Is FOIA the fastest way to get CBP entry data?

Usually no. If you are the Importer of Record, ACE exports or your broker's records are usually faster and more complete for refund analysis. FOIA and ITRAC can help as fallback paths, but they are not deadline-safe substitutes for direct broker or ACE retrieval.

What import entry data do I need for tariff refund analysis?

You usually need entry number, entry date, port, Importer of Record identity, HTS and Chapter 99 lines, duty amounts, and liquidation status or liquidation date.

FOIA vs ACE vs Broker Records: Fastest Ways to Get Import Entry Data

Quick Answer

If you need import entry data, use this order:

ACE if you are the Importer of Record and have access.
Your broker or filer if they cleared the entries.
Carrier/forwarder records if you only have shipment or duty-invoice references.
IOR authorization/cooperation if you are the consignee or buyer but not the IOR.
FOIA / ITRAC as a fallback, not as your first deadline-critical path.

For refund review, the minimum record is: entry number, entry date/port, IOR identity, HTS/Chapter 99 lines, duty amounts, and liquidation status/date. (CBP Form 7501 overview, CBP ACE Reports, CBP ITRAC Requests)

Informational only - not legal advice.

The practical rule

FOIA is a public-records mechanism. ACE and broker records are operational trade records.

That distinction matters. If your goal is to calculate tariff exposure, file a CAPE declaration, prepare a PSC/protest package, or build a liquidation deadline calendar, you usually need structured entry-level data quickly. FOIA can be useful, but it is usually slower and less controllable than ACE exports or broker/filer records.

The minimum record you are trying to get

Before choosing a path, define the output:

Field	Why it matters
Entry number	Join key across 7501s, ACE exports, broker statements, liquidation, and refunds.
Entry date and port	Anchors timing and CBP context.
Importer of Record identity	Determines authorization, standing, and refund routing questions.
HTS and Chapter 99 lines	Identifies IEEPA, Section 122, Section 232, Section 301, AD/CVD, or base duty.
Duty amounts	Drives exposure and refund math.
Liquidation status/date	Drives PSC vs protest timing and deadline calendars.

If a source cannot return those fields, it may still be a lead source, but it is not a complete refund-analysis source.

Path 1: ACE exports

Best when: you are the IOR and have ACE access, or your broker can export ACE-style data for you.

Ask for:

Entry Summary export with line-level HTS/Chapter 99 and duty amounts
Account Revenue / liquidation / statement data
Entry type
IOR and consignee fields

ACE exports are usually the best format for bulk analysis because they are structured and can cover many entries at once. CBP's ACE Reports materials describe ACE Reports and trade report resources, and CBP has also identified specific ACE reports for monitoring CAPE declarations and refunds. (CBP ACE Reports, CBP CSMS #68536553)

Caution: ACE access is role/account gated. A consignee or buyer may not be able to pull the IOR's ACE data without authorization.

Path 2: Broker or filer records

Best when: you know who filed the entries.

For most importers, the broker is the fastest path because the broker has the entry summary data, broker file references, and sometimes line-level exports that are easier to use than PDFs.

Ask for:

Please provide CBP Form 7501 Entry Summary PDFs, continuation sheets, and an entry summary export in CSV or Excel format for the entries below. Please include entry number, entry type, entry date, port, IOR, consignee, HTS/Chapter 99 lines, duty amounts, and liquidation status/date if available.

If they cannot produce 7501 PDFs, ask for the electronic equivalent or a broker entry-detail export. CBP regulations recognize CBP Form 7501 or an electronic equivalent for the entry summary in the relevant formal-entry contexts. (19 CFR 142.11)

Path 3: Carrier and forwarder records

Best when: you have tracking, AWB, BOL, invoice, or delivery references but do not know the entry numbers.

Carriers and forwarders may not have the full entry summary, but they can often identify the broker/filer, entry number, shipment-to-entry mapping, or customs packet.

Ask for:

entry numbers tied to tracking/AWB/BOL references,
customs packets,
carrier duty/tax invoices,
broker/filer name,
shipment-to-entry-number report,
any available 7501 or ACE-style export.

If the carrier says it cannot release the 7501, ask whether it filed the entry, whether another broker filed it, and what authorization is required from the IOR.

Path 4: IOR authorization or cooperation

Best when: you are the buyer, consignee, or party who paid the invoice, but not the IOR.

Do not assume that paying duties on a commercial invoice means you control the entry record. The IOR shown on the entry summary is the key record identity.

If you are not the IOR, ask the IOR for:

direct copies of the records,
written authorization for the broker/carrier to release records,
confirmation of whether any refund claim has been filed,
agreement on who will handle refunds if money is returned.

This is usually faster than FOIA when the relationship is cooperative.

Path 5: FOIA and ITRAC

Best when: direct ACE/broker/carrier/IOR paths have failed or you need a government-returned dataset for your own importer account.

CBP accepts FOIA requests through SecureRelease. CBP also has an Importer Trade Activity (ITRAC) request path, historically used by Importers of Record, filers, and legal representatives seeking import data under FOIA. CBP's ITRAC page notes that ITRAC data has been provided to IORs, filers, and legal representatives and lists entry numbers among the kinds of data involved. (CBP FOIA records page, CBP ITRAC Requests)

Use FOIA/ITRAC carefully:

It may be slower than broker or ACE retrieval.
It may not return the exact format your analysis needs.
It may require consent/authorization for third-party records.
It is not a substitute for a protest deadline calendar.
It may be useful for historical or bulk importer data when direct records are unavailable.

Decision tree

Your situation	Start here
You are the IOR and have ACE access	Pull ACE Entry Summary + Account Revenue exports.
You are the IOR but do not have ACE access	Ask your broker/filer for 7501s and exports; consider ACE setup in parallel.
You know the broker/filer	Request 7501 PDFs, continuation sheets, and a CSV/Excel entry-detail export.
You only have tracking/AWB/BOL or duty invoices	Ask the carrier/forwarder for entry numbers, customs packets, and filer identity.
You are the buyer/consignee but not the IOR	Get IOR cooperation or authorization first.
All direct paths fail	Consider FOIA/ITRAC, but keep deadline work moving separately.

Copy/paste request templates

Broker/filer request

Subject: Entry Summary Records Request - [Company] - [Date Range]

Body:

Please provide CBP Form 7501 Entry Summary PDFs, continuation sheets, and any available ACE or broker entry summary export for the entries or shipments below.

Please include entry number, entry type, entry date, port, Importer of Record, ultimate consignee, HTS/Chapter 99 lines, duty amounts, and liquidation status/date if available.

Identifiers:

Legal company name:
EIN/importer number, if known:
Date range:
Entry numbers, if known:
Tracking/AWB/BOL/invoice references:
Delivery/consignee address:

Carrier/forwarder request

Subject: Customs Entry Numbers and 7501/ACE Records - [Company] - [Date Range]

Body:

Please provide the customs entry numbers and any customs packets, CBP Form 7501 PDFs, ACE-style entry summary exports, duty/tax details, and broker/filer identity for the shipments below.

If your organization did not file the entries, please identify the broker/filer or filer code if available and explain what authorization is required to release the entry records.

IOR authorization request

Subject: Authorization to Retrieve Customs Entry Records - [Shipments/Date Range]

Body:

We are trying to retrieve customs entry records for shipments where your organization may be listed as Importer of Record. Please either provide the entry summaries/exports directly or authorize the broker/carrier to release them to us.

The requested records are CBP Form 7501 PDFs, continuation sheets, ACE/broker entry summary exports, liquidation status/date, and duty line detail.