For licensed customs brokerages
Handle refunds and rate changes without hiring another entry writer
Lunan trains your team to use AI inside the line US Customs and Border Protection (CBP) drew in ruling H350722, then sets up drafts for refund declarations, invoice data and client notices. Your licensed broker decides every line before anything is filed.
By September 2026, more than 286,000 refund declarations for IEEPA (International Emergency Economic Powers Act) tariffs, covering about 27.2 million entries, had been submitted to CBP. Source: C.H. Robinson client advisory, Sep 2026
What gets in the way
Tariff rules keep moving under filed entries
When rates change, your team redoes filings while new entries keep arriving. NCBFAA's then-president told Reuters in June 2025 that some of the automation brokers used "has been thrown out."
Refund declarations landed on top of daily work
Sorting each client's entries for a refund declaration, chasing missing banking details and tracking phases all compete with today's entries.
Nobody says plainly where AI is allowed
Vendors pitch classification tools, practitioner forums are skeptical, and CBP's ruling H350722 puts the decision on your licensed broker. Meanwhile the first continuing-education (CE) deadline is January 31, 2027.
What we set up
Refund declaration draft from your entry data
AI cleans your ACE (Automated Commercial Environment) or broker-software entry exports, tags each entry as likely eligible, not yet eligible or needs a look, with the reason in plain words, and flags missing importer or banking details. Your licensed broker picks the entries and approves the declaration before it is filed in CAPE, CBP's refund tool.
Before: hand-sorting entry reports per client. After: a sorted draft list with reasons, ready for the broker to approve or change.
Commercial invoice data into your broker software
AI reads commercial invoices and packing lists and pre-fills a draft worksheet or import file for your ABI (Automated Broker Interface) software. Under H350722, pre-filling entry data is customs business, so it runs only inside your brokerage, at your broker's direction, and nothing transmits without their review.
Before: retyping invoice lines. After: checking a pre-filled draft against the source document.
Client notices when rates change
When a tariff changes, AI finds the clients and products affected in your own records and drafts a short note for each. You decide what goes out and when.
Before: writing each notice from scratch. After: reviewing drafts the same day the change lands.
How it works
- 1
Free conversation
You walk us through how an entry and a refund move through your office. You get a short written read of where AI can help and where it must stay out.
- 2
Train your team
A hands-on session for entry writers and brokers on AI use under H350722, using your own document types, plus an AI-use policy and client authorization template. CE credit applies only when the hosting association has the course approved by a CBP-selected accreditor in advance, and we say up front whether it has.
- 3
Build one workflow and back-test it
We set up one workflow inside the accounts and software you already use, test it against entries you have already filed, and keep a licensed broker as the decision-maker on every line.
Ways to work together
Each is scoped and quoted after the conversation.
Learn
Brokerages that want staff trained and a policy in place before adding tools
- Hands-on session on AI use under ruling H350722
- Exercises on your own invoice and entry types
- AI-use policy and client written-authorization template
- Where AI helps and where it must stay out
- CE credit when the host has the course accredited in advance
Build
Offices ready to cut refund and data-entry workload
- One workflow: refund declaration draft, invoice pre-fill or client notices
- Back-test on entries you already filed
- Review queue and change log for your licensed broker
- Set-up and back-test of the classification tool you choose
- Staff training on the finished workflow
Run
Offices that want it kept current as CBP guidance and tariffs change
- Monthly check of AI drafts against broker edits
- Updates when CBP guidance or tariff rules change
- Prompt and template fixes
- Draft and edit logs kept in your accounts for the 5-year record
- Monthly review call
Guardrails
Under CBP ruling H350722, software cannot decide what goes on an entry, so every code, pre-filled field and refund declaration we set up is a draft that your licensed broker directs, reviews and decides; we never deliver 8- or 10-digit codes or entry data to importers. Client data stays in your accounts on US-region services, shared with an AI service only with your client's written authorization, as the 2022 Part 111 rules allow, and drafts and edits are kept with the entry file for at least the 5-year retention period in 19 CFR 111.23. Our fees are flat and never tied to the entries you file.
Questions
Is it legal for a brokerage to use AI on entries?
Yes, within limits. CBP ruling H350722 (January 2026) found that a tool pre-filling entry data is customs business, and that 8- or 10-digit AI classification handed to customers improperly directs entry preparation. So a licensed broker must direct the tool and decide what goes on the entry. We build to that line. Lunan is not a law firm, so confirm your setup with customs counsel.
Does your training count toward my CE credits?
Only if it was approved in advance by one of the accreditors CBP selected, such as NEI (the NCBFAA Educational Institute). Lunan can't grant credit. When an association hosts our session and gets it accredited, the listing will say so; if it doesn't say so, assume no credit.
Can our client data go to an AI service?
The 2022 broker rules let you share client information with a third party when the client authorizes it in writing, and original records must stay in the US customs territory. We set up US-region services, turn off vendor training where offered, and give you an authorization clause and a map of where every file goes.
Do we have to buy a new classification tool?
No. Lunan doesn't sell one. If you run CargoWise or Magaya, we test their built-in AI features first. If you pick a separate tool, we set it up and back-test it on your own filed entries so you can see where it is wrong before your team relies on it.
Will this replace my entry writers?
No. It drafts; your people review and your licensed broker decides. The aim is less retyping and sorting, so experienced staff spend more time on judgment calls, client questions and refund exceptions.
Reading list
- AI for customs brokers: where it helps a small brokerage and where the license line sits
A plain map of where AI helps an owner-run brokerage, what H350722 and the 2022 Part 111 rules require, and how to start without risking the license.
- CBP ruling H350722 explained: an AI review checklist for customs brokers
A feature-by-feature reading of H350722 and a printable checklist covering tools, entries, records, fees and staff.
- Drafting IEEPA refund (CAPE) declarations from your entry data, with the broker in control
A step-by-step workflow for drafting the entry list behind a CAPE declaration, with AI sorting and explaining and the broker deciding and filing.
- Customs broker CE credits before January 31, 2027: how the rules work and where AI training fits
The CE rules, the accreditor step, what sessions cost, a catch-up plan for brokers who are behind, and why AI rules are worth a few credits.
- AI classification tools for customs brokers: what they cost and how to back-test one
A price table of AI classification tools (vendor figures), a back-test method using your own filed entries, and a buy/don't-buy worksheet.
Get a read on your entry and refund workload
Start a free conversation. You walk us through how an entry and a refund move through your office, and we send a short written list of where AI could help and where it should stay out.