U.S. Customs and Border Protection is building a new system inside the ACE platform to process refunds of tariffs imposed under the International Emergency Economic Powers Act (IEEPA). The court has not instructed businesses to file refund claims yet.
Quick Takeaways
- Do not file refund claims or lawsuits yet. The court has not instructed businesses to do so, and CBP is still building the refund system.
- Make sure you are enrolled in ACE and set up for electronic refunds. CBP will issue refunds through ACH, not paper checks.
- Start organizing your records now. Track entry summaries and liquidation dates so you are ready when the refund process begins.
Are Tariff Refunds Guaranteed?
The Supreme Court ruled that the tariffs imposed under IEEPA were unlawful. As a result, the government must determine how to return those tariff payments to businesses that paid them.
However, the exact administrative process for issuing refunds is still being developed. The Court of International Trade is currently overseeing that process while CBP builds the system that will be used to administer refunds.
When Will Refunds Happen?
At this stage, there is no official timeline for when refunds will begin.
CBP has informed the court that it is still developing the system that will process refund claims. Once the system is completed and the court provides additional guidance, businesses will receive instructions on how to submit refund requests.
For now, the most important step is preparing your systems and records so you are ready when the refund process opens.
CBP Is Building a New Refund System
The Court of International Trade recently ordered U.S. Customs and Border Protection (CBP) to report on how it plans to process refunds for tariffs imposed under IEEPA.
On March 12, 2026, CBP filed a declaration explaining the system it is currently developing to handle those refunds.
CBP is creating a new capability inside the Automated Commercial Environment (ACE) — the system importers and brokers already use for customs filings.
The new system is called the Consolidated Administration and Processing of Entries (CAPE).
CAPE will be used to process refund requests for tariffs collected under IEEPA.
CBP says the system will have four components:
- Claim Portal – where importers or brokers submit refund requests
- Mass Processing – recalculates duties after removing the tariff codes
- Review and Liquidation/Reliquidation – finalizes corrected duty amounts
- Refund Processing – sends refund payments electronically
How the Refund Process Will Work
Once the system is operational, importers or brokers will submit refund requests through the ACE portal.
The system will then:
- Validate the entries submitted
- Remove the IEEPA tariff codes
- Recalculate duties as if the tariffs had never been imposed
- Schedule entries for liquidation or reliquidation
- Issue refunds electronically
Refunds will be paid through electronic transfer to the importer’s designated bank account.
The System Is Still Under Development
CBP reported the following development progress to the court:
| Component | Status |
| Claim Portal | ~70% complete |
| Mass Processing | ~40% complete |
| Liquidation/Reliquidation | ~80% complete |
| Refund Processing | ~60% complete |
CBP also stated that the system will be released in phases, starting with the most common entry types.
Some more complex entries may be handled in later phases.
Why You Should Not File Refund Claims Yet
Right now, the court has not directed businesses to file refund claims or lawsuits.
Thousands of cases that were already filed in the Court of International Trade have been temporarily set aside while the court and CBP work on a centralized refund process.
Because CBP is still building the system that will process refunds, filing a claim or lawsuit now would likely not move your refund forward and could simply mean spending money unnecessarily.
For most businesses, the best course of action right now is to wait while preparing for the refund process.
How to Prepare for IEEPA Tariff Refunds
Although the refund process has not yet opened, there are several steps businesses can take now to prepare.
- Confirm ACE Access
Make sure your company has active access to the Automated Commercial Environment (ACE) portal.
- Enroll for Electronic Refunds (ACH)
CBP has announced that refunds will be issued electronically through the Automated Clearing House (ACH) system.
Paper checks will generally no longer be used, so companies must ensure their banking information is properly configured in ACE.
- Track Entry Summaries
Maintain accurate records of:
- Entry summary numbers
- Tariff amounts paid
- Liquidation dates
- Assign a Refund Case Manager
Because the refund process may involve submitting lists of entries and tracking liquidation timelines, it is helpful to designate someone inside your company to monitor developments and manage refund claims.
What Happens Next
The Court of International Trade is currently overseeing CBP’s development of the refund system.
In the coming weeks and months, the court will likely:
- Review CBP’s progress building the CAPE refund system
- Consider how refunds should be handled for entries that have already liquidated
- Determine when businesses should begin submitting refund requests
Once the court and CBP finalize the process, businesses will receive clear instructions on how and when to submit refund claims through ACE.
We Will Continue Posting Updates
The court’s refund process is still developing, and additional guidance is expected as CBP completes the system.
We will continue posting updates here so businesses can stay informed about the IEEPA tariff refund process and next steps.
All updates and guidance will continue to be posted on this site.