There are four ways to file an IEEPA duty refund through CBP's CAPE system: flat-fee software, a customs broker on contingency, a trade law firm billed hourly, or do it yourself with a calculator and manual CSV work. Each maps to a different cost structure — flat, percentage, time, or internal labor. This guide walks the dollar math at four refund sizes, explains what each fee buys, and identifies when each choice is the right one.
The three cost structures (plus DIY)
Flat-fee software (un-tariff): a fixed price per filing based on analysis depth and entry count — not refund size. The Starter tier is $199 for up to 100 entries with rules-only classification. Standard is $799 for up to 1,000 entries with LLM-assisted classification (handles stacked tariffs under IEEPA-005 and USMCA exclusions under IEEPA-006). Premium is $1,499 for up to 9,999 entries with a full eligibility narrative that includes rule IDs and CROSS-ruling citations. All three tiers produce a CBP-validated CAPE CSV.
Contingency (customs broker): a percentage of the recovery, typically 10–25%, with 15% as the common midpoint. Some brokers quote hourly ($250–$500/hr) or flat rates of $2,000–$10,000 per declaration for enterprise clients. The percentage model is most common for IEEPA work because refund size is uncertain until CBP processes the claim.
Hourly (trade law firm): billed at $400–$900/hr, typically 10–40 hours for a clean CAPE filing. For protest-track filings — entries past the 80-day liquidation cliff, disputed origin claims, or complex exclusion challenges — the range expands to 20–80 hours. Law firms provide legal privilege and can sign arguments that a broker or software cannot.
DIY + calculator: zero tool cost for the calculation step (tools like TariffRefundIQ run $99–$199 one-time, or TariffRefundsCalculator.com at a similar price point). The calculator gives you the estimated refund amount. It does not produce a CATAIR-compliant CAPE CSV — that part remains manual. First-time DIY filers typically spend 8–20 hours learning the workflow: ACE export, HTS registry lookup, quarterly interest walk, CATAIR-spec CSV format, and CBP's VAL-F/E/I validation rules.
The comparison table
The table below shows total filing cost at four refund sizes. Law firm figures use 20 hours at $600/hr — a reasonable midpoint for a clean CAPE filing without protest complexity. Starter dashes at $100K and $500K reflect likely entry-count overflow (100-entry cap means a $100K+ refund spread across many lines usually exceeds Starter's scope, not that the price is unavailable).
| Refund amount | Starter $199 | Standard $799 | Premium $1,499 | Broker 15% | Law firm (20 hr × $600) |
|---|---|---|---|---|---|
| $10,000 | $199 | $799 | — | $1,500 | $12,000 |
| $50,000 | $199 | $799 | $1,499 | $7,500 | $12,000 |
| $100,000 | — | $799 | $1,499 | $15,000 | $12,000 |
| $500,000 | — | — | $1,499 | $75,000 | $12,000 |
At $500,000, the broker takes $75,000. Premium takes $1,499. The law firm takes $12,000 if the filing is clean. The law firm becomes competitive with the broker above roughly $80,000 in refund principal — but only if the filing needs legal argument. For a clean CAPE claim inside the 80-day window, it does not.
What each fee actually buys
un-tariff (all tiers): classification of each entry line against the IEEPA HTS registry, per-entry 80-day cliff check, interest computation using the CBP quarterly overpayment rate at 19 CFR 24.3a, CATAIR-spec CAPE CSV generation, and local VAL-F/E/I validation before download. Standard and Premium add LLM-assisted classification for stacking (IEEPA-005) and USMCA exclusions (IEEPA-006). Premium adds a full eligibility narrative with rule IDs and CROSS-ruling citations — useful as documentation for accounting or a future audit.
Customs broker (contingency): professional license-holder who can represent you at CBP, brokered account access, and experience across many importers' filings. For CAPE, the broker handles the same mechanical steps: classify, compute interest, build the CSV. For protest-track work — past the 80-day cliff, disputed origin, entry reliquidation disputes — a broker's CBP relationships and representation authority add real value.
Trade law firm (hourly): legal privilege (attorney– client), ability to draft and sign formal legal arguments, and specialist counsel for contested classifications, USTR exclusion challenges, and protest hearings. The law firm is the right choice when the filing involves argument — not when it involves mechanical CSV generation. Legal privilege also matters if you expect the filing to be challenged or audited.
DIY + calculator: full control, zero vendor dependency, and a refund estimate you can verify yourself. The calculator tools give you the total; the CATAIR-compliant CSV build and VAL-F/E/I validation remain on you. Appropriate when the internal team has trade compliance capacity, the filing is small, and the time cost is budgeted.
Break-even math
At 15% contingency, the break-even refund size for each un-tariff tier — the point where the flat fee equals what a broker would charge — is straightforward:
- Starter $199: $199 ÷ 0.15 = $1,327 break-even. Any refund above $1,327 and the Starter fee is lower than a 15% broker contingency.
- Standard $799: $799 ÷ 0.15 = $5,327 break-even. Above $5,327, Standard costs less than 15% contingency.
- Premium $1,499: $1,499 ÷ 0.15 = $9,993 break-even. Above $9,993, even the top-tier un-tariff fee is cheaper than a 15% broker contingency.
Put another way: for any CAPE-eligible refund above $10,000, the Premium flat fee is a rounding error compared to what a contingency broker retains. The crossover happens fast.
Broker rates vary. At 10% contingency, the break-even for Starter rises to $1,990 and for Premium to $14,990. At 25%, it drops to $796 for Starter and $5,996 for Premium. The math favors flat-fee software across the full contingency range for any refund large enough to matter.
