date ranges: Entry Date, Entry Summary Date, Liquidation Date, and Exportation Date can all differ for one transaction; the wrong date field can include or exclude entries relative to a program's effective date.

• Ignoring Chapter 99 lines: Failing to join overlay rows back to the base line either understates duty exposure or, if value fields are summed across ordinals, wildly overstates the value base.

• Treating historical rates as current: Given the IEEPA invalidation and the Section 122 surcharge's scheduled sunset, an effective rate computed from last year's data may bear no relationship to next month's entries.

• Assuming ACE access equals refund readiness: Even after the Supreme Court ruling, CBP reported that only roughly 6 to 7 percent of the approximately 330,566 importers who paid IEEPA duties had completed ACH refund enrollment in ACE by mid-2026, and refunds are rejected until that setup is validated, a step distinct from simply having report access.

Own Your Data Before Someone Else Reads It for You

The importers who navigate a volatile tariff environment well are the ones who own their entry data outright rather than depending on a broker to retrieve a slice of it. An ACE account is free, the reports are built for importers to run directly, and the exposure math, once the overlay lines are joined correctly, is repeatable. The discipline that separates a real exposure figure from a comforting one is repricing against current rates instead of extrapolating last year's, because the same government that is issuing refunds is also using this data to audit. Building the Section 232 and duty-stack visibility to see both the overpayments and the underpayments in your own history is the prerequisite for every decision that follows: a refund claim, a sourcing shift, or an audit defense.

See how Gaia helps importers analyze ACE data, quantify tariff exposure, and identify duty savings and compliance risks before they become costly. 

Frequently Asked Questions 

Do I need my own ACE account, or can I rely on my broker?

You need your own ACE account to access the complete CBP record. Broker summaries may omit Chapter 99 overlay lines or consolidate tariff sequences that ACE reports separately. An ACE account provides direct access to entry-level duty, tax, fee, and HTS data, and registration is free. 

Which ACE report shows the data I need for a tariff-exposure analysis?

ES-003 Entry Summary Line Tariff Details is the primary report because it includes tariff-level data and Chapter 98 and 99 overlays. TR-004 and TR-005 isolate Section 301 duties, while TR-001 through TR-003 cover Section 232. ES-006 provides a useful aggregate cross-check. 

Why can't I just project last year's duty rate forward?

Because tariff programs change frequently. Historical duty rates may no longer apply due to changes in Section 122, Section 301, Section 232, or other trade measures. Exposure should always be calculated using the current rates in effect at the time of analysis. 

Does having ACE report access mean I am set up to receive IEEPA refunds?

No. ACE report access and ACH refund enrollment are separate. You can view your import data without being enrolled to receive refunds, and refund payments will not be processed until ACH enrollment is complete and validated.