U.S. Customs and Border Protection (CBP) has outlined how it plans to administer refunds for broad, emergency tariffs struck down by the Supreme Court in a 6–3 decision last month. In a March 12 filing with the U.S. Court of International Trade, the agency described a four-step framework to refund approximately $166 billion in duties paid by more than 330,000 importers of record. CBP has said the refund system could be operational within 45 days. This could be a material cash recovery opportunity for your business, so take the time now to get your company operationally ready to do so.
For businesses operating across global supply chains, the filing offers a clearer view of how refunds may progress and where early preparation may be required.
CBP’s Four-Step Tariff Refund Process
CBP is building refund functionality within the Automated Commercial Environment (ACE), the platform used to process U.S. import entries. The capability will operate through a new module called the Consolidated Administration and Processing of Entries (CAPE).
Under the framework described in the filing, refunds are expected to move through four stages:
1. Refund Claim Submission Through ACE
Importers of record will submit refund requests through a centralized ACE portal using entry-level data submitted via .CSV uploads, either directly or through customs brokers. Automated checks will validate formatting, completeness and eligibility before claims move forward.
2. Mass Tariff Recalculation
Validated entries will move into mass processing, where International Emergency Economic Powers Act (IEEPA) tariffs will be removed and refund amounts recalculated.
3. Liquidation or Reliquidation Review
Entries will then proceed to liquidation or reliquidation, determining when refunds and any applicable interest can be issued.
4. Refund Issuance
Once liquidation or reliquidation is complete, refunds will be consolidated and issued electronically rather than processed entry by entry.
CBP reported the CAPE system is currently between 40%-80% complete across the four functional areas, with additional testing underway.
Electronic Refunds Require Clearinghouse Setup
CBP no longer issues paper refund checks. All duty refunds are issued electronically through Automated Clearinghouse (ACH) transfers within ACE.
Companies expecting refunds should take advantage of the next 45 days and confirm they have active ACE access, ACH enrollment, and current banking information on file. Internal processes for tracking and reconciling refund deposits may also need to be reviewed.
Strategic Considerations for Finance and Operations
As discussed in our earlier alert on CBP’s estimated 45-day timeline for a refund system, companies should expect preparation efforts to involve coordination across finance, operations, and compliance functions.
Practical implications include:
- Data readiness: Refund claims will require complete, consistent entry-level records. Companies should compile entry summaries, classifications, and proof of payment for imports subject to IEEPA tariffs.
- Cash-flow planning: With timing still uncertain, finance teams should model multiple timing scenarios and avoid assuming near-term cash inflows until more guidance is released.
- Inventory and cost accounting: IEEPA duties may have been capitalized into inventory or recognized through cost of goods sold. Companies may need to identify where tariff costs were recorded and assess the impact of any recovery.
- Financial reporting: Affected tariffs may have been recorded in prior periods. Finance teams should evaluate how refunds and any related interest are reflected in current financial statements.
- Supply chain and commercial agreements: Importers of record may need to revisit supplier, customer, or intercompany agreements to determine whether recovered duties are retained, shared, or remitted.
What to Watch Next
CBP has indicated that further guidance will follow as development and testing of the CAPE module continue. Importers should watch for updates on system readiness, ACH processing, and refund timing. Keep in mind that timelines and processes remain subject to litigation outcomes and system readiness. Another status update is expected by March 19.
How Grassi Can Help
Grassi advises businesses across globally connected supply chains as they navigate an evolving tariff and trade environment. Our teams help clients assess the implications of regulatory changes, including tariff refunds, while addressing financial reporting considerations, operational planning, and data readiness across compliance and finance functions.
For questions about the tariff refund process and how potential tariff refunds may affect your operations or forecasts, our advisors can help you understand the implications and consider next steps.