Hidden costs (total cost of ownership)
The headline fee is not the full cost. Four gotchas that matter for CFO-level budget planning:
1. Broker contingency on gross vs net. Contingency contracts typically charge on the gross refund — principal plus interest — not on the net amount after the broker's fee. On a $100,000 principal refund with $18,000 in accrued interest, gross is $118,000. At 15% of gross, the broker takes $17,700, leaving you $100,300. If the contract charges on net ($100,000 principal only), the broker takes $15,000 and you keep $103,000. Read the contract. The difference is $2,700 on a $100K filing.
2. Law firm scope creep. A "clean filing" estimate of 10 hours can balloon to 25+ when USMCA exclusion questions or stacking issues surface mid-engagement. Both require legal analysis and add billable hours the initial estimate did not include. Budget conservatively, or scope the engagement with a hard cap.
3. DIY time cost. Twenty hours of first-filing learning curve is not free — it is internal labor. For a $100/hr trade compliance employee, that is $2,000 in soft cost, often unbudgeted and invisible in the project comparison. For filings where internal expertise does not already exist, the true DIY cost is closer to a consultant's fee.
4. Calculator-to-CSV gap. Standalone refund calculators (TariffRefundIQ, TariffRefundsCalculator.com) give you the refund estimate. They do not produce a CATAIR-compliant CAPE CSV. The step from calculator output to a valid CBP upload still requires 6–10 hours of manual work for a clean first filing — the interest walk across quarter boundaries, the entry-number format validation, the header row matching CBP's exact template. That labor belongs in any honest DIY cost comparison.
When each choice is right
The decision is not purely about cost — it depends on filing complexity, entry count, whether the 80-day CAPE window is still open, and whether the filing needs legal argument. A short decision tree:
- Refund under $1,500 + clean tariff structure + internal DIY capacity: use a calculator ($99–$199 one-time) plus manual CSV build. The flat-fee savings over a broker don't fully offset the investment.
- Refund $1,500–$50,000 + clean tariff structure + under 100 entries: Starter at $199. The break-even vs a 15% broker is $1,327 — you are well above it, and the entry count fits the cap.
- Any refund size + stacked tariffs (IEEPA-005) or USMCA origin (IEEPA-006): Standard at $799. LLM-assisted classification is required; rules-only Starter will produce incorrect output on these edge cases.
- Any refund size + 1,000 or more entries: Premium at $1,499. Both Starter and Standard hit their entry caps; Premium handles up to CBP's 9,999-entry CAPE limit.
- Past the 80-day liquidation cliff: CAPE is closed. Recovery requires a formal protest under 19 CFR Part 174 within the 180-day protest clock — a legal filing that needs a customs broker or trade law firm. un-tariff Phase 1 does not handle protest-track filings.
- Disputed exclusions, contested origin, or argument-heavy classification: trade law firm. Attorney–client privilege, formal legal argument, and CBP hearing representation are not things software provides.
Common questions
Why is un-tariff so much cheaper than a broker?
un-tariff charges a flat fee per work done, not a percentage of your recovery. A broker's contingency scales with refund size even though the underlying work — classifying entries, building the CAPE CSV, running CBP validation — is roughly the same regardless of whether the refund is $10,000 or $500,000. Flat-fee software front-loads that engineering once and prices it accordingly.
Is there a catch at Starter $199?
No. The $199 Starter tier includes full CAPE CSV generation, VAL-F/E/I validation against CBP's rules, and a 90-day re-download window. The limits are 100 entries and rules-only classification — no LLM assistance for stacked tariffs (IEEPA-005) or USMCA exclusions (IEEPA-006). If your filing involves those edge cases, the Standard tier ($799) handles them.
What about large refunds — doesn't a broker's expertise justify 15%?
For filings inside the 80-day CAPE window with a clean tariff structure, the expertise differential is narrow. CAPE is a CSV upload to the ACE Portal — not a protest filing. Broker expertise adds the most value when the filing requires legal argument: protests, disputed origin, exclusion challenges. For straightforward IEEPA refund claims, the rules are mechanical and CBP's CAPE Phase 1 process is designed to be self-service.
How does hourly vs flat-fee compare on actual hours worked?
Software produces a validated CAPE CSV in a few minutes. A law firm billing 10–40 hours on the same filing is not spending that time generating the CSV — most of the time is intake, conflict check, eligibility opinion, client correspondence, and review. Hourly billing prices the overhead around the filing, not the filing itself. That overhead is valuable when a filing involves disputed classification or protest-track argument. For a clean CAPE claim, it is a mismatch between what you need and what you are paying for.
Is there a pay-by-results option like Tariffi.io?
Tariffi.io's no-recovery-no-fee structure requires a licensed customs broker to hold the contract under 19 CFR § 111.36. un-tariff is software, not a licensed broker. The equivalent risk-reversal is: use the free refund calculator to confirm you have a valid refund before purchasing, and if a tier selection mismatch is found post-upload, an upgrade credit covers the difference — you never pay for the higher tier twice.
What if I want a second opinion before paying $199?
Use the free refund calculator at /refund-calculator. No account required, no card. Enter total import volume and entry characteristics and the calculator returns a refund-band estimate. That estimate is the first sanity check before committing to any paid tier.
Not sure which tier fits your filing? The free refund calculator gives a refund-band estimate with no account or card required. The pricing page walks each tier's entry cap, analysis depth, and support SLA side by side.