U.S. Customs and Border Protection has been working to quickly stand up a centralized refund process following the Supreme Court’s decision to strike down broad emergency tariffs. With an estimated $166 billion in IEEPA duties potentially eligible for return, Phase 1 could be a significant cash recovery opportunity for many importers preparing for tariff refund claims.
In its most recent filing with the U.S. Court of International Trade, CBP provided its clearest guidance to date on which entries it will accept in Phase 1, and which it will not. For importers, the update adds important context on eligibility and next steps.
What We Know About the Tariff Refund Claims System
CBP is developing a digital claims system called the Consolidated Administration and Processing of Entries (CAPE). CAPE will exist within the Automated Commercial Environment (ACE), the platform importers already use to file entry summaries and report duty payments.
In our most recent update, we outlined the four-step process CBP proposed to stand up CAPE: Claim Portal, Mass Processing, Review and Liquidation/Reliquidation, and Refund. The latest filing enhances the framework by broadening the definition of eligible entries for Phase 1, which is targeted for late April 2026.
Which Entries Are, and Are Not, Eligible in Phase 1
According to CBP, Phase 1 is expected to cover about 63% of entries for which IEEPA duties were paid or deposited. Eligible entries for tariff refund claims include:
- Unliquidated entries
- Entries within the 90-day voluntary reliquidation window
- Certain entries with suspended, extended or under-review liquidation statuses
- Warehouse and warehouse withdrawal entries
- Certain antidumping and countervailing duty (AD/CVD) entries, where liquidation is suspended pending instructions from the Department of Commerce (DOC)
CAPE will accept declarations containing entries liquidated within the preceding 80 days and will take up to 45 days to review and liquidate validated summaries. That sequencing is designed to meet the 90-day statutory window for most voluntary reliquidations.
CBP also identified several categories that will not be accepted in Phase 1, including:
- Entries flagged for reconciliation
- Entries covered by open protests or drawback claims
- Entries not filed in ACE or lacking a recorded liquidation status
- Certain antidumping and countervailing duty entries
- AD/CVD for which DOC has already issued liquidation instructions
- Finally liquidated entries, which CBP has indicated will be addressed in later phases
Practical Actions for Importers
The most recent update clarifies who is eligible and when. Importers should use that clarity to start preparing now:
- Model realistic cash scenarios: Reflect timing gaps across IEEPA refunds and continued exposure under Section 232 and Section 301 tariffs.
- Get entry data in order now: Compile entry summaries, tariff classifications and proof of duty payment.
- Revisit how IEEPA duties were recorded: Whether capitalized into inventory, expensed through cost of goods sold or recorded elsewhere will determine the financial impact of recovery.
- Evaluate the reporting implications early: Consider how refunds and related interest would appear in current-period financial statements, including presentation and disclosure.
How Grassi Can Help
Grassi’s advisors are here to help you interpret evolving CBP guidance and understand how changes in the tariff landscape may affect cash flow planning, financial reporting, and operational decision‑making within the broader trade and regulatory environment.
For questions about how the tariff refund process may impact your business, reach out to a Grassi advisor today.
Frequently Asked Questions
Q: How will tariff refunds be issued by CBP?
A: CBP is implementing a centralized, electronic system to process tariff refund claims within the Automated Commercial Environment (ACE), with refunds processed in phases.
Q: What are the financial reporting implications of tariff refunds?
A: Refunds may affect inventory valuation, cost of goods sold, prior-period expenses, and current-period disclosures. Businesses should evaluate accounting treatment early to avoid reporting surprises.
Q: Could tariff refunds affect supply chain or commercial arrangements?
A: Yes. Importers of record may need to review supplier, customer, or intercompany agreements to determine how recovered duties are treated contractually.
Q: How can Grassi help with tariff refund planning?
A: Grassi advises businesses on tariff exposure, documentation readiness, and financial considerations, helping leaders understand how evolving CBP guidance may impact planning and decision‑making.
